It's not only states.  Some counties and cities require listing or field
labeling when the state doesn't.

Regards,
Brian Epstein
Sr Regulatory Compliance Engineer
Veeco Instruments
[email protected]
ph (805) 967-2700 ext 2315
ce (805) 591-9587
fx (805) 967-7717


________________________________________
From: [email protected] [mailto:[email protected]] On Behalf Of Petrie, Craig D
Sent: Thursday 13 April 2006 01:18 AM
To: [email protected]
Subject: RE: UL approvals

Does anyone have this list of states which require an NRTL mark?

________________________________________
From: [email protected] [mailto:[email protected]] On Behalf Of Tyra, John
Sent: 11 April 2006 14:40
To: peter merguerian; Richards, Carl; [email protected]
Subject: RE: UL approvals
You can import the product into the U.S. but there are a number of states
which have laws requiring consumer products to have an NRTL Mark for sale in
the State so effectively you must have an NRTL Mark to sell in the
U.S.................

From: [email protected] [mailto:[email protected]] On Behalf Of peter
merguerian
Sent: Tuesday, April 11, 2006 2:25 AM
To: Richards, Carl; [email protected]
Subject: Re: UL approvals
Carl,
 
Item 1 - There are many items in hardware that the manufacturer can change
without notifying UL or another NRTL. These would be non-safety critical
components or mechanical changes. The regulatory complaince manager at your
company should be informed and sign off any ECOs relating to the product.
 
Item 2 - Yes, you can build systems. You can also ship systems without the UL
Mark. In the US, we have a voluntary certification system. Customs officials
will not stop a system at the port of entry based on Harmonized Tariff Code.
However, if this is a product to be installed in the field and at a workplace,
OSHA rules come into play. Basically, any electrical equipment used in the
worplace must be safe and NRTL Listed or field evaluated. If approached in the
field by a local inspector and depending on the city, county or state, the
local inspector might want to have a field evaluation by an NRTL done on
sight. This can cost a few thousand dollars and should take no more than 1 - 2
days depending on the size and complexity of the equipment. If NRTL found the
system suitable based on assessed standard(s), then he/she will place a field
label on the system and provide the field evaluation report to the local
inspector. This label is a one-time field label - each time a system is
installed in another jurisdiction, a separate field evaluation must be
performed.
 
Best Regards,
 
Peter
 


"Richards, Carl" <[email protected]> wrote:
Dear Group,

I am attempting to understand the limitations of shipping UL approved
hardware under the following circumstances:

1. A modification made to an approved product without notification to UL
of the change; and with the intent of not applying the UL mark when
shipping the product 

2. A manufacturer certified to perform their own UL compliance subject
to verification by UL, can the manufacturer build systems while waiting
for final approvals; and would it be possible for the manufacturer to
build and ship such a product without applying the UL mark?

I hasten to add, this is a hypothetical and educational question!

Best Regards

Carl 


Carl Richards, 
Regulatory Compliance Manager, 
Aspect Software 
2, The Square
Stockley Park, Uxbridge, UB11 1AD, 
United Kingdom


+44 (0)208 589 1461 Office
+44 (0)870 460 1950 Fax
+44 (0)7875 27 1461 Mobile
www.aspect.com

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