Hi Safety folks, Many good points in this discussion. For us up here in Scandinavia, we se the U.S. market as one Market and we can not (may be we should..) go into law details for the City of LA, Santa Clara County and so on.
If there are States or Cities in the U.S. which require by law that an electrical equipment must be certified by NRTL ( I guess we talk about UL, CSA, Intertek, etc), that will be the most important information for us. That means, if we will enter the U.S. market with a product and we do not know where it will be used (some place in the range Key West to Vancouver ....), we have to be aware if Certification and/or listing is required by law. Just for a few seconds forget the customers requirements, is it therefore a correct interpretation that electrical equipment (ITE, household appliances, radio transmitters, etc) must be certified in order to follow the U.S. laws ? Best regards Amund Oslo / Norway > -----Opprinnelig melding----- > Fra: owner-emc-p...@majordomo.ieee.org > [mailto:owner-emc-p...@majordomo.ieee.org]Pa vegne av > gr...@test4safety.com > Sendt: 15. januar 2003 21:23 > Til: 'Rich Nute' > Kopi: 'Product Safety Technical Committee' > Emne: RE: NRTL in the U.S. > > > > Hi Rich, > > > I argue with some of your statements. :-) > Thanks - at least I know that I'm alive and not dreaming!!!!! > > > Dave's question - Does this apply to in-house test equipment? > > > > Hi Dave - Good question (Please see attached). I'm sorry > about the file > > size but I took it from the Department of Labor web site several years > ago > > when this topic first came up. (It repeats about every 6 months if my > memory > > serves) > > I believe Dave's question was in regard to compliance > to local electrical codes, not to OSHA requirements. > Yes - but that is not the full story - and it would be easy to misapply a > YES-NO answer to a similar (but inappropriate) situation. > > > Local electrical codes (e.g., NEC) require all > electrical equipment that comprises an electrical > installation to be "approved for the purpose." > This is taken to mean "listed" or otherwise certified > for safety. Codes are enforced by local inspectors > and by licensed electricians who perform the > installation. > > Department of Labor (OSHA) regulations require that > the electrical equipment used by employees be > certified for safety by an NRTL. Regulations are > enforced by the employer as well as by periodically > by inspectors from OSHA. > > While these two sets of rules are independent of > each other, one solution satisfies both rules: > listing. > > As Albert Camus wrote (in The Plague) "The difference was slight > - and the > result the same." > > Perhaps someone can comment about FIRE and ELECTRIC SHOCK reports on > non-Listed versus LISTED products. > > > > However - the BEST and MOST RELEVANT people to ask are your Corporate > > Insurers. > > > > It would be little good meeting the local code to find that there is > small > > print in your corporate liability insurance leaves you with personal > > liability for any failure - injury or death!!!!!!! > > > Even if you can avoid NRTL testing then you need to protect yourself - > NOT > > YOUR COMPANY - (people go to jail - companies don't). > > As a general rule, employees cannot be held > personally liable if they are doing work in > accordance with direction from the employer. > IF THEY CAN PROVE IT!!!!! > I'm sure that no 'employer' would say "I employed him as a > professional - I > expected him to act accordingly" - "Had I known the outcome I would never > have instructed him to ...." or even "I did not - it is our policy to > comply with ALL legislation - he obviously made a mistake - let him prove > otherwise." > > But, today's focus on profits motivates many > insurers to creatively find a way to prevent > payment of claims or to recover the loss from > some other source. > Gee - I can't imagine that ever happening > > However, recovering from > the likes of you and me would not come close > to covering the loss. There are bigger fish > and deeper pockets. > OK - but suppose it did - how long would it be before legal costs > bankrupted > you? - Maybe that are others that do not share you optimism. > > What about Joint and Several actions - if I wanted to bring a successful > action I would attack the designer - BECAUSE I know that his > funds would be > exhausted quickly AND that after disposing of him/her I would > have the case > proven (will minimal cost) and then go to find the deep pockets. > > > > Try to think of 'compliance' not as PASS or FAIL; but as a continuum > from > > DEPLORABLE through ACCEPTABLE to the UNATTAINABLE. > > These abstractions, DEPLORABLE, ACCEPTABLE, and > UNATTAINABLE, are difficult to use because they > are not very measurable. PASS and FAIL at least > provide a line by which to discriminate between > acceptable and unacceptable. > Correct - the word I used to describe them was "CONTINUUM" that is not > measurable either. > > I was trying to set sights higher than "Our product PASSED" - > where PASSED > equals look-at-that it passed!!!!!!!!!!!!! - pheeeweee!!!!!!!! > > > We, at HP and Agilent, use a "three-block model" > to evaluate safety: > > +---------+ +---------+ +---------+ > |hazardous| | | | | > |energy |--->|safeguard|--->| body | > |source | | | | | > +---------+ +---------+ +---------+ > > We say that, for every hazardous energy source, > there must be one or more safeguards interposed > between the source and the body. > > The safeguard has a number of parameters that > must be controlled such that the safeguard > remains effective for the equipment lifetime. > > If we do a thorough job, then we have a safe > product -- unless the safeguard is subjected > to influences greater than the design level. > > This is a practical, powerful, and measurable > model for safety. > I agree - I use a similar model and do a forward and backward pass. The > problem with all these models and reviews is that if we cannot > prove safety. > > The best we can hope for is that our assessments fail to prove a > hazard. So > if we are good at finding hazards we are better safety engineers than > someone that cannot find any. > > Best regards > > Gregg > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ > > To cancel your subscription, send mail to: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Ron Pickard: emc-p...@hypercom.com > Dave Heald: davehe...@attbi.com > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > Jim Bacher: j.bac...@ieee.org > > All emc-pstc postings are archived and searchable on the web at: > http://ieeepstc.mindcruiser.com/ > Click on "browse" and then "emc-pstc mailing list" This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
