Re: [PSES] Mandatory NRTL certification
Hi Peter, While the NRTL program and NRTL approval is used by a variety of local AHJs, employers and retailers, the program was developed by OSHA for OSHA's purposes. OSHA requires certain types of equipment (http://www.osha.gov/dts/otpca/nrtl/prodcatg.html) to be approved by an NRTL. Electrical equipment must be Acceptable to the Assistant Secretary of Labor as defined in 29 CFR 1910.399 (http://www.gpo.gov/fdsys/pkg/CFR-2011-title29-vol5/pdf/CFR-2011-title29-vol5-sec1910-399.pdf). 1910.399 provides three options to comply 1) Approval by an NRTL, 2) Approval by another regulatory body if it is of a type of equipment that no NRTL will approve or 3) Approval my the manufacturer if the product is custom made. Most equipment manufactured would not meet the requirements of options 2 or 3, so it would need to be approved by an NRTL. OSHA's authority in this area is limited to the employer, as such, the burden of complying with NRTL Approval requirements falls on US employers, not the product manufacturer. Product manufacturers have no LEGAL requirement (at least per OSHA regulations) to have their products tested or certified by an NRTL, however, due to the potentially destructive nature of the tests, the time and cost involved, as well as the amount of potentially confidental or priveleged information that must be provided to the NRTLs, most manufacturers opt to take on the burden of having the product certified by an NRTL. The NRTL Certification mark that is applied to the product can then be used by an employer to demonstrate to OSHA that they meet the applicable approval requirements. If your product could also be used in and around a home or school, or is classified as a medical device, it may also be subject to CPSC and/or FDA requirements in addition to OSHA requirements. If you have any additional questions, please feel free to contact me directly. Kevin Robinson Department of Labor – OSHA NRTL Program Engineer Lead Auditor Office of Technical Programs Coordination Activities 200 Constitution Ave, NW, Room N-3655 Washington DC 20210 Phone: 202 -693-1911 Fax: 202-693-1644 E-mail: robinson.ke...@dol.gov From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Thursday, January 05, 2012 5:41 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Mandatory NRTL certification Hello All, Today a colleague asked me a question as to why do we need NRTL certification such as UL or CSA on any product in the US. I thought this was a good and logical question and the way I answered it was that to the best of my knowledge, OSHA requires that any products that is used in work place to be safe and to have been certified by one of the NRTL labs. Would you say that is a correct answer? Thank you Peter - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Mandatory NRTL certification
While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require an NRTL mark for mains connected electronic products...and laws in 4 other States which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States... From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification NRTL certification/listing is not mandatory for product Manufacturers. This is a Customer driven requirement so your Customers can comply with local OSHA requirements. If you don't want to list or certify your product that's really a Marketing call. Also, it is my experience that most large Companies require third party approvals as a condition of sale. Therefore, unless you want to be reactive to Customer sales I would make sure your Marketing people understand the risk of losing a sale if your product is not certified/listed by an NRTL. Best regards, Ron Wellman From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Thursday, January 05, 2012 5:41 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Mandatory NRTL certification Hello All, Today a colleague asked me a question as to why do we need NRTL certification such as UL or CSA on any product in the US. I thought this was a good and logical question and the way I answered it was that to the best of my knowledge, OSHA requires that any products that is used in work place to be safe and to have been certified by one of the NRTL labs. Would you say that is a correct answer? Thank you Peter - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] International Certification Engineer Job Opening at Bose Corporation
This position is for International Certification Engineer at the Framingham, Massachusetts facility. The position was created to help coordinate the Worldwide Certification submittals for Bose Products. If interested please apply at the links below Bose.com 14348BR - 001191: Engineer III, Electrical View detailshttps://jobs.brassring.com/1033/asp/tg/cim_jobdetail.asp?jobId=591651PartnerId=3SiteId=58type=mailJobReqLang=1recordstart=1JobSiteId=58JobSiteInfo=591651_58gqid=0 LinkedIn http://www.linkedin.com/jobs?viewJob=jobId=2325090trk=jobs_biz_nprem John Tyra Manager Product Safety Group Bose Corporation The Mountain, MS-450 Framingham, MA 01701-9168 phone: 508-766-1502 fax: 508-518-4137 john_t...@bose.com CONFIDENTIALITY NOTICE: This e-mail and any attachments relate to the official business of Bose Corporation and are proprietary to Bose. This e-mail and any attachments may contain information which is confidential, proprietary, privileged or otherwise protected by law. The information is solely intended for the named addressee (or a person responsible for delivering it to the addressee). If you are not the intended recipient of this message, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this e-mail in error, please notify the sender immediately by return e-mail and delete it from your computer. - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Mandatory NRTL certification
