Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[James Pawson (U3C)]

Hello Peter,

 

For the EMC/EMI side of things, I believe the table in CFR 47 15.101 

  is the key. The Suppliers Declaration of Conformity (SDoC) path means no 
formal certification is required. You don’t even have to use an accredited test 
laboratory (you do for Certification).

 

The definition for SDoC is in 2.906 

  (more explanation in 2.1071 

  onwards) and Certification in 2.907 

  (more explanation in 2.1031 

  onwards).

 

Hope this is useful

All the best

James

 

 

 

James Pawson

EMC Problem Solver

 

Unit 3 Compliance

Design for EMC / Pre Compliance / Problem Solving / EMC Testing / Consultancy / 
Environmental & Vibration

  www.unit3compliance.co.uk -- 07811 139957

Opening Hours: Tuesday to Friday, 0830 to 1800. Closed Monday.

 

From: 06cee064502d-dmarc-requ...@ieee.org 
<06cee064502d-dmarc-requ...@ieee.org> 
Sent: 18 February 2020 04:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms. 

 

With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?

 

Thanks

Peter

-Original Message-
From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org 
 >
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Hello Peter,

 

Let me add to Rich and Regan’s comments.

 

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices. 

 

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice. 

 

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage device that isn’t 
mains connected, you will need to understand your customer’s needs before you 
make any determination about skipping NRTL approval.

 

Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL 
approval, you can state that you are selling a product to the general public 
for home use where NRTL approval for a mouse is clearly not required. You can 
then argue that any business that purchases it is making their own decision on 
whether to accept a non-NRTL product. However, it is up to you, your employer 
and your employer’s legal department on whether you should take this approach.

 

Ted Eckert

The opinions expressed do not necessarily reflect those of my employer, OSHA or 
the U.S. Department of Labor.

 

From: Richard Nute mailto:ri...@ieee.org> > 
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [EXTERNAL] Re: [PSES] Mandatory certification

 

 

Hi Peter:

 

I can only speak to NRTL certification. 

 

If your product can be used in a workplace, then NRTL certification is 
mandatory.  

 

In most non-workplace locations, safety certification is mandatory.  A local 
authority specifies the acceptable certification houses.  Most local 
authorities specify the NRTL certification houses.  

 

Certification by a NRTL certification house is accepted almost universally in 
the USA.  

 

Best regards,

Rich

 

 

-

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[000006cee064502d-dmarc-request]

Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms.
With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?
ThanksPeter

-Original Message-
From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
To: EMC-PSTC 
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

#yiv5277480094 #yiv5277480094 -- _filtered {} _filtered {} #yiv5277480094 
#yiv5277480094 p.yiv5277480094MsoNormal, #yiv5277480094 
li.yiv5277480094MsoNormal, #yiv5277480094 div.yiv5277480094MsoNormal 
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#yiv5277480094 a:link, #yiv5277480094 span.yiv5277480094MsoHyperlink 
{color:blue;text-decoration:underline;} #yiv5277480094 
span.yiv5277480094EmailStyle20 {font-family:sans-serif;color:windowtext;} 
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#yiv5277480094 div.yiv5277480094WordSection1 {} #yiv5277480094 Hello Peter,    
Let me add to Rich and Regan’s comments.    The question for residential 
installations isn’t as clear as for the workplace. Most jurisdictions in the 
United States have adopted the National Electrical Code which requires many 
electrical and electronic products to either be Listed or to be investigated 
and approved by the local Authority Having Jurisdiction. In practice, this 
typically will apply to hard-wired products or products attached to building 
structure. The enforcement is typically through an electrical inspection which 
will often not cover plug-connected devices.     In the workplace, any product 
that has a direct connection to the mains will need NRTL approval. At the other 
end of the spectrum, a product like a USB mouse or remote control using 
alkaline batteries likely won’t need NRTL approval. In theory, I believe an 
OSHA inspector could enforce the NRTL requirement on any electrical product, 
but that won’t necessarily be what happens in practice.    That being said, you 
can choose not to get NRTL approval for your product. However, you need to 
understand the risks your product may pose. If you sell products to commercial 
customers, are you meeting their needs? Will your products be acceptable to 
them? If you have a low-voltage device that isn’t mains connected, you will 
need to understand your customer’s needs before you make any determination 
about skipping NRTL approval.    Let’s use the USB mouse example. If you sell a 
USB mouse that has no NRTL approval, you can state that you are selling a 
product to the general public for home use where NRTL approval for a mouse is 
clearly not required. You can then argue that any business that purchases it is 
making their own decision on whether to accept a non-NRTL product. However, it 
is up to you, your employer and your employer’s legal department on whether you 
should take this approach.    Ted Eckert The opinions expressed do not 
necessarily reflect those of my employer, OSHA or the U.S. Department of Labor. 
   From: Richard Nute  
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Mandatory certification       Hi Peter:    I can 
only speak to NRTL certification.    If your product can be used in a 
workplace, then NRTL certification is mandatory.     In most non-workplace 
locations, safety certification is mandatory.  A local authority specifies the 
acceptable certification houses.  Most local authorities specify the NRTL 
certification houses.      Certification by a NRTL certification house is 
accepted almost universally in the USA.     Best regards, Rich       -
 This message 
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To post a message to the list, send your e-mail to  All 
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All emc-pstc postings are archived and searchable on the web 
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Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Ted Eckert]

