I concur with Mr. Perkin’s assessment. The NEC has used the term “Listed” for quite a while without specifically connecting it to the NRTL program. It only had to be a “Listing” acceptable to the local AHJ, which almost always meant NRTL Listed. I believe the intent of is to clarify the intent of current practice.
In regards to Mr. Powell’s comments; the AHJ will normally sign off before many plug-connected appliances are installed. Most of the AHJ inspection will cover appliances attached to building structure which are largely covered by the NRTL program. There are installations where this will be a problem as noted below. However, I don’t expect most AHJs to know which products are covered by the NRTL program and which are not. The AHJ will likely accept an approval mark by a test lab in the NRTL program even if that test lab doesn’t have the standard for that product within the scope of their NRTL registration. The question I have is whether there has been a problem with products being released with a Listing mark from a test lab that does not have NRTL approval for the standard being certified when that standard is covered by the NRTL? In other words, have any AHJs accepted products with meaningless Listing marks for products covered under the NRTL program? Ted Eckert Microsoft Corporation The opinions expressed are my own and do not necessarily reflect those of my employer. From: Doug Powell [mailto:[email protected]] Sent: Friday, July 22, 2016 5:47 AM To: [email protected] Subject: 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: [email protected]<mailto:[email protected]> 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 [email protected]<mailto:[email protected]> -----Original Message----- From: Nyffenegger, Dave [mailto:[email protected]] Sent: Thursday, July 21, 2016 2:55 PM To: [email protected]<mailto:[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 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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To post a message to the list, send your e-mail to <[email protected]<mailto:[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)<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 <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[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]>