This question comes up about every two years and what it boils down to is a catch 22. Damned if you do, damned if you don't. In my opinion, it is better to do regardless of how unbalanced these requirements are within the United States. As long as you budget for it and your management understands the risks of not having NRTL listing, it will be easier to manage. Best regards, Ron Wellman From: Tyra, John [mailto:john_t...@bose.com] Sent: Friday, January 06, 2012 6:34 AM To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Subject: RE: Mandatory NRTL certification While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require an NRTL mark for mains connected electronic products.and laws in 4 other States which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification NRTL certification/listing is not mandatory for product Manufacturers. This is a Customer driven requirement so your Customers can comply with local OSHA requirements. If you don't want to list or certify your product that's really a Marketing call. Also, it is my experience that most large Companies require third party approvals as a condition of sale. Therefore, unless you want to be reactive to Customer sales I would make sure your Marketing people understand the risk of losing a sale if your product is not certified/listed by an NRTL. Best regards, Ron Wellman From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Thursday, January 05, 2012 5:41 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Mandatory NRTL certification Hello All, Today a colleague asked me a question as to why do we need NRTL certification such as UL or CSA on any product in the US. I thought this was a good and logical question and the way I answered it was that to the best of my knowledge, OSHA requires that any products that is used in work place to be safe and to have been certified by one of the NRTL labs. Would you say that is a correct answer? Thank you Peter - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy
Re: [PSES] Mandatory NRTL certification
John, would you happen to have a link to that survey? Ian Schroeder Regulatory Compliance Engineer Echostar Technologies L.L.C. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Tyra, John Sent: Friday, January 06, 2012 7:34 AM To: 'Ron Wellman'; 'peterh...@aol.com'; 'emc-pstc@listserv.ieee.org' Subject: RE: Mandatory NRTL certification While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require an NRTL mark for mains connected electronic products...and laws in 4 other States which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States... From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification NRTL certification/listing is not mandatory for product Manufacturers. This is a Customer driven requirement so your Customers can comply with local OSHA requirements. If you don't want to list or certify your product that's really a Marketing call. Also, it is my experience that most large Companies require third party approvals as a condition of sale. Therefore, unless you want to be reactive to Customer sales I would make sure your Marketing people understand the risk of losing a sale if your product is not certified/listed by an NRTL. Best regards, Ron Wellman From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Thursday, January 05, 2012 5:41 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Mandatory NRTL certification Hello All, Today a colleague asked me a question as to why do we need NRTL certification such as UL or CSA on any product in the US. I thought this was a good and logical question and the way I answered it was that to the best of my knowledge, OSHA requires that any products that is used in work place to be safe and to have been certified by one of the NRTL labs. Would you say that is a correct answer? Thank you Peter - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas
Re: [PSES] Mandatory NRTL certification
Hi all, Regardless of the OSHA requirements already addressed within this list, don't lose sight of the fact that there's The Law of Economics at play here as well. I don't believe any major retailer (Walmart, Target, K-Mart, Sears, etc.) will accept electrical/electronic products without NRTL markings. Some even have their own test labs to further satisfy themselves that the products are safe. Additionally, in the workplace or other commercial structures, it's a requirement of most insurance policies that electrical/electronic products bear NRTL markings. Best regards, Art A.E. Michael, Dir. of Engineering Product Safety Int'l 166 Congdon St. East Middletown CT 06457-2107 U.S.A. Phone : (860) 344-1651 Email : p...@safetylink.com Website: http://www.safetylink.com - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Mandatory NRTL certification
