OK, now I’m going completely off topic, but here is my opinion. This is only my opinion and it does not necessarily reflect the opinion of my company or anybody else.
I completely agree with Pete that consolidation is unlikely. Congressional leaders reward members of their caucus by giving them committee positions, and those committees become minor fiefdoms that congress members defend jealously. Different organizations fall under the oversight of different congressional committees. No one committee appears willing to give up the authority or budget for their area to another committee. Consolidation can happen, but only in extreme circumstances. Even then, it doesn’t necessarily solve the problem. The Department of Homeland Security (DHS) was created after the September 11, 2001 attacks. It consolidated a number of organizations that fell under numerous oversight committees. The result ended up having multiple committees reviewing DHS and approving the budget. I welcome comments from anybody who feels that organizations centralized under DHS have improved significantly due to the new structure. (Intelligence sharing may be an example, but intelligence sharing was banned 40 years ago because of domestic spying abuses. Will it work better this time? One common example of committees protecting their areas of interest is food safety. Let’s say you want to buy lunch at Taco Bell. (I wouldn’t recommend it, but it works for this example.) You order a beef burrito and it is covered under the food safety regulations of the USDA. Your friend orders a bean burrito and their lunch is covered by the FDA. It gets even stranger if somebody orders fish. Which department covers fish depends on the species of fish. An electrical device could fall under CPSC, OSHA, MSHA, the FAA, the FDA, the DoD or any one of a number of organizations for safety depending on its intended use. As much as I hate to say it, my job exist partly due to inefficiency in the regulatory environment. O.K., I’ve vented enough for now. I’ll close my eyes, count to ten slowly and then get back to work. Ted Eckert Microsoft Corporation The opinions expressed are my own and do not necessarily reflect those of my employer. From: Pete Perkins [mailto:[email protected]] Sent: Monday, July 25, 2016 1:03 PM To: [email protected] Subject: Re: [PSES] Safety requirements in US John, et al, The WEB definition of NRTL is quite narrow. As we explained earlier, Labeling/Listing by a NRTL approved lab is an NEC concept which is administered by OSHA. The placement of this responsibility came upon OSHA not by legislation but by litigation when a test lab challenged the premise that, altho Labeling/Listing was required, there was no way for additional test labs to get on the list. The battle went all the way to the US Supreme Court and OSHA lost and, subsequently, were forced to develop the NRTL acceptance program which they run today. Apparently the 2017 NEC will now require NRTL Labeling of products which will continue to be honored by all 10k US Jurisdictions and enforced by the AHJs in each. I personally don’t see any effort to simplify or consolidate the US system any time soon. Especially in the climate of Brexit and other forces presently at work. :>) 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]> From: John Woodgate [mailto:[email protected]] Sent: Monday, July 25, 2016 11:53 AM To: [email protected]<mailto:[email protected]> Subject: Re: [PSES] Safety requirements in US From the WEB: NRTL Nationally Recognized Testing Laboratories, or NRTLs, are third party organizations recognized by the Occupational Safety and Health Administration (OSHA) under Federal code 29 CFR 1910.7 to provide product safety testing and certification services for products used in the US workplace. With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk/> J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Scott Xe [mailto:[email protected]] Sent: Monday, July 25, 2016 5:42 PM To: [email protected]<mailto:[email protected]> Subject: Re: [PSES] Safety requirements in US Hi John, What is exact meaning of NRTL approved? Is it a sample for type examination against applicable safety standard without production audits? What are the differences between A2LA and NRTL? From: "Tyra, John" <[email protected]<mailto:[email protected]>> Reply-To: "Tyra, John" <[email protected]<mailto:[email protected]>> Date: Monday, 25 July 2016 at 10:14 PM To: <[email protected]<mailto:[email protected]>> Subject: Re: [PSES] Safety requirements in US Some states have legal requirements for electrical products to be NRTL approved From: Richard Nute [mailto:[email protected]] Sent: Sunday, July 24, 2016 8:26 PM To: [email protected]<mailto:[email protected]> Subject: Re: [PSES] Safety requirements in US Hi Scott: For consumer and household products, compliance with CPSC requirements is required. No. Only products considered “substantial product hazards” such as hair dryers need comply with CPSC requirements. However, any consumer product that injures someone is subject to CPSC recall order. What about OSHA? Electrical products that are used by employees are required to be NRTL certified. Best regards, Rich - ---------------------------------------------------------------- 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]<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]<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]<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]<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]<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]>
