My recollection is that NFPA 70 does require various equipment to be listed, but I am not sure that NFPA 70 directly links to that OSHA web site. It would seem odd to me for a consensus standard like NFPA 70 to include requirements that could potentially be changed by OSHA without following a consensus standards approval process.
Mike Sherman Sherman PSC LLC > On 10/04/2022 11:48 AM James Pawson (U3C) <ja...@unit3compliance.co.uk> > wrote: > > > > 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: > 1. 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; > 2. 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; > 3. Some large retailers e.g. Walmart insist on NRTL listing for > any products carried as a liability reduction exercise, or; > 4. Some large retailers may insist on use of a particular NRTL > e.g. UL even though others are available, or; > 5. Local jurisdictions (e.g. LA, California) require NRTL for > consumer > 3. NRTL selection > 1. UL has become a generic term for NRTL certification like > “hoover” instead of “vacuum cleaner” > 2. 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 > he...@unit3compliance.co.uk mailto: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 > > > > www.unit3compliance.co.uk http://www.unit3compliance.co.uk/ | > ja...@unit3compliance.co.uk mailto: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. To post a message to the list, send your e-mail to > <emc-p...@ieee.org mailto:emc-p...@ieee.org > > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > 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: > Mike Cantwell <mcantw...@ieee.org mailto:mcantw...@ieee.org > > > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org mailto:j.bac...@ieee.org > > David Heald <dhe...@gmail.com mailto:dhe...@gmail.com > > > > --------------------------------------------- > > To unsubscribe from the EMC-PSTC list, click the following link: > https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1 > > - > ---------------------------------------------------------------- > > 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 > <emc-p...@ieee.org mailto:emc-p...@ieee.org > > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > 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: > Mike Cantwell <mcantw...@ieee.org mailto:mcantw...@ieee.org > > > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org mailto:j.bac...@ieee.org > > David Heald <dhe...@gmail.com mailto:dhe...@gmail.com > > > > --------------------------------------------- > > To unsubscribe from the EMC-PSTC list, click the following link: > https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1 > - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html 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: Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> _________________________________________________ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1