Hi, Kevin (from OSHA) thank you very much!! And Ron, point well taken. We are a consultancy and test lab and work with small to medium size companies that don't have a clue and we get this question at least once a month. For Household products there are no federal laws that I am aware of relating to NRTL. However, the industry polices itself, although sometimes not too consistently (i.e.; Walmart requires NRTL, but I've seen Walmart brand products in their stores without NRTL). Another reason is liability. If something happens in the field and you don't have NRTL, good luck!! For those of us who are very familiar with the NRTL program, we should all realize it is the absolute minimum. They do have factory inspections but only to confirm the product being made is what was tested. The NRTL program does not look at how a product can go out the door with a safety hazard (i.e.; Process FMEA). Most recalls of electrical products are products that have an NRTL Certification. Rightfully, our industry is moving toward Risk Management and Assessments and they are being built into our Standards (IEC60601 3rd edition and ISO14971, IEC 62368, Machinery Directive, General Product Safety Directive and RAPEX, etc.). It is in our best interest as compliance engineers to know this, learn Hazard Analysis and Risk Assessments, teach others about them, etc. This will raise the bar of safety in our country and around the world. If anyone is interested in learning more or staying in touch with Risk Assessments, please take a look at the IEEE's PSES Risk Assessment Technical Committee (yes, that was a pitch for more members). See links below. IEEE PSES - http://ewh.ieee.org/soc/pses/ IEEE PSES Chicago - http://ewh.ieee.org/r4/chicago/pstc/ IEEE PSES Risk Assessment Technical Committee - http://ewh.ieee.org/soc/pses/TAC/RATC/index.html Have a nice weekend. John Allen Product Safety Consulting, Inc. 605 Country Club Drive, Suites I J Bensenville, IL 60106 P - 630 238-0188 / F - 630 238-0269 1-877-804-3066 jral...@productsafetyinc.commailto:jral...@productsafetyinc.com http://www.productsafetyinc.comhttp://www.productsafetyinc.com/ 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: Ron Wellman [mailto:rwell...@wellman.com] Sent: Friday, January 06, 2012 9:27 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Mandatory NRTL certification This question comes up about every two years and what it boils down to is a catch 22. Damned if you do, damned if you don't. In my opinion, it is better to do regardless of how unbalanced these requirements are within the United States. As long as you budget for it and your management understands the risks of not having NRTL listing, it will be easier to manage. Best regards, Ron Wellman From: Tyra, John [mailto:john_t...@bose.com]mailto:[mailto:john_t...@bose.com] Sent: Friday, January 06, 2012 6:34 AM To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Subject: RE: Mandatory NRTL certification While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require an NRTL mark for mains connected electronic products...and laws in 4 other States which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States... From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: peterh...@aol.commailto:peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification NRTL certification/listing is not mandatory for product Manufacturers. This is a Customer driven requirement so your Customers can comply with local OSHA requirements. If you don't want to list or certify your product that's really a Marketing call. Also, it is my experience that most large Companies require third party approvals
Re: [PSES] Mandatory NRTL certification
John and all, thank you for a great feedback. The follow-up question is that how about products that are sold outside consumer market and basically are sold to professional market where their use and installation are done by professionals. These types of products are not available through regular retailers. Would I be correct to say that same applies? Thank you again Peter -Original Message- From: jral...@productsafetyinc.com jral...@productsafetyinc.com To: Ron Wellman rwell...