Michael:
You are right. The compliance with the safety law in the workplace is the
employer responsibility.
However, the manufacturer (importer) will obtain approvals to be able to sell
equipment and to have additional liability protection.
In USA the following safety and emission requirements applies to industrial
equipment intended for use in a workplace:
1.
See 29 CFR, Part 1910, Subpart S - Safety.
Electrical and electronic eqipment is aceptable for use in a workplace if
it is accepted, or certified, or listed or otherwise determined to be safe by
Nationally Recognized Testing Laboratory (NRTL).
2. See 47 CFR Part 18 (FCC Part 18) for Emission
FCC Part 15 does not apply to industrial equipment.
Samuel Lifshutz
Manager QA
MRV Communications Inc.
20520 Nordhoff Street
Chatsworth, CA 91311, USA
( (818) 772-6235 x265
7 (818) 772-0576
* [email protected]
Registered by QMI to ISO 9001:2000
_____
From: [email protected] [mailto:[email protected]] On Behalf Of M.
Loerzer-Mobile (GLOBALNORM)
Sent: Friday, February 16, 2007 12:26 PM
To: Mike Mertinooke; [email protected]; EMC-PSTC
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. Loerzer-Mobile (GLOBALNORM) <mailto:[email protected]>
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
>
> -
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