Not all companies manufacturers high volume consumer goods. Our company designs and builds analytical test equipment (laboratory equipment) which is very expensive (relatively speaking) and built one at a time per our customer requirements. We have about 50 Families of products; each with dozens of variations. Even our best selling product family might only sell less than 50 units per year, and many models may not see a single sale in a year. Yet when someone needs one, we build it.
Some of our customers require NRTL certification. We have approached several NRTLs requesting Certification for our production units. Nope. Their 'certification programs' do not accommodate low volume production, such as ours. The ONLY option we have is NRTL Field Evaluations. NOTE: If anyone out there in cyberland knows of an NRTL or other local authority who can provide an alternate but acceptable service, please let me know!! We started paying for NRTL FES (Field Evaluation Services) more than 20 years ago. It started out maybe one per year at a cost of only a few hundred dollars (US). Now we get 12-15 requests a year and the cost has sky-rocketed to nearly $4000. We beg and plead to our NRTLs to do everything possible to keep down the costs without success. AGAIN, if anyone knows of an acceptable alternative, please let me know. Ok, let's talk about the 3 definitions the Federal Register 29 section 1910-399 gives for Acceptable by OSHA. I will paraphrase below: Number 1: Products must be tested and labeled by an NRTL. This can be done through a Certification Program with an NRTL or by a Field Evaluation. Does anyone know another way to get an NRTL sticker on your products? Please share. Number 2: For products that no NRTL accepts, certifies, lists, labels, or determines to be safe. What does this mean? In our case, if NRTLs will not Certify our products because of how we manufacturer them in low volume, does this section apply? And if so, who is the "federal agency, state, municipal, or other local authority that will test my product and stick a label on it that will be acceptable to our customers? Local to the manufacturer or local to the customer purchasing the equipment? Can anyone provide me with a name, company name, phone or email of such a person? Practically speaking, I don't think this option will work. If anyone has a real-life example of how this works, please fill me in. I would really appreciate it. Number 3: Custom-made equipment is SUPPOSED to be "ACCEPTABLE" if it is "determined to be safe for its intended use *by its manufacturer*". Is this crazy or what? Can I be so bold as to say that THIS IS LAW??? Ok, so how is this accomplished? The manufacturer has a top-notch safety compliance lab that generates a test report with "test data" showing the product to be SAFE. Then what? The manufacturer has no marking. How do I convince a Customer that this method is or should be acceptable by OSHA? NOTE: In the last 25 years, I have successfully used this approach. I sent a detailed safety test report in CB (like) format to an OSHA inspector at our customer site and it was accepted. But don't get your hopes up. BOTTOM LINE: If you do business with customers who are associated with federal or state organization, schools, universities, military subcontractors, customers in California or Washington, etc., chances are you ONLY have Option ONE above which can be accomplished by an NRTL Certification Program or by a Field Evaluation. However, as I mentioned, either choice is getting crazy expensive. Something has to be done and soon. Many test labs are struggling to keep their doors open including NRTLs. Many have closed down in the last 10 years. Final Comment: Last year we had a small supporting product that we sold to a customer who wanted an NRTL Label on it. The retail price of the device was only $2000 (US) but the NRTL charged us $4000 for the Field Evaluation. As a federal subcontractor, the customer paid for it because they had no choice. Something needs to be done. An alternative must be found. Like Europe, for low-risk devices, OSHA should allow manufacturers to test their own products and do a Manufacturer's Declaration of Compliance with some kind of recognized marking. This issue comes up about every year and I really really hope that someday North American authorities will come up with a solution. It is a crazy and very expensive mess for may manufacturers. Is there someone in the US Government we can talk to, complain to, plead to? I now return you to your regularly scheduled program. The Other Brian On Thu, Feb 20, 2020 at 10:09 PM Kevin Robinson <[email protected]> wrote: > Clause 2 under the definition for “acceptable” can only be used under > specific conditions, specifically if no NRTL has the capability to test and > certify the equipment. In such cases, the equipment/installation would be > acceptable to OSHA if a state/federal agency determined it was safe. The > reality is however that most local jurisdictions don’t want to take on the > liability of approving non certified equipment, so they will require the > owner/employer to get a field evaluation. > > OSHA has not made an OFFICIAL interpretation of the regulations to say > that a field evaluation could be used to meet the definition of > “acceptable”. > https://www.osha.gov/laws-regs/standardinterpretations/publicationdate/currentyear > > Disclaimer: My positions posted here are my own and do not represent the > official positions of my employer the US Department of Labor or OSHA. > > Kevin Robinson > > Get Outlook for iOS <https://aka.ms/o0ukef> > ------------------------------ > *From:* Richard Nute <[email protected]> > *Sent:* Thursday, February 20, 2020 8:15:36 PM > *To:* [email protected] <[email protected]> > *Subject:* Re: [PSES] Mandatory certification > > > > > Hi Regan: > > > > Yes, if that piece of equipment is not within *any* NRTL purview. > > > > Best regards, > > Rich > > > > > > *From:* Regan Arndt <[email protected]> > *Sent:* Thursday, February 20, 2020 1:22 PM > *To:* Richard Nute <[email protected]> > *Cc:* [email protected] > *Subject:* Re: [PSES] Mandatory certification > > > > Hi Rich. > > > > If you are referring to clause (2): > > > > *(2) With respect to an installation or equipment of a kind that no > nationally recognized testing laboratory accepts, certifies, lists, labels, > or determines to be safe, if it is inspected or tested by another Federal > agency, or by a State, municipal, or other local authority responsible for > enforcing occupational safety provisions of the National Electrical Code, > and found in compliance with the provisions of the National Electrical Code > as applied in this subpart; o*r > > > > Correct me if I am wrong, "BUT ONLY" if that piece of equipment *cannot > be certified by the NRTL's*, which is almost rare nowadays when you look > at the extensive scope of accreditation of the NRTL's. > > > > Regan > > > - > ---------------------------------------------------------------- > > 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) <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]> > Mike Cantwell <[email protected]> > > For policy questions, send mail to: > Jim Bacher <[email protected]> > David Heald <[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) <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]> > Mike Cantwell <[email protected]> > > For policy questions, send mail to: > Jim Bacher <[email protected]> > David Heald <[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]>