@wellman.com; EMC-PSTC EMC-PSTC@LISTSERV.IEEE.ORG Sent: Fri, Jan 6, 2012 7:54 am Subject: RE: [PSES] Mandatory NRTL certification Hi, Kevin (from OSHA) thank you very much!! And Ron, point well taken. We are a consultancy and test lab and work with small to medium size companies that don’t have a clue and we get this question at least once a month. For Household products there are no federal laws that I am aware of relating to NRTL. However, the industry polices itself, although sometimes not too consistently (i.e.; Walmart requires NRTL, but I’ve seen Walmart brand products in their stores without NRTL). Another reason is liability. If something happens in the field and you don’t have NRTL, good luck!! For those of us who are very familiar with the NRTL program, we should all realize it is the absolute minimum. They do have factory inspections but only to confirm the product being made is what was tested. The NRTL program does not look at how a product can go out the door with a safety hazard (i.e.; Process FMEA). Most recalls of electrical products are products that have an NRTL Certification. Rightfully, our industry is moving toward Risk Management and Assessments and they are being built into our Standards (IEC60601 3rd edition and ISO14971, IEC 62368, Machinery Directive, General Product Safety Directive and RAPEX, etc.). It is in our best interest as compliance engineers to know this, learn Hazard Analysis and Risk Assessments, teach others about them, etc. This will “raise the bar” of safety in our country and around the world. If anyone is interested in learning more or staying in touch with Risk Assessments, please take a look at the IEEE’s PSES Risk Assessment Technical Committee (yes, that was a pitch for more members). See links below. IEEE PSES - http://ewh.ieee.org/soc/pses/ IEEE PSES Chicago - http://ewh.ieee.org/r4/chicago/pstc/ IEEE PSES Risk Assessment Technical Committee - http://ewh.ieee.org/soc/pses/TAC/RATC/index.html Have a nice weekend. John Allen Product Safety Consulting, Inc. 605 Country Club Drive, Suites I J Bensenville, IL 60106 P - 630 238-0188 / F - 630 238-0269 1-877-804-3066 jral...@productsafetyinc.com http://www.productsafetyinc.com 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: Ron Wellman [mailto:rwell...@wellman.com] Sent: Friday, January 06, 2012 9:27 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Mandatory NRTL certification This question comes up about every two years and what it boils down to is a catch 22. Damned if you do, damned if you don’t. In my opinion, it is better to do regardless of how unbalanced these requirements are within the United States. As long as you budget for it and your management understands the risks of not having NRTL listing, it will be easier to manage. Best regards, Ron Wellman From: Tyra, John [mailto:john_t...@bose.com] Sent: Friday, January 06, 2012 6:34 AM To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Subject: RE: Mandatory NRTL certification While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require an NRTL mark for mains connected electronic products…and laws in 4 other States which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States……….. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012
Re: [PSES] Mandatory NRTL certification
I don't see where companies really have much of a choice as this is a legal requirement in 20 States for Consumer products From: Ron Wellman [mailto:rwell...@wellman.com] Sent: Friday, January 06, 2012 10:27 AM To: Tyra, John; peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification This question comes up about every two years and what it boils down to is a catch 22. Damned if you do, damned if you don't. In my opinion, it is better to do regardless of how unbalanced these requirements are within the United States. As long as you budget for it and your management understands the risks of not having NRTL listing, it will be easier to manage. Best regards, Ron Wellman From: Tyra, John [mailto:john_t...@bose.com] Sent: Friday, January 06, 2012 6:34 AM To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Subject: RE: Mandatory NRTL certification While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require an NRTL mark for mains connected electronic products...and laws in 4 other States which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States... From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: peterh...@aol.commailto:peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification NRTL certification/listing is not mandatory for product Manufacturers. This is a Customer driven requirement so your Customers can comply with local OSHA requirements. If you don't want to list or certify your product that's really a Marketing call. Also, it is my experience that most large Companies require third party approvals as a condition of sale. Therefore, unless you want to be reactive to Customer sales I would make sure your Marketing people understand the risk of losing a sale if your product is not certified/listed by an NRTL. Best regards, Ron Wellman From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.commailto:peterh...@aol.com Sent: Thursday, January 05, 2012 5:41 PM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Mandatory NRTL certification Hello All, Today a colleague asked me a question as to why do we need NRTL certification such as UL or CSA on any product in the US. I thought this was a good and logical question and the way I answered it was that to the best of my knowledge, OSHA requires that any products that is used in work place to be safe and to have been certified by one of the NRTL labs. Would you say that is a correct answer? Thank you Peter - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com -
Re: [PSES] Mandatory NRTL certification
