Art Michael has brought some clarification on OSHA requirements to my attention and my previous understanding was incorrect. Although the standards are not as clear as they could be, OSHA has an interpretation stating that, except for a few specified cases, products must be approved by an NRTL. Certainly any mass produced item would fall into this category.
This link shows the OSHA interpretation fairly well. http://www.osha.gov/dts/otpca/nrtl/faq_nrtl.html#15 I would like to thank Art for his guidance and I apologize if my earlier messages had led anybody in the wrong direction. This leads me to another question. I am one of those strange people who actually looks for NRTL marking on products. I have seen electrical products with no NRTL approval marking. These have all been consumer products intended for the home. Is my understanding correct that OSHA has authority only over commercial establishments and not residential installations. Is this correct? If so, is it legal to sell a consumer product without NRTL approval? Ted Eckert American Power Conversion Corporation The items contained in this e-mail reflect the personal opinions of the writer and are only provided for the assistance of the reader. The writer is not speaking in an official capacity for APC nor representing APC's official position on any matter. Arthur Michael <amichael@safetyl ink.com> To Sent by: [email protected] [email protected] cc [email protected] Subject 12/29/2006 08:28 Re: OSHA reg? AM Hello Ted, Although I'm not a lawyer, I can't agree with your initial sentence below. All one needs to do to find the 'connection' to NRTLs is to look at the definitions for either "Listed" or "Labeled" at 29 CFR 1910.399. The attestations of NRTLs are explicitly required within both of those definitions as well as in the definitions for, "Approved", "Certified", and other related terms. The terms "Accepted" & "Acceptable (i)" also require NRTL determinations. Exceptions, which I don't believe are germaine to this discussion, are noted in the definitions "Acceptable (ii)" and Acceptable (iii)" Best regards, Art Michael ======================================================================= On Fri, 29 Dec 2006, [email protected] wrote: > I can simplify the situation by stating that OSHA does not require > equipment to have NRTL approval. 1910.303 states "Electrical equipment > shall be free from recognized hazards that are likely to cause death or > serious physical harm to employees.... Suitability of equipment for an > identified purpose may be evidenced by listing or labeling for that > identified purpose." > > http://www.osha.gov/pls/oshaweb/owadisp show_document?p_table=STANDARDS&p_id=9880 > > Equipment that has no NRTL approval can be sold, but it is then up to the > AHJ to determine the safety of the electrical equipment. The AHJ may have > restrictions on how they can determine safety. However, in reality the AHJ > has a lot of power and you are at their mercy if you have an unapproved > product. > > Ted Eckert > American Power Conversion Corporation > > The items contained in this e-mail reflect the personal opinions of the > writer and are only provided for the assistance of the reader. The writer > is not speaking in an official capacity for APC nor representing APC's > official position on any matter. > > > > Arthur Michael > <amichael@safetyl > ink.com> To > Sent by: EMC-PSTC - Forum > [email protected] <[email protected]> > cc > Jim Eichner > 12/28/2006 09:55 <[email protected]> > PM Subject > Re: OSHA reg? > > > > > > > > > > > Hi Jim, > > I believe you seek the following; 29 CFR Part 1910 Subpart S, > (especially 1910.303 and 1910.399). For details see: > > http://www.osha.gov/pls/oshaweb/owadisp show_document?p_table=FEDERAL_REGISTER&p_id=15480 > > > This regulation is further supported by the very precise definitions (see > Certified, Listed, Labeled, Approved, etc) found at: > > http://www.osha.gov/pls/oshaweb/owadisp show_document?p_table=STANDARDS&p_id=9976 > > > For an easier-to-follow (but unofficial) version, see: > http://www.setonresourcecenter.com/29CFR/1910/osha_1910_subpart_s.htm > > Related Links can be found on the Safety Link <www.safetylink.com> > When there, just use your browser's FIND function (Typically, Control F) > and input the term, 29 CFR 1910 -This will take you to directly related > links. > > I hope this helps. > > Happy New Year, Art Michael > > Int'l Product Safety News > A.E. Michael, Editor > P.O. Box 1561 INT > Middletown CT 06457-8061 U.S.A. > > Phone : (860) 344-1651 > Fax : (860) 346-9066 > Email : [email protected] > Website: http://www.safetylink.com > ISSN : 1040-7529 > > ======================================= > On Thu, 28 Dec 2006, Jim Eichner wrote: > >> I am under the impression that there's an OSHA reg on the books >> somewhere that says something along the lines of "any electrical >> equipment that is to be used in the workplace must have a product safety >> approval from an NRTL". > >> Can anyone confirm or correct me, and does anyone have a reference to >> chapter and verse? I spent 20 minutes looking on OSHA's site and didn't >> feel like I was going to find it. > >> Thanks, >> Jim Eichner, P.Eng. >> Compliance Engineering Manager >> Xantrex Technology Inc. >> e-mail: [email protected] >> web: www.xantrex.com > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society > emc-pstc discussion list. Website: http://www.ieee-pses.org/ > > To post a message to the list, send your e-mail to [email protected] > > Instructions: http://listserv.ieee.org/request/user-guide.html > > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > > Scott Douglas [email protected] > Mike Cantwell [email protected] > > For policy questions, send mail to: > > Jim Bacher: [email protected] > David Heald: [email protected] > > All emc-pstc postings are archived and searchable on the web at: > > http://www.ieeecommunities.org/emc-pstc > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society > emc-pstc discussion list. Website: http://www.ieee-pses.org/ > > To post a message to the list, send your e-mail to [email protected] > > Instructions: http://listserv.ieee.org/request/user-guide.html > > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > > Scott Douglas [email protected] > Mike Cantwell [email protected] > > For policy questions, send mail to: > > Jim Bacher: [email protected] > David Heald: [email protected] > > All emc-pstc postings are archived and searchable on the web at: > > http://www.ieeecommunities.org/emc-pstc > - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc ______________________________________________________________________ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email ______________________________________________________________________
