PSNet,
There has been a lot of good points made in this discussion.
I think that it is pretty clear that the American way is to give the
responsibility to the lowest level - national, state, local, etc. - as much
as possible.
Invocation of the US National Electrical Code (which insists upon
NRTL approval) is pushed down this way. The NEC does not differentiate
between consumer, commercial and industrial equipment. The law establishes
where it is applied.
Another American way is to pass laws for just about anything, but
don't put hardly any money into compliance - OSHA is an example of this in
that they do not have any substantial ongoing compliance effort but seem to
focus more on setting the blame after an accident.
I have heard that the UK Health and Safety at Work folks visit every
factory each year and ask what new equipment has been installed then review
the Manufacturer's Declaration of Conformity for each piece of equipment.
Perhaps someone there could comment on this.
Finally, American lawyers are willing to help anyone push back on
any requirement set down anywhere.
Why not accept your responsibility and provide equipment that meets
the intent of the requirement - NRTL listing. A novel idea, perhaps.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201 fone/fax
p.perk...@ieee.org
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