interesting aspects of this topic 1) Authorities Having Jurisdiction (AHJ) that has adopted the National Electrical Code (NEC) also place a requirement for an NRTL mark on a device. So while there maybe no state requirements there are AHJs (City, County,…) requirements for devices to have an NTRL mark. Los Angeles http://www.ladbs.org/ FUNCTION OF THE LOS ANGELES ELECTRICAL TESTING LABORATORY The California Electrical Code requires under Sections 110.2 and 110.3 that electrical equipment be safety approved by the authority having jurisdiction or listed by an approved testing laboratory. In addition, the City of Los Angeles Municipal Code Section 93.0402 also requires approval for these equipment, if a listing cannot be secured, either by the Los Angeles Electrical Testing Laboratory (LAETL) or third party testing agencies recognized by the City. 2) Do not assume that Federal Regulations preempt state or local requirements for NRTL listing. For example medical devices. 21 CFR §808.1 (d)(1) SUBCHAPTER H--MEDICAL DEVICES PART 808 -- EXEMPTIONS FROM FEDERAL PREEMPTION OF STATE AND LOCAL MEDICAL DEVICEREQUIREMENTS Subpart A--General Provisions (1) Section 521(a) does not preempt State or local requirements of general applicability where the purpose of the requirement relates either to other products in addition to devices (e.g., requirementssuch as general electrical codes, and the Uniform Commercial Code (warranty of fitness)), or to unfair trade practices in which the requirements are not limited to devices. 3) State laws are unique in scope: http://www.bcd.oregon.gov/rules_statutes/compilations/oar/306.pdf http://egov.sos.state.or.us/division/archives/rules/OARS_900/OAR_918/918_306.html 918-306- Scope and Authority for Rule (1) The rules in OAR 918-306- to 918-306- 0530 deal with the different ways to qualify an electrical product for sale, disposal and installation in Oregon. (2) Authority for rules. (a) ORS 479.540 authorizes partial and complete product exemptions; (b) ORS 479.610 requires products for sale in Oregon to be certified; and (c) ORS 479.730 authorizes creation of procedures for product certifications, administration and enforcement and field evaluation of electrical products. 918-306-0010 Overview (1) ORS 479.610 establishes certification requirements for electrical products. (2) The certification process generally involves inspection, testing and evaluation of the product. This is done through: (a) Listing and application of listing label by a Nationally Recognized Testing Laboratory (NRTL); Oregon Law 479.610 479.610 Sale or disposal of uncertified or unevaluated electrical product prohibited. Except as provided under ORS 479.540http://www.paperadvantage.org/ORS/479.html#479.540#479.540, no person shall sell or dispose of by gift or otherwise in connection with the person’s business an electrical product that is not certified or evaluated under the requirements of ORS 479.510http://www.paperadvantage.org/ORS/479.html#479.510#479.510 to 479.945http://www.paperadvantage.org/ORS/479.html#479.945#479.945 and 479.995http://www.paperadvantage.org/ORS/479.html#479.995#479.995. [1959 c.406 §9; 1981 c.815 §12; 1995 c.706 §2] Bill Opinions expressed are my own and not necessarily those of my employer, use at your own risk From: Tyra, John john_t...@bose.commailto:john_t...@bose.com Reply-To: Tyra, John john_t...@bose.commailto:john_t...@bose.com Date: Fri, 6 Jan 2012 09:34:16 -0500 To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Mandatory NRTL certification While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require anNRTL mark for mains connected electronic products…and laws in 4 otherStates which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States……….. From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: peterh...@aol.commailto:peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification NRTL certification/listing is not mandatory for product Manufacturers. This is a Customer driven requirement so your Customers can comply with local OSHA requirements. If you don’t want to list or certify your product that’s really a Marketing call. Also, it is my experience that most large Companies require third party approvals as a condition of sale. Therefore, unless you want to be reactive to Customer sales I would make sure your Marketing people understand the risk of losing a sale if your product is not certified/listed by an NRTL. Best regards, Ron Wellman From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of
Re: [PSES] Mandatory NRTL certification
