RE: U.S. National Product Safety Laws
Art, You absolutely win the prize for the first truly definitive answer to my challenge! Obviously Mr. Blocher had the same trouble interpreting the meaning of utilization equipment. Note how simple it was for OSHA to clearly state that desktop computuers (PCs) are included. It is a shame that the wording in the CFR is so much more obtuse. Now all we need is about 10,000 more such letters to cover pencil sharpeners, plotters, staplers, etc. The horse was not dead, but I think your note finished it off. BTW, your prize is a nomination for the Product Safety Hall of Fame, to be established at the beginning of the third millenium. Regards, George Hello George, While I'm reluctant to flog a dead horse, somewhere along this discussion thread, someone was looking for a definitive statement regarding the subject at hand. After searching OSHA's Interpretation Letters I found the following letter relating OSHA's requirements and (desktop) computers. Regards, Art Michael Editor - Int'l Product Safety News * * * * * * * * * * * * * * * * * * * * * * * International Product Safety Bookshop * * Check out our current offerings! * * http://www.safetylink.com/bookshop.html * * * * Another service of the Safety Link* * www.safetylink.com * * * * * * * * * * * * * * * * * * * * * * * OSHA Banner Image Map OSHA Standards Interpretation and Compliance Letters 02/18/1992 - Electrical standards as it applies to desktop computers. _ OSHA Standard Interpretation and Compliance Letters - Table of Contents OSHA Standard Interpretation and Compliance Letters - Table of Contents _ * Record Type: Interpretation * Standard Number: 1910.303;1910.399 * Subject: Electrical standards as it applies to desktop computers. * Information Date:02/18/1992 _ February 18, 1992 William K. Blocher President BBC Computers Inc. 7 Columbia Circle Merrimack, New Hampshire 03054 Dear Mr. Blocher: Thank you for your letter of January 23, requesting clarification on the applicability of 29 CFR 1910 Subpart S, Electrical standards, to desktop computers. Desktop computers are appliances otherwise described as utilization equipment when used by employees in the workplace. By 29 CFR 1910.303(a) equipment required or permitted by 29 CFR 1910 Subpart S shall be accepted only if approved. Approved means acceptable to the authority, that is, the Assistant Secretary of Labor for Occupational Safety and Health, enforcing 29 CFR 1910 Subpart S. The definition of acceptable includes three different methods to determine acceptable equipment, and these methods are specified at 1910.399. A copy of the 1910.399 definitions, specified by quotation marks in this letter, is enclosed for your use. We appreciate your interest in occupational safety and health. If we can be of further assistance, please do not hesitate to contact us. Sincerely, Patricia K. Clark, Director Directorate of Compliance Programs Enclosure _ OSHA Standard Interpretation and Compliance Letters - Table of Contents OSHA Standard Interpretation and Compliance Letters - Table of Contents tracking image === - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: U.S. National Product Safety Laws
Hello George, While I'm reluctant to flog a dead horse, somewhere along this discussion thread, someone was looking for a definitive statement regarding the subject at hand. After searching OSHA's Interpretation Letters I found the following letter relating OSHA's requirements and (desktop) computers. Regards, Art Michael Editor - Int'l Product Safety News * * * * * * * * * * * * * * * * * * * * * * * International Product Safety Bookshop * * Check out our current offerings! * * http://www.safetylink.com/bookshop.html * * * * Another service of the Safety Link* * www.safetylink.com * * * * * * * * * * * * * * * * * * * * * * * OSHA Banner Image Map OSHA Standards Interpretation and Compliance Letters 02/18/1992 - Electrical standards as it applies to desktop computers. _ OSHA Standard Interpretation and Compliance Letters - Table of Contents OSHA Standard Interpretation and Compliance Letters - Table of Contents _ * Record Type: Interpretation * Standard Number: 1910.303;1910.399 * Subject: Electrical standards as it applies to desktop computers. * Information Date:02/18/1992 _ February 18, 1992 William K. Blocher President BBC Computers Inc. 7 Columbia Circle Merrimack, New Hampshire 03054 Dear Mr. Blocher: Thank you for your letter of January 23, requesting clarification on the applicability of 29 CFR 1910 Subpart S, Electrical standards, to desktop computers. Desktop computers are appliances otherwise described as utilization equipment when used by employees in the workplace. By 29 CFR 1910.303(a) equipment required or permitted by 29 CFR 1910 Subpart S shall be accepted only if approved. Approved means acceptable to the authority, that is, the Assistant Secretary of Labor for Occupational Safety and Health, enforcing 29 CFR 1910 Subpart S. The definition of acceptable includes three different methods to determine acceptable equipment, and these methods are specified at 1910.399. A copy of the 1910.399 definitions, specified by quotation marks in this letter, is enclosed for your use. We appreciate your interest in occupational safety and health. If we can be of further assistance, please do not hesitate to contact us. Sincerely, Patricia K. Clark, Director Directorate of Compliance Programs Enclosure _ OSHA Standard Interpretation and Compliance Letters - Table of Contents OSHA Standard Interpretation and Compliance Letters - Table of Contents tracking image === On Thu, 19 Aug 1999 geor...