Hello Art,
The OSHA requirement states that Listing may be used to show compliance
with the OSHA regulations. The rules specifically use the word "may" and
not "must" or "shall".
The AHJ can always accept a product without NRTL approval. The NRTL
approval keeps the AHJ from using his own judgement and prejudices to
assess your product. However, if you are going to build a small number of
products for only a few installations, you can have the AHJ review the
product based on the NEC and any local codes. NRTL approval is not
absolutely required.
That being said, my personal opinion is that NRTL approval is very
desirable. It provides third party review of your design's safety. The
NRTL should also provide third party review of your manufacturing and
routine safety testing. It also keeps the AHJ from making personal
decisions about your product. Finally, it allows you to use one standard
for product sold throughout the country.
Although OSHA encourages NRTL approval, and OSHA reviews and certifies
NRTLs, OSHA does not absolutely require NRTL approval on products.
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
[email protected]
12/29/2006 08:28 cc
AM [email protected]
Subject
Re: OSHA reg?
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
>
> -
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