"So bottom line is, an NRTL Certification is NOT required, but is one method to satisfy OSHA. For any high volume produced product, certification is really the only reasonable option."
No actually in some states and cities an NRTL mark is absolutely legally required per State or City statutes.............. -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Kunde, Brian Sent: Tuesday, February 01, 2011 10:36 AM To: [email protected] Subject: RE: NRTL listing for product sold in the United States We get into this discussion about once every year or two so I'm curious whether things have changed or not? This is the way it used to be. Let me know if it is no longer true...... People make statements such as "NRTL is Required for Workplace Safety", but technically "ACCEPTABLE BY OSHA" is what is required. NRTL certification is not the only method that satisfies OSHA. According to the Federal Register 29 section 1910-399, there are three ways to be "acceptable" by OSHA; -clip- 1) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory [NRTL] recognized pursuant to ยง 1910.7; (2) With respect to an installation or equipment of a kind that no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code, and found in compliance with the provisions of the National Electrical Code as applied in this subpart; (3) With respect to custom-made equipment or related installations that are designed, fabricated for, and intended for use by a particular customer, if it is determined to be safe for its intended use by its manufacturer on the basis of test data which the employer keeps and makes available for inspection to the Assistant Secretary [OSHA] and his authorized representatives [OSHA Inspector]. --unclip-- Method #1 above lists "certified" as only one of many options. Many have interpreted #2 above to mean that you can get the product Field Tested at the customer location by a local inspector or authority. Many of our customers have their own electrical inspectors or hire a local inspector. OSHA generally accepts their report. For some very low quantity built equipment which can be considered "custom-made", OSHA may accept a detailed test report from the Manufacturer. In the (low quantity custom-made) Laboratory Equipment category, for example, NRTL certification is fairly rare. In my experience, 99% of customers in North America accept products without any markings (CE Marking only) or hire their own local electrical inspector to look it over prior to putting the equipment into service. Less than 1% requires a field inspection from an NRTL and generally it is because of their own internal requirements. A full NRTL Certification is never the only option. So bottom line is, an NRTL Certification is NOT required, but is one method to satisfy OSHA. For any high volume produced product, certification is really the only reasonable option. This is my current understanding. Is this all still true or has things once again changed? The Other Brian -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of [email protected] Sent: Monday, January 31, 2011 6:40 PM To: [email protected] Subject: RE: NRTL listing for product sold in the United States I was recently at a fire scene where the home owner had extended some outlets around a room. The wire he chose to use inside the walls did not have a NRTL approval. Apparently he bought it at a big box store that happened to be orange. Jack Burns -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of [email protected] Sent: Monday, January 31, 2011 5:22 PM To: 'Jim Robson'; [email protected] Subject: RE: NRTL listing for product sold in the United States Hi Jim: You've had a number of answers with good data. NRTL certification is required for two totally unrelated applications. 1) NRTL is required for workplace safety. 2) NRTL or equivalent is required as a part of the local (city, county, state) building code safety. Certification by a NRTL is required under the USA workplace safety law, aka OSHA. If you sell your product to an employer (who is responsible for workplace safety), the electrical equipment used by his employees must bear the mark of an NRTL. (NRTL is the means for electrical equipment safety administration under OSHA.) Certification by a NRTL or equivalent is required by the USA National Electrical Code. This code (or a version of it) is adopted by local (state or county or city) jurisdictions responsible for building codes. Most codes require certification of electrical equipment. Most codes require certification by an NRTL, but some codes have a specific list of acceptable certification houses. As far as I know, all NRTLs are accepted by all building codes; some codes may specify the cert house, and some codes may include cert houses that are not NRTL. For an example of a local jurisdiction that specifies cert houses, see: http://ladbs.org/LADBSWeb/LADBS_Forms/TestLab/ETL_list_lab.pdf (The City of Los Angeles has its own electrical testing laboratory and safety certification label.) As a general rule for the USA all electrical products must be certified by an NRTL. (Some retailers, such as Wal-Mart, also require safety certification of the products they sell, and often have their own list of acceptable cert houses. NRTL works for them, too.) Here is the current list of NRTLs: http://www.osha.gov/dts/otpca/nrtl/nrtllist.html Best regards, Richard Nute Product Safety Consultant San Diego, California, USA > -----Original Message----- > From: [email protected] [mailto:[email protected]] On Behalf > Of Jim Robson > Sent: Monday, January 31, 2011 1:41 PM > To: [email protected] > Subject: NRTL listing for product sold in the United States > > > Group, > > I am in a discussion with one of our customers about NRTL listing for > ITE products sold in the US. He sent me this comment. > > "All equipment sold in the State of Alaska as well as at > least 20 other > states is required to be listed by a nationally recognized > testing lab." > > Is anyone familiar with this requirement, know where to find the more > details and where I can find a list of the states that do > require a NRTL > listing? Google didn't help on this one. > > Regards, > Jim Robson > > > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]> LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]>