@lexmark.com wrote: Tania, Thank you for your comments. Allow me to better explain my position. 1. I am well aware of the language you cited from UL1950. This has never been in question, as it is precise and understandable. Page 23? even lists many examples of products falling under the standard. 2. However, UL1950 is a standard, not a law, which was the original question initiating this discussion. I think the original inquiry asked what laws require compliance to the standards. My original point was that the laws cited, e.g.NEC and OSHA, are very poorly worded when it comes to what equipment is covered. One response was that it means any electrical equipment with a useful purpose, or words to that effect. Is there electrical equipment out there that has no useful purpose that would therefore not be covered? 3. You are correct that SELV ITE is included in UL1950. I did not mean to gloss over this. An earlier append in the discussion said that utilization equipment was anything that plugged into 120V. I was pointing out that it also applies to voltages other than 120V. The standard does allow for the certification of Class III (SELV) ITE. However, the scope limits this to mains or battery powered equipment. This excludes the many devices which may be powered at SELV voltages from an external AC adapter. That is, the adapter falls within the scope (mains powered), but not the driven device. 4. It is my opinion that the reason battery
RE: U.S. National Product Safety Laws
Tania, Thank you for your comments. Allow me to better explain my position. 1. I am well aware of the language you cited from UL1950. This has never been in question, as it is precise and understandable. Page 23? even lists many examples of products falling under the standard. 2. However, UL1950 is a standard, not a law, which was the original question initiating this discussion. I think the original inquiry asked what laws require compliance to the standards. My original point was that the laws cited, e.g.NEC and OSHA, are very poorly worded when it comes to what equipment is covered. One response was that it means any electrical equipment with a useful purpose, or words to that effect. Is there electrical equipment out there that has no useful purpose that would therefore not be covered? 3. You are correct that SELV ITE is included in UL1950. I did not mean to gloss over this. An earlier append in the discussion said that utilization equipment was anything that plugged into 120V. I was pointing out that it also applies to voltages other than 120V. The standard does allow for the certification of Class III (SELV) ITE. However, the scope limits this to mains or battery powered equipment. This excludes the many devices which may be powered at SELV voltages from an external AC adapter. That is, the adapter falls within the scope (mains powered), but not the driven device. 4. It is my opinion that the reason battery powered equipment was included is that some older products were prone to catching fire inside briefcases as a result of shorted batteries. See the CPSC website for some early laptops pulled from the market for this reason. BTW, the flashlight comments were posted by Rich, not me. Again, thank you for your comments. That is what makes this listserver an excellent sounding board. I have consistently been impressed with the caliber of questions and answers posted. Note that there is a big difference between ignorance and stupity. Ignorance can be cured. I am still ignorant in many matters, but hope I am not stupid, which has no cure. Regards, George Alspaugh To all us others, and primarily to George at Lexmark! Regarding your item 3. The NEC and OSHA requirements probably do apply to any electrical device that is operated from voltages above SELV.Take a look at the 3rd edition of UL1950 under Scope, 1.1.1: This standard is applicable to mains-powered or battery-powered information technology equipment, including electrical business equipment and associated equipment, with a rated voltage not exceeding 600 V and..Nowhere does it state that this standard applies only to equipment at SELV and above. In fact, if you go further into the standard and check out section 1.2.4.3, it describes Class III equipment (SELV supplied). Thus, any equipment, including that which operates at SELV voltages, falls under this standard. Regarding the following comment- (Obviously, OSHA ignores low-voltage and battery-operated equipment such as flashlights and calculators. I haven't located the out for these kinds of equipments.) -- I believe that flashlights and calculators are ignored because the standard addresses mains-powered or (they should have said) mains battery-powered equipment. If your equipment needs a wire to obtain power, you are covered by this standard (assuming other characteristics apply.) And yes, I do agree with your 4th item. The legalese could be more user friendly. Tania Grant, tgr...