As this is my personal email address, this answer is not an official answer. If you would like the official answer from the Department of Labor/OSHA reach out to my work email: [email protected]
Unofficial answer ;-): OSHA requires all electrical equipment used in the workplace to be tested and certified by a Nationally Recognized Testing Laboratory or these determined to be “acceptable” as defined in 29 CFR 1910.399 which reads: Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this subpart S: (1) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory recognized pursuant to § 1910.7; or (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; or (3) With respect to custom-made equipment or related installations that are designed, fabricated for, and intended for use by a particular customer, if it is determined to be safe for its intended use by its manufacturer on the basis of test data which the employer keeps and makes available for inspection to the Assistant Secretary and his authorized representatives. Also in 1910.399 http://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.399is the definition for “Utilization equipment” which describes the scope of Subpart S https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-S?toc=1 of the Occupational Safety and Health Act which covers electrical equipment Specifically 1910.301 (a)(1) reads:” Covered. The provisions of §§ 1910.302<https://www.ecfr.gov/current/title-29/section-1910.302> through 1910.308<https://www.ecfr.gov/current/title-29/section-1910.308> cover electrical installations and utilization equipment installed or used within or on buildings, structures, and other premises, including:” Utilization equipment is defined as “Utilization equipment. Equipment that utilizes electric energy for electronic, electromechanical, chemical, heating, lighting, or similar purposes.”. (So pretty much anything you can think of that is electrical) The types of equipment requiring NRTL approval is summarized here http://www.osha.gov/nationally-recognized-testing-laboratory-program/products-requiring-approval. The first line is electrical equipment The remaining 36 categories are references to other OSHA standards that require NRTL approval. OSHA requires employers to ensure equipment they use is NRTL certified (or acceptable). If an employer doesn’t follow those requirements they could be cited for violating OSHA standards. Kevin Robinson (my own opinion and not representing the views of the government or my employer) Get Outlook for iOS<https://aka.ms/o0ukef> ________________________________ From: Savino Macias <[email protected]> Sent: Wednesday, January 7, 2026 1:41:25 PM To: [email protected] <[email protected]> Subject: Re: [PSES] Mandatory NRTL certification Are you saying it’s mandatory for every electrical product to be certified by an NRTL in the workplace? I was under the impression that only those listed here: OSHA's Nationally Recognized Testing Laboratory (NRTL) Program - Products Requiring Approval | Occupational Safety and Health Administration<https://www.osha.gov/nationally-recognized-testing-laboratory-program/products-requiring-approval> [Canon U.S.A., Inc.] Savino Macias Electrical Engineer Product Engineering Division Canon Virginia, Inc. 12000 Canon Boulevard Newport News, VA 23606 www.cvi.canon.com<http://www.cvi.canon.com/> [email protected]<mailto:[email protected]> T 757-969-6308 From: Jim Bacher, WB8VSU <[email protected]> Sent: Wednesday, January 7, 2026 12:42 PM To: [email protected] Subject: Re: [PSES] Mandatory NRTL certification This message originated outside the Canon Network It's mandatory, but not enforced by OSHA unless an issue arises. There are a few cities that do enforce it. Los Angeles being one of them. If their inspectors find such a product they will require it's removal and that includes trade show demos. One company I dealt with many years ago was paying for site inspections of their products when installing their products, instead of certifying their products. Once you have a CB Report, getting a NRTL cert isn't too difficult or expensive. Jim Bacher, WB8VSU [email protected]<mailto:[email protected]> JBRC Consulting LLC Product EMC & Regulatory Consultant https://www.trc.guru/<https://trc.guru/> email:[email protected] IEEE Life Senior Member On January 7, 2026 12:22:26 PM "[email protected]<mailto:[email protected]>" <[email protected]<mailto:[email protected]>> wrote: John and James, Thank you so much for your valuable feedback. I see a lot of products that are used in the professional market that do not have any type of 3rd party certification and they are being sold on the market and they are from some big manufacturers. So would you agree that 3rd party certification is not mandatory but rather valuntary? Thanks Peter On Tuesday, January 6, 2026 at 05:48:11 AM PST, James Hulbert <[email protected]<mailto:[email protected]>> wrote: We all own a debit of gratitude to Leonard Frier. Jim Hulbert From: John Allen <[email protected]<mailto:[email protected]>> Sent: Monday, January 5, 2026 7:55 PM To: [email protected]<mailto:[email protected]> Subject: [EXTERNAL] Re: [PSES] Mandatory NRTL certification This message is from an EXTERNAL EMAIL system. Use caution and think before opening attachments, clicking links, or responding. By the way, "NRTL" used to say "UL". Leonard Frier (owner of MET labs), god bless that man, took OSHA to court and in 1988 the OSHA regulation changed from "UL" to "NRTL". Here is a copy of the Federal Register back in 1988............. Best Regards and Be Safe, John John Allen | President & CEO | Product Safety Consulting, Inc. Your Outsourced Compliance Department® 630-238-0188, Cell: 630-330-3145 https://www.youtube.com/channel/UCVSzENmSoWeNFSBQcOYN7-A www.productsafetyinc.com<https://urldefense.com/v3/__http://www.facebook.com/pages/Product-Safety-Consulting-Inc/97306850917__;!!GXa4NB5MBjHR!QWzoP4he-0GDBE_08PDsLCHh-IxQgC5p8T3Pf3mPb0d3oJGwITM0mNXq_cxaGlZ_d9W1jlLJbbXMTQhI_5Fp1FyOm-hF-7s$> https://search.anab.org/public/organization_files/Product-Safety-Consulting-Inc-Cert-and-Scope-File-11-07-2025_1762537985.pdf Please be sure to fill out our PSC