John and all, thank you for a great feedback. The follow-up question is that how about products that are sold outside consumer market and basically are sold to professional market where their use and installation are done by professionals. These types of products are not available through regular retailers. Would I be correct to say that same applies?
Thank you again Peter -----Original Message----- From: [email protected] <[email protected]> To: Ron Wellman <[email protected]>; EMC-PSTC <[email protected]> Sent: Fri, Jan 6, 2012 7:54 am Subject: RE: [PSES] Mandatory NRTL certification Hi, Kevin (from OSHA) thank you very much!! And Ron, point well taken. We are a consultancy and test lab and work with small to medium size companies that don’t have a clue and we get this question at least once a month. For Household products there are no federal laws that I am aware of relating to NRTL. However, the industry polices itself, although sometimes not too consistently (i.e.; Walmart requires NRTL, but I’ve seen Walmart brand products in their stores without NRTL). Another reason is liability. If something happens in the field and you don’t have NRTL, good luck!! For those of us who are very familiar with the NRTL program, we should all realize it is the absolute minimum. They do have factory inspections but only to confirm the product being made is what was tested. The NRTL program does not look at how a product can go out the door with a safety hazard (i.e.; Process FMEA). Most recalls of electrical products are products that have an NRTL Certification. Rightfully, our industry is moving toward Risk Management and Assessments and they are being built into our Standards (IEC60601 3rd edition and ISO14971, IEC 62368, Machinery Directive, General Product Safety Directive and RAPEX, etc.). It is in our best interest as compliance engineers to know this, learn Hazard Analysis and Risk Assessments, teach others about them, etc. This will “raise the bar” of safety in our country and around the world. If anyone is interested in learning more or staying in touch with Risk Assessments, please take a look at the IEEE’s PSES Risk Assessment Technical Committee (yes, that was a pitch for more members). See links below. IEEE PSES - http://ewh.ieee.org/soc/pses/ IEEE PSES Chicago - http://ewh.ieee.org/r4/chicago/pstc/ IEEE PSES Risk Assessment Technical Committee - http://ewh.ieee.org/soc/pses/TAC/RATC/index.html Have a nice weekend. John Allen Product Safety Consulting, Inc. 605 Country Club Drive, Suites I & J Bensenville, IL 60106 P - 630 238-0188 / F - 630 238-0269 1-877-804-3066 [email protected] http://www.productsafetyinc.com Although PSC maintains the highest level of virus protection, this e-mail and any attachments should be scanned by your virus protection software. It is the responsibility of the recipient to check that it is virus free. PSC does not accept any responsibility for data loss or systems damage arising in any way from its use. This message is confidential and intended only for the individual to whom or entity to which it is addressed. If you are not the intended recipient or addressee, or an employee or agent responsible for delivering this message to the addressee, you are hereby notified that any dissemination, distribution, or copying, in whole or part, of this message is strictly prohibited. If you believe that you have been sent this message in error, please do not read it. Please immediately reply to sender that you have received this message in error. Then permanently delete all copies of the message. Thank you. From: Ron Wellman [mailto:[email protected]] Sent: Friday, January 06, 2012 9:27 AM To: [email protected] Subject: Re: [PSES] Mandatory NRTL certification This question comes up about every two years and what it boils down to is a catch 22. Damned if you do, damned if you don’t. In my opinion, it is better to do regardless of how unbalanced these requirements are within the United States. As long as you budget for it and your management understands the risks of not having NRTL listing, it will be easier to manage. Best regards, Ron Wellman From: Tyra, John [mailto:[email protected]] Sent: Friday, January 06, 2012 6:34 AM To: 'Ron Wellman'; '[email protected]'; '[email protected]' Subject: RE: Mandatory NRTL certification While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require an NRTL mark for mains connected electronic products…and laws in 4 other States which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States……….. From: [email protected] [mailto:[email protected]] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: [email protected]; [email protected] Subject: RE: Mandatory NRTL certification NRTL certification/listing is not mandatory for product Manufacturers. This is a Customer driven requirement so your Customers can comply with local OSHA requirements. If you don’t want to list or certify your product that’s really a Marketing call. Also, it is my experience that most large Companies require third party approvals as a condition of sale. Therefore, unless you want to be reactive to Customer sales I would make sure your Marketing people understand the risk of losing a sale if your product is not certified/listed by an NRTL. Best regards, Ron Wellman From: [email protected] [mailto:[email protected]] On Behalf Of [email protected] Sent: Thursday, January 05, 2012 5:41 PM To: [email protected] 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 <[email protected]> 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 <[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://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 <[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://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 <[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://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 <[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://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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