@lucent.com tgr...@lucent.com Lucent Technologies, Communications Applications Group -- From: geor...@lexmark.com [SMTP:geor...@lexmark.com] Sent: Wednesday, August 18, 1999 2:02 PM To: ri...@sdd.hp.com Cc: private_u...@lexmark.com; emc-p...@majordomo.ieee.org Subject: Re: U.S. National Product Safety Laws To Rich et al (fancy way of saying and others): I was a little reluctant to fan the embers of this discussion the other day, but do not regret doing so based on the healthy discussion that followed. In any event, I shall blame Doug's append for peaking my interest. I assume we can all agree that: 1. We do not want to market unsafe products that may cause harm. 2. No one is looking for loopholes in the safety standards. 3. The NEC and OSHA requirements probably do apply to any electrical device that is operated from voltages above SELV. 4. The NEC and OSHA requirements are worded like legal documents, and thus, far from clear in their meaning. Having said this, I have added some remarks (in brackets [ ] ) to your last note below, hoping that these do not not extend the discussion, but are my final thoughts. Best regards, George Alspaugh __ Hi George: I've read these sections of the CFR many times, and always interpreted them
RE: U.S. National Product Safety Laws
To all us others, and primarily to George at Lexmark! Regarding your item 3. The NEC and OSHA requirements probably do apply to any electrical device that is operated from voltages above SELV.Take a look at the 3rd edition of UL1950 under Scope, 1.1.1: This standard is applicable to mains-powered or battery-powered information technology equipment, including electrical business equipment and associated equipment, with a rated voltage not exceeding 600 V and..Nowhere does it state that this standard applies only to equipment at SELV and above. In fact, if you go further into the standard and check out section 1.2.4.3, it describes Class III equipment (SELV supplied). Thus, any equipment, including that which operates at SELV voltages, falls under this standard. Regarding the following comment- (Obviously, OSHA ignores low-voltage and battery-operated equipment such as flashlights and calculators. I haven't located the out for these kinds of equipments.) -- I believe that flashlights and calculators are ignored because the standard addresses mains-powered or (they should have said) mains battery-powered equipment. If your equipment needs a wire to obtain power, you are covered by this standard (assuming other characteristics apply.) And yes, I do agree with your 4th item. The legalese could be more user friendly. Tania Grant, tgr...@lucent.com tgr...@lucent.com Lucent Technologies, Communications Applications Group -- From: geor...@lexmark.com [SMTP:geor...@lexmark.com] Sent: Wednesday, August 18, 1999 2:02 PM To: ri...@sdd.hp.com Cc: private_u...@lexmark.com; emc-p...@majordomo.ieee.org Subject: Re: U.S. National Product Safety Laws To Rich et al (fancy way of saying and others): I was a little reluctant to fan the embers of this discussion the other day, but do not regret doing so based on the healthy discussion that followed. In any event, I shall blame Doug's append for peaking my interest. I assume we can all agree that: 1. We do not want to market unsafe products that may cause harm. 2. No one is looking for loopholes in the safety standards. 3. The NEC and OSHA requirements probably do apply to any electrical device that is operated from voltages above SELV. 4. The NEC and OSHA requirements are worded like legal documents, and thus, far from clear in their meaning. Having said this, I have added some remarks (in brackets [ ] ) to your last note below, hoping that these do not not extend the discussion, but are my final thoughts. Best regards, George Alspaugh __ Hi George: I've read these sections of the CFR many times, and always interpreted them to apply to end user equipment, as you imply. However, I am beginning to see that this may be somewhat like quoting the Bible out of context. The context in this section of the CFR (before and after) overwhelmingly refers to house wiring types of equipment. I don't agree that the text overwhelmingly refers to wiring (i.e., in OSHA words, utilization system). First, it would be derelict of OSHA to ignore the utilization equipment used by employees. One of the major construction site hazards was failure of insulation in portable electric tools. OSHA was the prime mover towards double-insulated electric tools! While