Amund, Ted does a nice job of summarizing the US situation
with regard to the legality of the NRTL certification for products installed
during construction, including remodeling, which is inspected in the US.
There is also the issue for retail products here in the US as most large
retailers have contractual clauses in their POs which require a NRTL listing
on any electrical product which they will sell for you. This will cover the
coffee pot purchased to use at work as discussed.
So, you see that legally required means several things; it is required by
the US NEC which is invoked for the workplace by OSHA and for all
installations including industrial, commercial and residential construction
by AHJ inspection plus contractually thru the distribution chain.
Finally, I'll repeat my own experience when I worked for a large electronics
company. During the period in which talk TV shows exploded we received a
frantic call from our local field rep. Because this studio construction was
on a fast track they ordered all the equipment which was to be installed to
be delivered before the final AHJ electrical inspection of the building.
Upon that inspection the AHJ inspector saw the boxes on the floor he went to
inspect them for their NRTL mark. Almost none of the commercial equipment
was NRTL marked and the AHJ inspector 'red tagged' all of it - meaning that
it could not be installed until it was acceptably certified.
Our solution was to send an experienced Safety Engineer onsite and taking
the products, one type at a time, for a NRTL review, getting all of them
updated at our local repair facility per the deficiencies and then having
the NRTL lab provide a 'Field Label' on each individual updated product.
The entire exercise took a couple of weeks (& more U$ bucks than marketing
had expected to spend) but the equipment was then acceptable to be installed
in the studio. Our products did not delay the installation schedule. To
avoid that dilemma again, the VP for that equipment group reluctantly agreed
to get NRTL Listing on all of their products moving ahead, a win for the
overall safety program at the company.
Hopefully, for your equipment there will be harmonized technical safety
requirements between the US NRTL requirements and the Euro CE requirements
which can simplify your work by getting a CB Report which includes showing
compliance with all the Country deviations.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 1067
Albany, ORe 97321-0413
503/452-1201
IEEE Life Fellow
IEEE PSES 2020 Distinguished Lecturer
<mailto:[email protected]> [email protected]
Entropy ain't what it used to be
From: Ted Eckert <[email protected]>
Sent: Monday, May 25, 2020 7:57 AM
To: [email protected]
Subject: Re: [PSES] [EXTERNAL] [PSES] Electrical safety testing US and
Canada ... Mandatory ?
Hello Amund,
This is an oversimplification, but here is how I understand the laws and
regulations of the United States. I'll leave the discussion of Canadian
regulations to somebody who better knows those rules.
The Occupational Safety & Health Administration (OSHA) is a division of the
U.S. Department of Labor. OSHA has legal authority over the workplace. OSHA
runs the Nationally Recognized Testing Laboratory (NRTL
<https://www.osha.gov/dts/otpca/nrtl/> ) program, and it requires NRTL
approval for a limited set of products
<https://www.osha.gov/dts/otpca/nrtl/prodcatg.html> .
The NRTL program covers a much wider set of standard to support the broader
requirements in the NFPA 70, the National Electrical Code (NEC). Generally,
the NEC says that products must either be Listed or be approved by the local
Authority Having Jurisdiction (AHJ). In general, that means that you either
get your product listed or it's up to the local inspector to determine if
he/she will accept the unlisted equipment.
The AHJ will generally check the Listing status during construction
inspections. This typically means that products that are hard-wired or
attached to building structure will get checked, but plug-in equipment might
not be checked. It's unlikely that any AHJ will check the coffee pot that
somebody brings into the employee break room. Legally, they can, but it
probably won't happen.
The applicability of the NEC depends on whether the local jurisdiction has
adopted it or something similar. Most jurisdictions in the United States
have either adopted a version of the NEC or have some other regulation with
a similar statement on Listing. These codes will apply to all installations,
commercial and residential.
There are a number of de-facto Listing requirements. For example, insurance
companies may have clauses in their policies that require Listed products be
used.
Regards,
Ted Eckert
The opinions expressed do not necessarily reflect those of my employer,
OSHA, the Department of Labor or any local electrical inspectors.
-----Original Message-----
From: Amund Westin <[email protected]
<mailto:[email protected]> >
Sent: Monday, May 25, 2020 6:09 AM
To: [email protected] <mailto:[email protected]>
Subject: [EXTERNAL] [PSES] Electrical safety testing US and Canada ...
Mandatory ?
Sorry for bringing up this issue again, but I have lost my history for all
previous IEEE mails ...
I know (assume ...) that UL, CSA, FM and others are voluntary for showing
compliance.
But that is actually required by law in US and C?
Thanks!
Best regards
Amund
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