Thanks William for the information. I would like to add from the 918-306-0010 Overview that NTRL is only one of three methods that can be used. Note that (c) is a Field Evaluation which is generally performed to the requirements of the state or local electrical code. I'm assuming Peter's question is more geared toward low volume non-commercial products. It is not practical for many manufacturers of such products to obtain NRTL Certification but will support a Field Evaluation performed at the customer site if they desire or are required. All of the local codes I have had the opportunity to look at (so far) accepts a field evaluation in addition to the NRTL Certification. Many companies hire local inspectors to perform such evaluations.
The Other Brian ------ 918-306-0010 Overview (1) ORS 479.610 establishes certification requirements for electrical products. (2) The certification process generally involves inspection, testing and evaluation of the product. This is done through: (a) Listing and application of listing label by a Nationally Recognized Testing Laboratory (NRTL); (b) Special Deputy Evaluation and Certification. A product can be submitted to the division for certification under ORS 479.760. The special deputy procedures, rules and limitations are located in OAR 918-306-0510 to 918-306-0530; or (c) Field Evaluation of Products. Field evaluation involves inspection, testing, evaluation and application of an evaluation label utilizing Recommended Practice and Procedures for Unlabeled Electrical Equipment Evaluation dated June 2003 and published by the American Council of Independent Laboratories (ACIL). From: [email protected] [mailto:[email protected]] On Behalf Of Morse, William Sent: Friday, January 06, 2012 12:23 PM To: Tyra, John; [email protected] Subject: Re: [PSES] Mandatory NRTL certification "interesting" aspects of this topic 1) Authorities Having Jurisdiction (AHJ) that has adopted the National Electrical Code (NEC) also place a requirement for an NRTL mark on a device. So while there maybe no state requirements there are AHJs (City, County,...) requirements for devices to have an NTRL mark. Los Angeles http://www.ladbs.org/ FUNCTION OF THE LOS ANGELES ELECTRICAL TESTING LABORATORY The California Electrical Code requires under Sections 110.2 and 110.3 that electrical equipment be safety approved by the authority having jurisdiction or listed by an approved testing laboratory. In addition, the City of Los Angeles Municipal Code Section 93.0402 also requires approval for these equipment, if a listing cannot be secured, either by the Los Angeles Electrical Testing Laboratory (LAETL) or third party testing agencies recognized by the City. 2) Do not assume that Federal Regulations preempt state or local requirements for NRTL listing. For example medical devices. 21 CFR §808.1 (d)(1) SUBCHAPTER H--MEDICAL DEVICES PART 808 -- EXEMPTIONS FROM FEDERAL PREEMPTION OF STATE AND LOCAL MEDICAL DEVICEREQUIREMENTS Subpart A--General Provisions (1) Section 521(a) does not preempt State or local requirements of general applicability where the purpose of the requirement relates either to other products in addition to devices (e.g., requirementssuch as general electrical codes, and the Uniform Commercial Code (warranty of fitness)), or to unfair trade practices in which the requirements are not limited to devices. 3) State laws are unique in scope: http://www.bcd.oregon.gov/rules_statutes/compilations/oar/306.pdf http://egov.sos.state.or.us/division/archives/rules/OARS_900/OAR_918/918_306.html 918-306-0000 Scope and Authority for Rule (1) The rules in OAR 918-306-0000 to 918-306- 0530 deal with the different ways to qualify an electrical product for sale, disposal and installation in Oregon. (2) Authority for rules. (a) ORS 479.540 authorizes partial and complete product exemptions; (b) ORS 479.610 requires products for sale in Oregon to be certified; and (c) ORS 479.730 authorizes creation of procedures for product certifications, administration and enforcement and field evaluation of electrical products. 918-306-0010 Overview (1) ORS 479.610 establishes certification requirements for electrical products. (2) The certification process generally involves inspection, testing and evaluation of the product. This is done through: (a) Listing and application of listing label by a Nationally Recognized Testing Laboratory (NRTL); Oregon Law 479.610 479.610 Sale or disposal of uncertified or unevaluated electrical product prohibited. Except as provided under ORS 479.540<http://www.paperadvantage.org/ORS/479.html#479.540#479.540>, no person shall sell or dispose of by gift or otherwise in connection with the person's business an electrical product that is not certified or evaluated under the requirements of ORS 479.510<http://www.paperadvantage.org/ORS/479.html#479.510#479.510> to 479.945<http://www.paperadvantage.org/ORS/479.html#479.945#479.945> and 479.995<http://www.paperadvantage.org/ORS/479.html#479.995#479.995>. [1959 c.406 §9; 1981 c.815 §12; 1995 c.706 §2] Bill Opinions expressed are my own and not necessarily those of my employer, use at your own risk From: "Tyra, John" <[email protected]<mailto:[email protected]>> Reply-To: "Tyra, John" <[email protected]<mailto:[email protected]>> Date: Fri, 6 Jan 2012 09:34:16 -0500 To: <[email protected]<mailto:[email protected]>> Subject: Re: [PSES] 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 anNRTL mark for mains connected electronic products...and laws in 4 otherStates 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]> [mailto:[email protected]] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: [email protected]<mailto:[email protected]>; [email protected]<mailto:[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]> [mailto:[email protected]] On Behalf Of [email protected]<mailto:[email protected]> Sent: Thursday, January 05, 2012 5:41 PM To: [email protected]<mailto:[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. 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To post a message to the list, send your e-mail to <[email protected]<mailto:[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]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[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]<mailto:[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]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[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]<mailto:[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]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[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://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]>
