Hi John, My name is Kevin Robinson, and I am the Director of the office that administers the NRTL Program for OSHA. While this response is not an "official" response from OSHA (as I am sending it from my personal account), I would say the same thing if you were to contact me at work ( robinson.ke...@dol.gov).
Before I answer your question, I would like to help set the stage a bit. The NRTL Program was created by OSHA and for OSHA. OSHA NRTL Approval requirements while adopted by many state and local AHJs do not officially travel down to that level. Whether an AHJ would accept a certification is really up to that AHJ. Additionally, only certain types of equipment ( http://www.osha.gov/dts/otpca/nrtl/prodcatg.html) are required by OSHA regulations to be "acceptable" (certified by an NRTL). You will notice that engine driven arc welders do not appear on the list of products requiring NRTL approval, therefore, NRTL approval is not required to satisfy OSHA (but your local AHJ may require some independent certification). With that said, any organization recognized by OSHA as an NRTL can evaluate, test and certify equipment that is not on their NRTL scope and issue a certification, however, if the standard is not in their NRTL scope of recognition (http://www.osha.gov/dts/otpca/nrtl/nrtllist.html) then they may not represent themselves as an NRTL (either in the quotation, contracts, but most importantly, on the certification mark that they authorize you to apply to your product. If an organization recognized by OSHA as an NRTL were to test and certify a product outside their NRTL scope that would be fine. An AHJ may accept that certification, but the certification would NOT be acceptable to OSHA (assuming NRTL certification was even required). If you have any additional questions, feel free to contact me directly. Kevin Robinson 202-693-1911 robinson.ke...@dol.gov On Thu, Oct 8, 2015 at 2:54 PM, John Allen <jral...@productsafetyinc.com> wrote: > Hi guys, > > > Question on the subject - > > UL60974-1 (Engine Driven Arc Welders) is not on the OSHA list of > "Appropriate Test Standards". UL551 (Transformer Arc Welders) is on the > list. No NRTLs have UL60974-1 coverage by OSHA. Can we still use > UL60974-1 for USA Certification? > > Our issue is that UL551 does not cover our product - an Engine Driven Arc > Welder. > > Stated another way, if a Standard is not on the "Appropriate Test > Standard" list, and no NRTLs have OSHA coverage for it, can we still > Certify to it and have it be accepted by OSHA or any AHJ? > > Thanks, > > John > - > ---------------------------------------------------------------- > > 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) <http://www.ieee-pses.org/list.html> > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <sdoug...@ieee.org> > 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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
