I would also add that this looks like a text book example of a
Multiple Listing. The OEM can add their customer's product to their
Listing Report under the Multiple Listing category. The changes can be
listed there (in most cases not safety-affecting and limited to
re-branding only). In the event that there are changes that could
affect Product safety, this could also be evaluated by the NRTL in
question and documented accordingly. Based on the information below, it
is not clear what modifications to the enclosure (branding only or
mechanical/electrical in nature) are made.
Thx,
Joe
From: [email protected] [mailto:[email protected]] On Behalf Of Kunde,
Brian
Sent: Friday, July 13, 2007 8:45 AM
To: [email protected]
Subject: RE: NRTL Listing for Home Use Products
Ted gave a great summary. The only point I would add is the lawsuit
liability issue. Without an NRTL, if your product hurts or kills
someone, or burns down a building, a million dollar lawsuit can turn
into a multi-million dollar lawsuit real quick; and in some cases there
may even be jail time.
So if you modify another company's product, I highly recommend taking
Ted's advice and having it checked out by an NRTL. If the modification
truly is minor, the NRTL may consider only the modification and not have
to do a full blow evaluation which will save money and time.
The Other Brian
From: [email protected] [mailto:[email protected]] On Behalf Of
[email protected]
Sent: Friday, July 13, 2007 8:11 AM
To: [email protected]
Cc: [email protected]
Subject: Re: NRTL Listing for Home Use Products
OSHA only governs safety in the work place and has no authority over
residential installations. The requirements for consumer products come
>from the local electrical codes. The vast majority of electrical codes
are based on NFPA 70, the National Electrical Code (NEC). Strictly
speaking, the NEC does not require equipment to be Listed. However,
equipment that is not listed is subject to review by the local
inspector. The NEC states "It is the intent of this Code that
factory-installed internal wiring or the construction of equipment need
not be inspected at the time of installation of the equipment, except to
detect alterations or damage, if the equipment has been listed by a
qualified electrical testing laboratory...." Practically speaking,
local inspectors don't want to review the construction of every device,
so they insist on the use of only Listed products.
Any modifications may be considered to violate the Listing of a product.
Modifications to the enclosure would definitely violate the Listing.
These modifications may not touch the electrical circuits, but there may
still be changes affecting safety. The modified enclosure may no longer
properly serve as a fire enclosure. It may not properly restrict
accessibility to electrical, thermal or mechanical hazards. Spacings
may be unacceptably reduced. Flammable materials may be introduced.
In my opinion, the supplier needs to contract with an NRTL to get their
modified product Listed.
Ted Eckert
American Power Conversion/MGE
http://www.apc.com/
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-MGE or Schneider
Electric.
The speaker does not represent APC-MGE's or Schneider Electric's
official position on any matter.
Christine Rodham
<chrisrodham@yaho
o.com>
To
Sent by: [email protected]
[email protected]
cc
Subject
07/13/2007 06:45 NRTL Listing for Home Use
Products
AM
Hi List Members,
While I know not all products require a NRTL ( UL, MET, TUV, etc ) mark,
I understood that products used for home use ( 120V) in the USA required
a NRTL listing. Is this correct?
Isn't this an OSHA requirement? We are looking at buying a product
that
would be used in the home from a supplier. The supplier gets the product
>from an OEM, modifies the chassis / enclosure, and then sells it to us.
Their modified chassis has no regulatory marks on it but they
think.......that since the OEM listed the product that they are ok
marketing it...even though they made changes. ( No electrical changes )
We are not buying it to this but need to specifically know what is
required by law
Can anybody shed any light on this......particularly who is the legal
authority in the USA? ( OSHA...right? )
Thank you!
Christine Rodham
Food fight? Enjoy some healthy debate
in the Yahoo! Answers Food & Drink Q&A. -
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