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
> 
> 
> 
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