Dave, et al,.
This is not a new requirement for the NEC. In the past the NEC
required that all equipment be Labeled [Art 100 definition] by an
organization acceptable to the AHJ indicating compliance with appropriate
standards ... The Handbook explanation also adds a reference to Art 90.7
which is an examination of equipment for safety.
I haven't read the 2017 NEC but you claim that NRTL has been added.
If so, I'm not surprised as this is just a clarification to what has been
understood for years.
As has been discussed before, Americans are quick to promulgate
rules but reluctant to spend anything on enforcement. OSHA invokes the NRTL
cert requirement for equipment used in the workplace. Other enforcement is
mixed; much enforcement is primarily left to the legal system in that any
manufacturer that has a serious problem with a product that causes harm will
have to hang their head in shame and admit that the product doesn't even
meet the minimum safety requirements for that class of products. Under the
present conditions it seems that the manufacturer would end up paying maybe
U$ 2Million if someone dies from the product deficiency. At what level does
this become an incentive to the manufacturer to get the product NRTL
approved? If you have a number in mind I bet that the ambulance chasing
lawyers would like to use it in their claims for damage.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
[email protected]
-----Original Message-----
From: Nyffenegger, Dave [mailto:[email protected]]
Sent: Thursday, July 21, 2016 2:55 PM
To: [email protected]
Subject: [PSES] NEC 2017
The 2017 NEC will require all appliances to be NRTL listed. I wonder how
that will be enforced? Individual states adopt the NEC into law. I don't
know what the actual state statutes look like for the current NEC, I imagine
specific statutes would need to be written to deal with this new
requirement, assuming the states adopt it. Doesn't make sense to enforce
that on the consumer/owner on the manner that OSHA enforces workplace
compliance on the workplace owner. Appliances present during a AHJ
inspection could be checked but that would be a very small percentage of
appliances. The requirement would have to be put on the in-state retailers
which probably couldn't be enforced on out of state shippers the same way
that collecting sales tax from out of state shippers is challenged.
Perhaps it could be made to apply to manufacturers within the state.
Perhaps it can be enforced at the federal level for imports that have to
clear customs.
-Dave
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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
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