Brian, I am responding from my personal account which is where I monitor the EMC-PSTC, so this can not serve as an "Official Response" from OSHA, but if you would like something, more official, I have included my work e-mail below. For the purpose of this discussion, I will keep my comments generic and not tied to a specific NRTL. If you wish to discuss the markings of a specific NRTL, please contact me at one of the e-mail addresses below with the appropriate details.
The use of what I will call "supplemental" information around an NRTL's certification mark became an administrative headache for OSHA late last year, and it was determined that OSHA would simply include on its website a sample of the "Core" certification mark on its website https://www.osha.gov/dts/otpca/nrtl/nrtlmrk.html . We then asked NRTLs to create a web page that described the different variations of its mark and what each one means. For example, several NRTLs use a "US" designation and/or an "NRTL" designation or other additional text in conjunction with their mark. These clarification web pages can be found by clicking on the NRTL name that you are interested in at: https://www.osha.gov/dts/otpca/nrtl/. If you have any questions about this, or any NRTL related matter, please contact me directly at: [email protected] or send an e-mail to the general NRTL Program mail box at: [email protected] Kevin Robinson (Unofficially in this e-mail) Acting Director OSHA NRTL Program 202-693-1911 On Mon, Sep 29, 2014 at 3:19 PM, Brian Oconnell <[email protected]> wrote: > Good People, > > Per OSHA and 29CFR1910, the images for the various marks shall be > registered. For the third time, yet another NRTL has mandated a mark change > where there is no record of the image in the OSHA database for registered > NRTL marks. Previously, an NRTL has issued a change notice so an ECO was > issued to update marking labels. After questioning the NRTL about the > 'official' mark, they said "never mind, just use the old marks", so we had > to eat several rolls of useless labels. > > Am at these same cross-roads - agency demanding that I change NRTL mark > image on labels where there is no official image in the OSHA database. > > Sent a message to OSHA requesting clarification, but no answer. Any ideas > on what OSHA officials would be appropriate for escalation of this issue? > > Thanks, > Brian > > - > ---------------------------------------------------------------- > 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://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 <[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://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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
