Hello everyone,
Thank you for all the replies. Some of them confirmed my existing understanding but there were more that revealed more questions. Summary of previous points (please call these out for lack of accuracy) 1. Safety testing not explicitly based on any kind of voltage threshold (like EU Low Voltage Directive) or on the presence of a Radio in the equipment (like EU Radio Equipment Directive) 2. NRTL approval and marking can be mandated by a number of sources: a. If the equipment is used in a workplace where the employer has more than 50 staff then the employer has to comply with OSHA requirements for all equipment used on site, or; b. If the product falls under the one of these safety approval standards <https://www.osha.gov/nationally-recognized-testing-laboratory-program/list-standards> then it requires listing? or; c. Some large retailers e.g. Walmart insist on NRTL listing for any products carried as a liability reduction exercise, or; d. Some large retailers may insist on use of a particular NRTL e.g. UL even though others are available, or; e. Local jurisdictions (e.g. LA, California) require NRTL for consumer 3. NRTL selection a. UL has become a generic term for NRTL certification like “hoover” instead of “vacuum cleaner” b. Check list of NRTLs <https://www.osha.gov/nationally-recognized-testing-laboratory-program/current-list-of-nrtls> and verify that they are recognised for the specific standard Questions Is my understanding of Point 2.b above correct? Bernd mentioned that this requirement comes from NFPA 70? Specific application The product in question is a motion sensor used in building control systems. It is powered off a maximum of 36VDC and has a power consumption of less than 1W. Following the EU standards trail, EN 60730-1 would be the most relevant Harmonised Standard. I can see the equivalent UL 60730-1 in the list of safety approval standards. Does that mean NRTL approval is required as per point 2.b above? Or is NRTL use still a matter of choice if it doesn’t fall under point 2? I’m just trying to give the best advice to my customer. I appreciate Scott’s well word comments of “better to go through the process and reduce liability” so I appreciate the risk/liability dimension to this question. All the best James James Pawson Managing Director & EMC Problem Solver Office hours: My mornings are reserved for full attention on consultancy, testing, and troubleshooting activities for our customers’ projects. I am otherwise contactable between 1300h to 1730h from Monday to Friday. For inquiries, bookings, and testing updates please send us an email on <mailto:he...@unit3compliance.co.uk> he...@unit3compliance.co.uk or call 01274 911747. Our lead times for testing and consultancy are typically 4-5 weeks. Unit 3 Compliance Ltd EMC : Environmental & Vibration : Electrical Safety : CE & UKCA : Consultancy <http://www.unit3compliance.co.uk/> www.unit3compliance.co.uk | <mailto:ja...@unit3compliance.co.uk> ja...@unit3compliance.co.uk +44(0)1274 911747 | +44(0)7811 139957 2 Wellington Business Park, New Lane, Bradford, BD4 8AL Registered in England and Wales # 10574298 From: James Pawson (U3C) <ja...@unit3compliance.co.uk> Sent: 27 September 2022 08:20 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] To NRTL or not NRTL, that is the question Hello experts, I'm trying to understand what electrical products require NRTL approval for electrical safety for sale in the United States. Looking on the OSHA website I find this page (https://www.osha.gov/nationally-recognized-testing-laboratory-program/products-requiring-approval) which links to this page ( https://www.osha.gov/nationally-recognized-testing-laboratory-program/1910-references#1910_303-307) Taking this at face value, particularly 303(g)(2)(i), does this mean that equipment operating at less than 50V (I'm assuming DC and AC RMS) does not require NRTL approval? The question comes from a customer who was emailed by one of his US customers stating that he should have "UL listing". I understand that NRTL approval and the Listing process are different with the latter being more involved? Would appreciate any comments on this. Thanks as always. All the best James - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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