Thanks William for the information. I would like to add from the 918-306-0010 Overview that NTRL is only one of three methods that can be used. Note that (c) is a Field Evaluation which is generally performed to the requirements of the state or local electrical code. I'm assuming Peter's question is more geared toward low volume non-commercial products. It is not practical for many manufacturers of such products to obtain NRTL Certification but will support a Field Evaluation performed at the customer site if they desire or are required. All of the local codes I have had the opportunity to look at (so far) accepts a field evaluation in addition to the NRTL Certification. Many companies hire local inspectors to perform such evaluations. The Other Brian -- 918-306-0010 Overview (1) ORS 479.610 establishes certification requirements for electrical products. (2) The certification process generally involves inspection, testing and evaluation of the product. This is done through: (a) Listing and application of listing label by a Nationally Recognized Testing Laboratory (NRTL); (b) Special Deputy Evaluation and Certification. A product can be submitted to the division for certification under ORS 479.760. The special deputy procedures, rules and limitations are located in OAR 918-306-0510 to 918-306-0530; or (c) Field Evaluation of Products. Field evaluation involves inspection, testing, evaluation and application of an evaluation label utilizing Recommended Practice and Procedures for Unlabeled Electrical Equipment Evaluation dated June 2003 and published by the American Council of Independent Laboratories (ACIL). From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Morse, William Sent: Friday, January 06, 2012 12:23 PM To: Tyra, John; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Mandatory NRTL certification interesting aspects of this topic 1) Authorities Having Jurisdiction (AHJ) that has adopted the National Electrical Code (NEC) also place a requirement for an NRTL mark on a device. So while there maybe no state requirements there are AHJs (City, County,...) requirements for devices to have an NTRL mark. Los Angeles http://www.ladbs.org/ FUNCTION OF THE LOS ANGELES ELECTRICAL TESTING LABORATORY The California Electrical Code requires under Sections 110.2 and 110.3 that electrical equipment be safety approved by the authority having jurisdiction or listed by an approved testing laboratory. In addition, the City of Los Angeles Municipal Code Section 93.0402 also requires approval for these equipment, if a listing cannot be secured, either by the Los Angeles Electrical Testing Laboratory (LAETL) or third party testing agencies recognized by the City. 2) Do not assume that Federal Regulations preempt state or local requirements for NRTL listing. For example medical devices. 21 CFR §808.1 (d)(1) SUBCHAPTER H--MEDICAL DEVICES PART 808 -- EXEMPTIONS FROM FEDERAL PREEMPTION OF STATE AND LOCAL MEDICAL DEVICEREQUIREMENTS Subpart A--General Provisions (1) Section 521(a) does not preempt State or local requirements of general applicability where the purpose of the requirement relates either to other products in addition to devices (e.g., requirementssuch as general electrical codes, and the Uniform Commercial Code (warranty of fitness)), or to unfair trade practices in which the requirements are not limited to devices. 3) State laws are unique in scope: http://www.bcd.oregon.gov/rules_statutes/compilations/oar/306.pdf http://egov.sos.state.or.us/division/archives/rules/OARS_900/OAR_918/918_306.html 918-306- Scope and Authority for Rule (1) The rules in OAR 918-306- to 918-306- 0530 deal with the different ways to qualify an electrical product for sale, disposal and installation in Oregon. (2) Authority for rules. (a) ORS 479.540 authorizes partial and complete product exemptions; (b) ORS 479.610 requires products for sale in Oregon to be certified; and (c) ORS 479.730 authorizes creation of procedures for product certifications, administration and enforcement and field evaluation of electrical products. 918-306-0010 Overview (1) ORS 479.610 establishes certification requirements for electrical products. (2) The certification process generally involves inspection, testing and evaluation of the product. This is done through: (a) Listing and application of listing label by a Nationally Recognized Testing Laboratory (NRTL); Oregon Law 479.610 479.610 Sale or disposal of uncertified or unevaluated electrical product prohibited. Except as provided under ORS 479.540http://www.paperadvantage.org/ORS/479.html#479.540#479.540, no person shall sell or dispose of by gift or otherwise in connection with the person's business an electrical product that is not certified or evaluated under the requirements of ORS 479.510http://www.paperadvantage.org/ORS/479.html#479.510#479.510 to
Re: [PSES] Mandatory NRTL certification
In message e9c52f9e77c43c49a56a22691b3680be229...@tk5ex14mbxc301.redmond.corp.micro soft.com, dated Fri, 6 Jan 2012, Ted Eckert ted.eck...@microsoft.com writes: I?ve worked with low-volume and custom built-in equipment, and I would recommend against having a field evaluation done by the AHJ. It is an option, but it can be a very risky option. I have also been advised of that by US colleagues. If the AHJ doesn't like your choice of necktie... -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Some people who are peeling the finch of the financial crisis are thinking of biting a rook. - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] Mandatory NRTL Certification
