Does this apply to in-house test equipment? That is, equipment that is built in-house and remains on site? In the past I have designed in-house equipment to meet the safety standards but did not send the equipment out for testing and certification.
Dave From: Gregg Kervill [mailto:gr...@test4safety.com] Sent: Tuesday, January 14, 2003 7:50 AM To: 'Joe P Martin'; emc-p...@majordomo.ieee.org Subject: RE: NRTL in the U.S. Importance: High Joe, You are correct that NRTL LISTING is a specified requirement by some cities and states. You are incorrect in that all products used where OSHA applies are required to be NRTL LISTED. NEC Code makes that same requirement Furthermore most (I have yet to find an exception) cities and states base their code upon NEC There may be local exception but I believe that to make a 'blanket statement that ".. NRTL is not required in the US..." is I believe at best confusing and at that the worst very dangerous. The following is a statement from the US NOL: All electrical equipment, except those kinds which no NRTL accepts, certifies, lists, labels, or otherwise determines to be safe, must be "approved", as that term is defined at 29 CFR 1910.399. Except as indicated in the following this means that a NRTL must accept, certify, label, list, or otherwise determine that equipment is safe for it to be considered "approved". The requirement mandating that electrical equipment be "approved" is set forth at 29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that "approved" equipment be used in conformance with its approval. Electrical equipment which no NRTL accepts, certifies, lists, labels, or determines to be safe is acceptable to OSHA under the following if the equipment is inspected or tested by another Federal Agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the NEC and found in compliance with the provisions of the NEC as applied to Subpart S of 29 CFR 1910 standards. Custom made equipment which is designed, fabricated for, and intended for use by a particular customer does not have to be approved if it is determined to be safe for its intended use by its manufacturer. The determination must be made on the basis of test data that the employer keeps and makes available to the Assistant Secretary of Labor for OSHA. In summary then if there are ten different models of a particular kind of equipment, but only one of them is accepted, certified, listed, labeled or otherwise determined to be safe by a NRTL only that one would be considered to be "approved"; unless of course it is custom made equipment. Only those entities that have applied and been approved pursuant to the requirements of 29 CFR 1910.7 are considered to be a NRTL. Recently the "Canadian Standards Association" was the first foreign laboratory approved as an NRTL. Enclosed find a copy of a directive that discusses NRTLs. Best regards Gregg Kervill Gregg Kervill DipIM, MIMgt, MIEEE VP Engineering Test4Safety.com Inc PO Box 310, Reedville, VA 22539. USA Phone ( 804) 453-3141 Fax (804) 453-9039 http://www.test4safety.com/ From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Joe P Martin Sent: Monday, January 13, 2003 11:22 PM To: emc-p...@majordomo.ieee.org Subject: NRTL in the U.S. Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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