Scott,
As a newcomer, you are quite perceptive at asking food
questions.
There has been some discussion of how the responsibilities are
divided between jurisdictions in the US but there is one common thread in all
of this. The US NEC (National Electric Code) has always provided guidance in
this. The wording and explanation have changed with time but the intent seems
the same.
The NEC applies to Utilization Equipment: Equipment that
utilizes electrical energy for electronic, electromechanical, chemical.,
heating, lighting or similar purposes.
And Approved: Acceptable to the AHJ (Authority Having
Jurisdiction).
And Labeled: Equipment or materials to which has been attached a
label, symbol, or other identifying mark of an organization that is acceptable
to the AHJ and concerned with product evaluation, that maintains periodic
inspection of production of labeled equipment or materials, aby by whose
labeling the manufacturer indicated compliance with appropriate standards or
performance in a specified manner.
Organization acceptable to the AHJ has come to mean NRTL
certifying laboratory. The NRTL lab certification program is organized by OSHA
but applies more broadly than the OSHA requirements themselves.
There are more than a handful off NRTL approved labs (all
qualified for specific types of equipment); you can see the list on the OSHA
website along with the details as to their product class certifications. In
the US, UL is the 800 lb gorilla in this business but there is vigorous
competition. All of these NRTL labs, I believe, work with manufacturers on a
worldwide basis; their certification label shown proof of compliance with the
NEC.
The US safety requirements for products are from ANSI standards.
For the products that I most commonly work with UL is important in developing
the standards and closely works with the US committees as well as the
corresponding IEC committee, too, as the US is working to harmonize technical
safety requirements on a worldwide basis for many product groups (e.g. ITE
62368, Test/Measurement/Process Control 61010, etc.).
So, I think that your basic understanding is correct. The
products have to be certified to a US standard by a NRTL cert lab which does an
examination/testing of a sample product and, upon successful completion of the
evaluation, issues a certification (Listing in many cases) then does ongoing
factory inspections on a regular basis to ensure that the labeled product
continues to be manufactured in the same way as the product evaluated.
I hope that this long-winded explanation is helpful to you.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
<mailto:[email protected]> [email protected]
From: Scott Xe [mailto:[email protected]]
Sent: Monday, July 25, 2016 9:52 AM
To: Pete Perkins <[email protected]>; 'Scott Xe' <[email protected]>;
[email protected]
Subject: Re: [PSES] Safety requirements in US
Hi Peter,
Yes, I have got that feeling. It is difficult to ask a manufacturer designing
a product meeting US requirements. It sounds no certain places to provide such
information.
What is the exact meaning of NRTL certification? Is NRTL accredited laboratory
in the US? What can they certify a sample or production? Understand UL listed
certifies both sample and production.
Sorry for my silly questions as you know I am just a new comer in this area.
From: Pete Perkins <[email protected] <mailto:[email protected]> >
Date: Monday, 25 July 2016 at 11:55 PM
To: Raymond Li <[email protected] <mailto:[email protected]> >,
<[email protected] <mailto:[email protected]> >
Subject: RE: [PSES] Safety requirements in US
Scott,
There has been quite a bit of discussion here on US
requirements. As you can tell there is no ‘overall’ single US requirement that
covers everything. The final say is locally for most instances; the local AHJ
inspectors have local control. Local inspectors have access to all
construction – both new construction and substantial remodeling – and must
approve the final construction, including the electrical installation. They
can refuse to accept any unit for attachment to the grid power based upon their
local laws, rules and understanding, s we have commented previously. There are
more than 10k jurisdictions in the USA. This is confusing to outsiders who are
looking for a simple solution such as the EU has developed.
Since you have asked; the best response of manufacturers is to
provide NRTL certification for their product when it is sold in the USA.
This is additional effort and, possibly, additional cost since
there is a finite list of NRTL labs. Since most NRTLs will also issue a CB
Report where the requirements are harmonized, I have advised manufacturers to
obtain both evaluations and reports at the same time for a savings in effort
and cost.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
<mailto:[email protected]> [email protected]
From: Scott Xe [mailto:[email protected]]
Sent: Saturday, July 23, 2016 10:31 PM
To: [email protected] <mailto:[email protected]>
Subject: Re: [PSES] Safety requirements in US
Thanks for all your responses!
What is the best practice for the suppliers/importers to demonstrate the
compliance with relevant requirements?
Scott
From: Ron Wellman <[email protected] <mailto:[email protected]> >
Reply-To: Ron Wellman <[email protected] <mailto:[email protected]> >
Date: Sunday, 24 July 2016 at 12:14 AM
To: <[email protected] <mailto:[email protected]> >
Subject: Re: [PSES] Safety requirements in US
United States laws are codified in the United States Code (USC). The Code of
Federal Regulations (CFR) is the implementation of the laws in the USC.
Ron
From: Doug Powell [mailto:[email protected]]
Sent: Saturday, July 23, 2016 7:38 AM
To: [email protected] <mailto:[email protected]>
Subject: Re: [PSES] Safety requirements in US
Actually, I think FDA, FCC, FTA, USDA, CDC, Homeland Security, etc. all report
up to the CFR.
Doug
From: Nyffenegger, Dave
Sent: Saturday, July 23, 2016 8:32 AM
To: Doug Powell; [email protected] <mailto:[email protected]>
Subject: RE: [PSES] Safety requirements in US
Anything with a laser in it is also governed by FDA regs. I think the
objective is to make it so confusing that no-one can figure it out completely
and the lawyers will always have something to do.
-Dave
From: Doug Powell [mailto:[email protected]]
Sent: Saturday, July 23, 2016 10:08 AM
To: [email protected] <mailto:[email protected]>
Subject: Re: [PSES] Safety requirements in US
Ultimately, everything goes up to the Code of Federal Regulations, CFR. These
are the law of the land. You can find the regulations that both OSHA and CPSC
follow there. In turn, each state has their own set of laws, for example in my
home state are the Colorado Revised Statutes, CRS.
Usually all these can be found online at no charge.
All the best, Doug
From: Kevin Robinson
Sent: Saturday, July 23, 2016 2:47 AM
To: [email protected] <mailto:[email protected]>
Reply To: Kevin Robinson
Subject: Re: [PSES] Safety requirements in US
Scott,
In the US, the regulations rounds on the type of product and where it will be
used. For example:
If the product will be used in the workplace then Osha NRTL regs apply.
If the product will be used in the home or around schools, then CPSC regs
apply.
If the product is a medical device then FDA regs apply
Most products fall under multiple regulators as for example, a hospital is both
a medical space as well as a workplace. Thankfully, most us regulations
reference voluntary consensus standards so one round of testing will often
satisfy all safety regulators.
Kevin Robinson
Get Outlook for iOS <https://aka.ms/o0ukef>
_____________________________
From: Scott Xe <[email protected] <mailto:[email protected]> >
Sent: Saturday, July 23, 2016 1:30 AM
Subject: [PSES] Safety requirements in US
To: <[email protected] <mailto:[email protected]> >
Within EU, most of electrical products are covered by LVD and GPSD. In US,
which body, law and standards are responsible for the similar regulatory?
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