Hello Peter,

Let me add to Rich and Regan’s comments.

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices.

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice.

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage device that isn’t 
mains connected, you will need to understand your customer’s needs before you 
make any determination about skipping NRTL approval.

Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL 
approval, you can state that you are selling a product to the general public 
for home use where NRTL approval for a mouse is clearly not required. You can 
then argue that any business that purchases it is making their own decision on 
whether to accept a non-NRTL product. However, it is up to you, your employer 
and your employer’s legal department on whether you should take this approach.

Ted Eckert
The opinions expressed do not necessarily reflect those of my employer, OSHA or 
the U.S. Department of Labor.

From: Richard Nute 
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Mandatory certification


Hi Peter:

I can only speak to NRTL certification.

If your product can be used in a workplace, then NRTL certification is 
mandatory.

In most non-workplace locations, safety certification is mandatory.  A local 
authority specifies the acceptable certification houses.  Most local 
authorities specify the NRTL certification houses.

Certification by a NRTL certification house is accepted almost universally in 
the USA.

Best regards,
Rich


-


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-

Re: [PSES] Mandatory certification

[Richard Nute]

 

Hi Peter:

 

I can only speak to NRTL certification. 

 

If your product can be used in a workplace, then NRTL certification is 
mandatory.  

 

In most non-workplace locations, safety certification is mandatory.  A local 
authority specifies the acceptable certification houses.  Most local 
authorities specify the NRTL certification houses.  

 

Certification by a NRTL certification house is accepted almost universally in 
the USA.  

 

Best regards,

Rich

 

 


-

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 


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://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:
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Re: [PSES] Mandatory certification

[Regan Arndt]

Hi Peter.
Here is a very good link on NRTL and requirements by OSHA:
*https://www.osha.gov/dts/shib/shib021610.html
*

As for the FCC, see this link, specifically subpart B
https://www.ecfr.gov/cgi-bin/text-idx?SID=c7be03a4f7b02514cea89421fc363794=true=/ecfrbrowse/Title47/47cfr15_main_02.tpl


Hope this helps.

Regan


On Mon, Feb 17, 2020 at 3:25 PM <06cee064502d-dmarc-requ...@ieee.org>
wrote:

> Hello colleagues,
>
> I have a simple question. For an IT product that falls under 60950-1 and
> CISPR 32, do FCC and NRTL certification mandatory? I have always been under
> the impression that the when it comes to EMI/EMC, testing and
> certification/validation is mandatory but when it comes to product safety
> it is not but I am not 100% sure about my assumption. The product is
> unintentional radiator.
>
> Thanks
> 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://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:
> Scott Douglas sdoug...@ieee.org
> Mike Cantwell mcantw...@ieee.org
>
> For policy questions, send mail to:
> Jim Bacher j.bac...@ieee.org
> David Heald dhe...@gmail.com
>

-

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discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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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://www.ieee-pses.org/list.html (including how to unsubscribe)
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[PSES] Mandatory certification

[000006cee064502d-dmarc-request]

Hello colleagues,


I have a simple question. For an IT product that falls under60950-1 and CISPR 
32, do FCC and NRTL certification mandatory? I have always been under the 
impression that the when it comes to EMI/EMC, testing and 
certification/validation is mandatory but when it comes to product safety it is 
not but I am not 100% sure about my assumption. The product is unintentional 
radiator.


Thanks
Peter

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-

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discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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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://www.ieee-pses.org/list.html (including how to unsubscribe)
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