Ted, In an unrelated instance, one of my colleagues just had an occasion today to discuss field evaluations with UL and was informed that they won't perform field evaluations on equipment older than one year nor if the equipment does not have a UL report. Good day, Richard Pittenger Agency Approval Engineer Food Machines Engineering Hobart/Berkel Disclaimer - This email and any files transmitted with it are confidential and contain privileged or copyrighted information. You must not present this message to another party without first gaining permission from the sender. If you are not the intended recipient, you must not copy, print, distribute or use this email or the information contained in it for any purpose other than to notify us. If you received this email in error, please notify the sender immediately and delete this email from your system. We do not guarantee that this email is free from viruses or any other defects although due care has been taken to minimize the risk. - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Mandatory NRTL certification
For Consumer products I see your point, but what about test, measurement, and laboratory equipment? These products are usually sold business to business and it's really up to the Customer to decide if NRTL is required for the sale. Best regards, Ron Wellman From: Tyra, John [mailto:john_t...@bose.com] Sent: Friday, January 06, 2012 8:50 AM To: 'Ron Wellman'; peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification I don't see where companies really have much of a choice as this is a legal requirement in 20 States for Consumer products From: Ron Wellman [mailto:rwell...@wellman.com] Sent: Friday, January 06, 2012 10:27 AM To: Tyra, John; peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification This question comes up about every two years and what it boils down to is a catch 22. Damned if you do, damned if you don't. In my opinion, it is better to do regardless of how unbalanced these requirements are within the United States. As long as you budget for it and your management understands the risks of not having NRTL listing, it will be easier to manage. Best regards, Ron Wellman From: Tyra, John [mailto:john_t...@bose.com] Sent: Friday, January 06, 2012 6:34 AM To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Subject: RE: Mandatory NRTL certification While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require an NRTL mark for mains connected electronic products.and laws in 4 other States which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification NRTL certification/listing is not mandatory for product Manufacturers. This is a Customer driven requirement so your Customers can comply with local OSHA requirements. If you don't want to list or certify your product that's really a Marketing call. Also, it is my experience that most large Companies require third party approvals as a condition of sale. Therefore, unless you want to be reactive to Customer sales I would make sure your Marketing people understand the risk of losing a sale if your product is not certified/listed by an NRTL. Best regards, Ron Wellman From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Thursday, January 05, 2012 5:41 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Mandatory NRTL certification Hello All, Today a colleague asked me a question as to why do we need NRTL certification such as UL or CSA on any product in the US. I thought this was a good and logical question and the way I answered it was that to the best of my knowledge, OSHA requires that any products that is used in work place to be safe and to have been certified by one of the NRTL labs. Would you say that is a correct answer? Thank you Peter - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com -
Re: [PSES] Mandatory NRTL certification
There is also the chance that the very expensive one-off piece equipment may be damaged by the testing and disassembly it is subjected to in a field inspection. Extra cost, time, and unsatisfied customer... Brian Ceresney, CTech. Regulatory Team Lead, Delta-Q Technologies Corp. 3755 Willingdon Ave., Burnaby, BC Canada V5G 3H3 Tel: 604-566-8827 www.delta-q.com bceres...@delta-q.com Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Friday, January 06, 2012 11:41 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Mandatory NRTL certification In message e9c52f9e77c43c49a56a22691b3680be229...@tk5ex14mbxc301.redmond.corp.micro soft.com, dated Fri, 6 Jan 2012, Ted Eckert ted.eck...@microsoft.com writes: I?ve worked with low-volume and custom built-in equipment, and I would recommend against having a field evaluation done by the AHJ. It is an option, but it can be a very risky option. I have also been advised of that by US colleagues. If the AHJ doesn't like your choice of necktie... -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Some people who are peeling the finch of the financial crisis are thinking of biting a rook. - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Mandatory NRTL Certification
