Re: [PSES] NEC 2017

[Doug Powell]

Title: RE: [PSES] NEC 2017

I need to read the 2017 edition as well.  Requiring NRTL simply seems wrong, if only because not all appliance standards are available under the NRTL program https://www.osha.gov/dts/otpca/nrtl/list_standards.html.  I am presently working on certifying a UL 1973 product and will have to settle for the agency monogram but no NRTL. I am certain there are many more product types like this.   In addition, the first 1/4th of that listing of standards are not UL standards at all. It would seem that if OSHA is able to understand this nuance, then NFPA and AHJs should be able to understand this as well.   All the best, Doug Douglas E Powell ‎https://www.linkedin.com/in/dougp01   ‎ From: Pete Perkins Sent: Thursday, July 21, 2016 11:46 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Pete Perkins Subject: Re: [PSES] NEC 2017 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 p.perk...@ieee.org -----Original Message----- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Thursday, July 21, 2016 2:55 PM To: EMC-PSTC@LISTSERV.IEEE.ORG 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 - ---------------------------------------------------------------- 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> - ---------------------------------------------------------------- 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> - ---------------------------------------------------------------- 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>