Michael,
Be careful using the word “legal” and thinking only of the federal government. I have seen other people make this mistake. The people that normally enforce the electrical codes in the United States are the “local” governments, typically cities, townships, counties, etc. The electrical inspection authorities are referred to in the National Electrical Code, NFPA 70 as the “authority having jurisdiction”. The state governments adopt the National Electrical Code, with or without their deviations, as their own after every 3-year code cycle. Some municipalities, such as Los Angeles, have their own electrical code that is not a derivative of NFPA 70, but essentially all municipalities share the code requirement that “conductors and equipment required or permitted by this Code shall be acceptable only if approved” (NFPA 70-110.2). The code says in so many places that equipment does not have to be re-examined at the installation site if it is listed by a qualified lab. To keep this message brief, the qualified labs are the Nationally Recognized Testing Laboratories (NRTLs) determined by the Occupational Safety and Health Administration (OSHA). In most parts of the code, it says specifically that the equipment or wiring means must be “listed”. In addition, OSHA Rules Part 1900-Subpart S has requirements for equipment used in the workplace to be listed by an NRTL. That, of course, is at the federal government level. Best Regards, Don Gies, N.C.E Senior Product Compliance Engineer Alcatel-Lucent Holmdel, NJ 07733 USA _____ From: M. Loerzer-Mobile (GLOBALNORM) [mailto:[email protected]] Sent: Friday, February 16, 2007 3:26 PM To: [email protected] Subject: Re: Industrial Sub-Assembly for the US-market Mike, David, Two different answers or not?! David said: _____ Correct. Mfr of the machine is responsible for appovals. There is no customs requirement. But if the subassembly is a power supply to be incorporated into an NRTL-approved unit, a UL or TÜV recognition mark (backwards 'UR', 'bauart') facilitates approval. David _____ My "new understanding": Some OSHA regulations e. g. 29 CFR Part 1910 Subpart S (Electrical) requires "NRTL approved equipment" BUT in my view that is a OBLIGATION (legal requirement) for the EMPLOYER (safety at the workplace for the exposed worker) not for the manufacturer! Surely: a customer (employer) will only buy a machine or equipment which is safe. Therefore he will accept (buy) only a machine which is NRTL accepted but that is not a legal requirement for the manufacturer, isn´t it? Another question for "industrial products": Are "industrial equipments/sub-assemblies like electrical safe guards, power drive systems, motors, control system" covered by FCC Part 15? Mit freundlichen Grüßen Yours sincerely Dipl.-Ing. Michael Loerzer Managing Director Regulatory Affairs Specialist Fon: +49 30 3229027-50, Direct Call: -51 Fax: +49 30 3229027-59 <http://www.Globalnorm.de> www.Globalnorm.de Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin Geschaeftsfuehrer: Dipl.-Ing. Michael Loerzer Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 ----- Original Message ----- From: Mike <mailto:[email protected]> Mertinooke To: M. <mailto:[email protected]> Loerzer-Mobile (GLOBALNORM) Sent: Friday, February 16, 2007 9:21 PM Subject: Re: Industrial Sub-Assembly for the US-market Hi Michael; Your understanding is not correct. There are MANY US requirements. The complete list can only be determined >from the construction of the assembly and the environment in which it is used. Also, the state to which it is being shipped, and in some cases the states through which it will pass while being transported. Every state has its own regulations (example: California has many regulations that are completely unique). Also, every county and city has its own regulations (example: New York and Los Angeles have very extensive regulations that are unique). Next, OSHA becomes involved if the assembly is to be installed in a workplace. Finally, the industry or the customer itself may have many regulations (example: General Electric, General Motors, Ford, etc. all have very extensive regulations of their own). UL, CSAUS, ETL, and any other NRTL mark may or may not be required. It all depends on the above. Finally, your own business decision might be to use NRTL approval even when it is not required. Remember, when you sell in the USA, you *WILL* be sued by your customers. They will try to steal all your money. This is how business works in USA. Your *ONLY* defense is NRTL certification. And even that is not a very good protection. Good luck. Mike Mertinooke M. Loerzer-Mobile (GLOBALNORM) wrote: > Hi All, > > in my understanding an industrial sub-assembly which is intended for a machinery no mandatory US requirements do exist, don´t it? > > Also a "UL mark" isn´t required because the UL mark isn´t a "legal mark" (like the European CE marking). > > Is that correct? Comments are welcome. > > Mit freundlichen Grüßen > Yours sincerely > > Dipl.-Ing. Michael Loerzer > Managing Director > Regulatory Affairs Specialist > > Fon: +49 30 3229027-50, Direct Call: -51 > Fax: +49 30 3229027-59 > > www.Globalnorm.de > ------------------------------------- > Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin > Geschaeftsfuehrer: Dipl.-Ing. Michael Loerzer > Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 > > - > ---------------------------------------------------------------- > 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 ______________________________________________________________________ - ---------------------------------------------------------------- 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