UL has two different services. Field Inspectionhttp://www.ul.com/global/eng/pages/offerings/services/globalfieldservices/fieldservices/fieldinspections/ is to look at equipment that has a Listing report, but left the factory without being UL marked. Field Inspection is done by an inspector who would normally do factory inspection, but does not have the engineering background to do a full evaluation. The inspector is only there to verify that the product matches an existing UL report. I used this service once when a number of air conditioners had to be shipped and installed while the UL Listing process was still in progress. The air conditioners had to go into the building on a certain schedule, and they were a new model still undergoing Listing. Once the Listing was done, the Field Inspection was done, the UL mark was applied and the AHJ was happy. Field Evaluationhttp://www.ul.com/global/eng/pages/offerings/services/globalfieldservices/fieldservices/fieldevaluationservices/ is done by a UL engineer who is evaluating a product to an existing UL standard. This is more common for equipment that is highly customized to an installation such as control panels, motor control centers, robotics and some heating and cooling equipment. There may be a limit on how long the equipment can be in place before the inspection, but it is typically done before the equipment is first used by the customer and would be done relatively soon after installation. UL, being the bureaucracy that they are, might steer you to the wrong program if you aren't careful in describing your needs. However, they do have both programs. It is likely the other NRTLs have similar programs with separate inspection/evaluation programs. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.commailto:ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. From: Richard Pittenger [mailto:richard.pitten...@hobartcorp.com]mailto:[mailto:richard.pitten...@hobartcorp.com] Sent: Friday, January 06, 2012 11:46 AM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Mandatory NRTL Certification Ted, In an unrelated instance, one of my colleagues just had an occasion today to discuss field evaluations with UL and was informed that they won't perform field evaluations on equipment older than one year nor if the equipment does not have a UL report. Good day, Richard Pittenger Agency Approval Engineer Food Machines Engineering Hobart/Berkel Disclaimer - This email and any files transmitted with it are confidential and contain privileged or copyrighted information. You must not present this message to another party without first gaining permission from the sender. If you are not the intended recipient, you must not copy, print, distribute or use this email or the information contained in it for any purpose other than to notify us. If you received this email in error, please notify the sender immediately and delete this email from your system. We do not guarantee that this email is free from viruses or any other defects although due care has been taken to minimize the risk. - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas
Re: [PSES] Mandatory NRTL certification
Microsoft Word - 13608_48002 Adding more fuel to the fire, some AHJs demonstrate a preference for certain NRTLs, meaning they place more credence in some NRTLs certifications over others. This will not necessarily be found in writing. If a product is a relatively new technology in a field, some AHJs question the NRTL’s work, the intent and meaning of standards applicable to a product, and pull requirements from out of scope standards and insist they apply. This thread makes the memory of the recent thread on Orgalime whiningwriting a letter about component certifications all the more hilarious amusing. Regards, Peter L. Tarver *From:* Morse, William [mailto:william.mo...@careinnovations.com] *Sent:* Friday, January 06, 2012 09:23 *To:* EMC-PSTC@LISTSERV.IEEE.ORG *Subject:* Re: [PSES] Mandatory NRTL certification interesting aspects of this topic 1) Authorities Having Jurisdiction (AHJ) that has adopted the National Electrical Code (NEC) also place a requirement for an NRTL mark on a device. So while there maybe no state requirements there are AHJs (City, County,…) requirements for devices to have an NTRL mark. This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Mandatory NRTL Certification
I was unaware that UL certifications had a 1 year shelf life. That statement from UL devalues UL certification in a big way. At a previous employer, we had an environmental chamber moved to a building that had been renovated before we moved in. The AHJ red tagged the chamber, because it lacked an NRTL certification. The chamber was certainly more than a year old and no prior NRTL report existed. UL performed a field evaluation on the chamber with only the proviso that the AHJ accept their letter report and that the company make any necessary changes to the equipment. Regards, Peter L. Tarver *From:* Richard Pittenger [mailto:richard.pitten...@hobartcorp.com] *Sent:* Friday, January 06, 2012 11:46 Ted, In an unrelated instance, one of my colleagues just had an occasion today to discuss field evaluations with UL and was informed that they won’t perform field evaluations on equipment older than one year nor if the equipment does not have a UL report. Good day, Richard Pittenger This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - 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 Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
