Hi Brian, You stated : "Do not understand the statement that components are not covered by NRTL program, as the standards list does include component standards: www.osha.gov/dts/otpca/nrtl/list_standards.html"
In short, we know, and we are attempting to clean up that list to remove standards that should no longer be on there (or ones that never should have been added to the list that somehow were added). The first of what will likely be many Federal Register notices dealing with the list of appropriate test standards: http://www.regulations.gov/#!documentDetail;D=OSHA-2013-0012-0004 . Many standards that could be considered component only standards do apply in some instances to end products (ex. motors, transformers etc.). Internally, it is a discussion that we have all the time, and we do receive comments that recommend the addition or deletion of test standards. Kevin Robinson Electrical Engineer & Senior Assessor OSHA NRTL Program robinson.ke...@dol.gov 202-693-1911 On Thu, Sep 4, 2014 at 4:16 PM, Brian Oconnell <oconne...@tamuracorp.com> wrote: > As previously stated to Mr. Robinson, the industrial compliance > engineering community very much appreciates his support of our concerns and > ideas. Good people, this is our chance to provide some relevant industry > comments. For example, for some product classes the default factory FUS > audit interval should be no more than twice per year where the site has not > received any variation notices, and there are no new product classes added > to production. NRTLs should not be allowed to use the factory audit system > as a profit center. Many other ideas, so let us write (link in below > message). > > Do not understand the statement that components are not covered by NRTL > program, as the standards list does include component standards: > www.osha.gov/dts/otpca/nrtl/list_standards.html > Perhaps there are differences in implementation. Note that a few AHJs will > actually look up a component's 'recognition' to see if the scoped standard > was on the NRTL list. > > Brian > > > From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] > Sent: Thursday, September 04, 2014 12:15 PM > To: EMC-PSTC@LISTSERV.IEEE.ORG > Subject: Re: [PSES] Battery certification issue > > I do want to chime in here on a few issues to stop any misconceptions > about the NRTL program. First a disclaimer, in my former life, I worked > for an NRTL, I now work for OSHA in the office that oversees the NRTL > program. > > The NRTL Program applies ONLY to end products used in the workplace. It > does not apply to component power supplies, plastic materials used to make > enclosures, transformers, switches etc. that are used to make up end > products. OSHA has no authority to regulate components (as they typically > can't be used in the workplace alone), and as a result, components are not > covered under the NRTL Program. It is true that many organizations > recognized by OSHA as NRTLs do issue certifications on components, however, > they are doing so outside of their NRTL scope of recognition, and OSHA does > not oversee the activities that an organization we recognize does with > respect to components. A common complaint that I hear is the policies of > some NRTLs as to the acceptance of component recognitions. As the NRTL > program does not cover components, and OSHA has no authority to require one > NRTL to accept component recognition from another NRTL (that authority lies > with other Federal agencies ! > if the policies are determined to be anti-competitive). > > With that said, OSHA and the NRTL Program do recognize the importance that > component recognitions play in product safety certifications, and we do > allow NRTLs to accept component certifications from another NRTL provided > they can demonstrate that they have reviewed the component certification > documents to ensure that the component is being properly used, and that the > organization that granted the certification had the specific standard in > their NRTL scope. > > As for mutual recognition of one NRTL's certification for an end product, > again, OSHA does not have the authority to require one NRTL to accept > certifications from another NRTL. We do allow this, and we have > established some guidelines if an NRTL does accept certifications from > another NRTL, but we can not require an NRTL to do this. Fortunately, it > is very rare when an end product certified by NRTL #1 is then submitted to > NRTL #2. > > > John Tyra was sharing his experiences when working a an NRTL 20 years ago. > I can say that times have changed. 20 years ago, the NRTL program was > only 5 years old, and the assessors were borrowed from other federal > agencies. The only guidance that OSHA or NRTLs had was what was written in > the regulations (29 CFR 1910.7) which provides a very high level approach > to the program. The NRTL Program within OSHA is a very small group (we > currently have a staff of 4 people), 50% of whom are ex-NRTL employees, so > we now have the expertise to dig deeper into the capabilities. In the late > 1990's, OSHA did publish additional guidance for the NRTLs, although, there > has been only minor updates since that time. I am very happy to say that > we will soon (hopefully this week) be releasing portions of an updated > draft directive (OSHA Policies and procedures) for the NRTL program that > align our requirements with ISO 17025 & 17065. On October 22, we will be > holding a stakeholder mee! > ting to discuss which direction to take the program in the future, and > whether those changes will require rule making which can be a lengthy > process. Some of the topics presented in this thread will be discussed at > this meeting. While registration for the meeting has officially closed, we > so still have space available for those who are interested in attending as > an observer. Details on the meeting are available here: > http://www.regulations.gov/#!docketDetail;D=OSHA-2013-0028. If you are > interested in attending this meeting, please send an e-mail to > nrtlprog...@dol.gov . Future updates to the program, including the draft > directive will be posted here: https://www.osha.gov/nrtlpi/index.html > > If you have any questions, feel free to contact me. > > Kevin Robinson > Electrical Engineer & Senior Assessor > OSHA NRTL Program > robinson.ke...@dol.gov > 202-693-1911 > > > On Thu, Sep 4, 2014 at 1:15 PM, jral...@productsafetyinc.com < > jral...@productsafetyinc.com> wrote: > Hi Rich, > > Yes, I would agree. Not sure how or if we'll ever get there, but if an > NRTL is covered by OSHA for a Standard, all NRTLs should accept their mark > and not have to repeat any testing. How do we get there if the Standard > itself leaves too much room for interpretation?? If all the Standards were > Hazard Based (I know you'll love this), do we have a chance of getting to > harmonized interpretations?? > > -----Original Message----- > From: Richard Nute [mailto:ri...@ieee.org] > Sent: Thursday, September 04, 2014 12:10 PM > To: jral...@productsafetyinc.com; EMC-PSTC@LISTSERV.IEEE.ORG > Subject: Re: [PSES] Battery certification issue > > > Hi John: > > > On 9/4/2014 8:52 AM, jral...@productsafetyinc.com wrote: > > Is it that NRTLs don't trust each other's data? Or is the pink elephant > in the room revenue and market share?? > The issue is revenue (profits). > > If the NRTL performs ALL of the tests, the revenue is higher and the > profits higher. > > They use the argument that the NRTL must KNOW that the equipment is safe > through their own measurements. They cannot be held responsible for tests > that are done by another NRTL. > > On the other hand, some NRTLs do accept tests and data from other NRTLs. > And, some NRTLs have MRAs (to reduce time and costs for a client). > > > Best regards, > Rich > > - > ---------------------------------------------------------------- > 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://www.ieee-pses.org/list.html (including how to > unsubscribe) > 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://www.ieee-pses.org/list.html (including how to > unsubscribe) > 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://www.ieee-pses.org/list.html (including how to > unsubscribe) > 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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>