FEEDBACK FORM +++++++++++++++++++++++++++++++++++++++++++ IEEE Product Safety Engineering Society President 2024-2025 Compliance 101 Technical Committee Chairman IEEE Senior Member Keeping our members informed and educated on Product Safety and Compliance https://ewh.ieee.org/soc/pses/index.html Although PSC maintains the highest level of virus protection, this e-mail and any attachments should be scanned by your virus protection software. It is the responsibility of the recipient to check that it is virus free. PSC does not accept any responsibility for data loss or systems damage arising in any way from its use. This message is confidential and intended only for the individual to whom or entity to which it is addressed. If you are not the intended recipient or addressee, or an employee or agent responsible for delivering this message to the addressee, you are hereby notified that any dissemination, distribution, or copying, in whole or part, of this message is strictly prohibited. If you believe that you have been sent this message in error, please do not read it. Please immediately reply to sender that you have received this message in error. Then permanently delete all copies of the message. Thank you ________________________________ From: John Allen <[email protected]> Sent: Monday, January 5, 2026 6:43 PM To: [email protected] <[email protected]> Subject: Re: [PSES] Mandatory NRTL certification Hello and Happy New Year!! I hope to simplify and clarify the vagueness - See OSHA's definition of acceptable installation below. OSHA requires NRTL if there is an applicable Standard (item 1). If there is not an applicable Standard the AHJ can accept his own evaluation or another Federal agency's evaluation (item 2), or if the equipment is custom the AHJ can accept the manufacturers test data (item 3). Our experience is Field Evaluation labeling satisfies most AHJs for items 2 and 3. I believe AHJs do not want the liability of accepting non-Certified installations and prefer an NRTL FE label at a minimum. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.399 Part Number:1910 * Part Number Title:Occupational Safety and Health Standards * Subpart:1910 Subpart S * Subpart Title:Electrical * Standard Number: 1910.399 * Title: Definitions applicable to this subpart. * GPO Source: e-CFR Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this subpart S: (1) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory recognized pursuant to § 1910.7; or (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; or (3) With respect to custom-made equipment or related installations that are designed, fabricated for, and intended for use by a particular customer, if it is determined to be safe for its intended use by its manufacturer on the basis of test data which the employer keeps and makes available for inspection to the Assistant Secretary and his authorized representatives. Best Regards and Be Safe, John John Allen | President & CEO | Product Safety Consulting, Inc. Your Outsourced Compliance Department® 630-238-0188, Cell: 630-330-3145 https://www.youtube.com/channel/UCVSzENmSoWeNFSBQcOYN7-A www.productsafetyinc.com https://search.anab.org/public/organization_files/Product-Safety-Consulting-Inc-Cert-and-Scope-File-11-07-2025_1762537985.pdf Please be sure to fill out our PSC FEEDBACK FORM +++++++++++++++++++++++++++++++++++++++++++ IEEE Product Safety Engineering Society President 2024-2025 Compliance 101 Technical Committee Chairman IEEE Senior Member Keeping our members informed and educated on Product Safety and Compliance https://ewh.ieee.org/soc/pses/index.html Although PSC maintains the highest level of virus protection, this e-mail and any attachments should be scanned by your virus protection software. It is the responsibility of the recipient to check that it is virus free. PSC does not accept any responsibility for data loss or systems damage arising in any way from its use. This message is confidential and intended only for the individual to whom or entity to which it is addressed. If you are not the intended recipient or addressee, or an employee or agent responsible for delivering this message to the addressee, you are hereby notified that any dissemination, distribution, or copying, in whole or part, of this message is strictly prohibited. If you believe that you have been sent this message in error, please do not read it. Please immediately reply to sender that you have received this message in error. Then permanently delete all copies of the message. Thank you ________________________________ From: Ralph McDiarmid <[email protected]> Sent: Monday, January 5, 2026 6:17 PM To: [email protected] <[email protected]> Subject: Re: [PSES] Mandatory NRTL certification [EXTERNAL EMAIL] DO NOT CLICK links or attachments unless you recognize the sender and know the content is safe. Happy New Year. The US Dept of Labor has a mandate to enforce workplace safety regulations. One of its many agencies is the Occupational Safety and Health Administration which is tasked with ensuring a safe work environment by enforcing product compliance by the application of US standards and done by accredited laboratories. That means products that are within scope of at least one UL standard must be shown to be compliant to that standard by a Nationally Recognized Testing Laboratory. (an accredited laboratory and OSHA runs the NRTL accreditation program) Ralph From: [email protected] <[email protected]> Sent: January 5, 2026 3:40 PM To: [email protected] Subject: [PSES] Mandatory NRTL certification Happy New Year to all I was asked by one of the engineers that I work with if getting safety certification for a product in the US is mandatory or not? i.e do manufacturer of electrical or electronics have to have certification from NRTL or other 3rd party labs? The products in question are 100% used in professional environment and are not intended for general consumer market. If this is a mandatory requirement, where can I see the requirements written? Thanks Pete ________________________________ This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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