Hi Peter, While the NRTL program and NRTL approval is used by a variety of local AHJs, employers and retailers, the program was developed by OSHA for OSHA's purposes.
OSHA requires certain types of equipment (http://www.osha.gov/dts/otpca/nrtl/prodcatg.html) to be approved by an NRTL. Electrical equipment must be "Acceptable" to the Assistant Secretary of Labor as defined in 29 CFR 1910.399 (http://www.gpo.gov/fdsys/pkg/CFR-2011-title29-vol5/pdf/CFR-2011-title29-vol5-sec1910-399.pdf). 1910.399 provides three options to comply 1) Approval by an NRTL, 2) Approval by another regulatory body if it is of a type of equipment that no NRTL will approve or 3) Approval my the manufacturer if the product is custom made. Most equipment manufactured would not meet the requirements of options 2 or 3, so it would need to be approved by an NRTL. OSHA's authority in this area is limited to the employer, as such, the burden of complying with NRTL Approval requirements falls on US employers, not the product manufacturer. Product manufacturers have no LEGAL requirement (at least per OSHA regulations) to have their products tested or certified by an NRTL, however, due to the potentially destructive nature of the tests, the time and cost involved, as well as the amount of potentially confidental or priveleged information that must be provided to the NRTLs, most manufacturers opt to take on the burden of having the product certified by an NRTL. The NRTL Certification mark that is applied to the product can then be used by an employer to demonstrate to OSHA that they meet the applicable approval requirements. If your product could also be used in and around a home or school, or is classified as a medical device, it may also be subject to CPSC and/or FDA requirements in addition to OSHA requirements. If you have any additional questions, please feel free to contact me directly. Kevin Robinson Department of Labor – OSHA NRTL Program Engineer & Lead Auditor Office of Technical Programs & Coordination Activities 200 Constitution Ave, NW, Room N-3655 Washington DC 20210 Phone: 202 -693-1911 Fax: 202-693-1644 E-mail: robinson.ke...@dol.gov > > From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of > peterh...@aol.com > Sent: Thursday, January 05, 2012 5:41 PM > To: EMC-PSTC@LISTSERV.IEEE.ORG > Subject: Mandatory NRTL certification > > > > Hello All, > > > > Today a colleague asked me a question as to why do we need NRTL > certification such as UL or CSA on any product in the US. I thought this was > a good and logical question and the way I answered it was that to the best > of my knowledge, OSHA requires that any products that is used in work place > to be safe and to have been certified by one of the NRTL labs. Would you say > that is a correct answer? > > > > Thank you > > Peter > > - > ---------------------------------------------------------------- > > 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 > <emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > Attachments are not permitted but the IEEE PSES Online Communities site at > http://product-compliance.oc.ieee.org/ can be used for graphics (in > well-used formats), large files, etc. > > 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 <emcp...@radiusnorth.net> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org> > David Heald <dhe...@gmail.com> > > - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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 <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