our government often makes mistakes, they do NOT ignore utilization equipment. [I believe that there are a dozen ways utilization equipment could be better stated to clarify the intended meaning. How about any electrical equipment, devices, appliances, and other products that are connected to electrical power systems at voltages deemed to be hazardous. Note that in homes and offices there are products requiring 220V (e.g. air conditioners, dryers, heaters) in addition to those operated from 115V.] Second, the text refers to equipment and to utilization equipment, both of which are defined terms. The definitions must be substituted EVERYWHERE the words appear in the text. When I apply the definitions, I cannot conclude as you do that the text refers overwhelmingly to wiring. [I suggest if one goes to the cheapest discount store in their area, and look at the table/floor lamps offered for sale, they will find some with no NRTL markings. I will also suggest that these were NOT approved by a Federal, state, or local government authority. Are these utilization equipment? If so, how can they be offered for sale?] Is it only me, or do others have problems reading into this that it does apply to end user products such as ITE or blenders? With so many pages dedicated to describing the exact requirements for the construction of an installation to provide power to equipment, why are there no pages dedicated to describing the requirements of the equipment? IEC 60950 contains 180 pages
Re: U.S. National Product Safety Laws
To Rich et al (fancy way of saying and others): I was a little reluctant to fan the embers of this discussion the other day, but do not regret doing so based on the healthy discussion that followed. In any event, I shall blame Doug's append for peaking my interest. I assume we can all agree that: 1. We do not want to market unsafe products that may cause harm. 2. No one is looking for loopholes in the safety standards. 3. The NEC and OSHA requirements probably do apply to any electrical device that is operated from voltages above SELV. 4. The NEC and OSHA requirements are worded like legal documents, and thus, far from clear in their meaning. Having said this, I have added some remarks (in brackets [ ] ) to your last note below, hoping that these do not not extend the discussion, but are my final thoughts. Best regards, George Alspaugh __ Hi George: I've read these sections of the CFR many times, and always interpreted them to apply to end user equipment, as you imply. However, I am beginning to see that this may be somewhat like quoting the Bible out of context. The context in this section of the CFR (before and after) overwhelmingly refers to house wiring types of equipment. I don't agree that the text overwhelmingly refers to wiring (i.e., in OSHA words, utilization system). First, it would be derelict of OSHA to ignore the utilization equipment used by employees. One of the major construction site hazards was failure of insulation in portable electric tools. OSHA was the prime mover towards double-insulated electric tools! While our government often makes mistakes, they do NOT ignore utilization equipment. [I believe that there are a dozen ways utilization equipment could be better stated to clarify the intended meaning. How about any electrical equipment, devices, appliances, and other products that are connected to electrical power systems at voltages deemed to be hazardous. Note that in homes and offices there are products requiring 220V (e.g. air conditioners, dryers, heaters) in addition to those operated from 115V.] Second, the text refers to equipment and to utilization equipment, both of which are defined terms. The definitions must be substituted EVERYWHERE the words appear in the text. When I apply the definitions, I cannot conclude as you do that the text refers overwhelmingly to wiring. [I suggest if one goes to the cheapest discount store in their area, and look at the table/floor lamps offered for sale, they will find some with no NRTL markings. I will also suggest that these were NOT approved by a Federal, state, or local government authority. Are these utilization equipment? If so, how can they be offered for sale?] Is it only me, or do others have problems reading into this that it does apply to end user products such as ITE or blenders? With so many pages dedicated to describing the exact requirements for the construction of an installation to provide power to equipment, why are there no pages dedicated to describing the requirements of the equipment? IEC 60950 contains 180 pages of such requirements. The OSHA standard for electrical equipment is that it be approved. Approved means acceptable. Acceptable has three definitions, one of which is certified by an NRTL, one of which is testing to NEC provisions, and one of which is testing by the manufacturer. In this way, OSHA skirts having to publish individual product safety standards. As near as I can tell, OSHA did this overtly and after having thought it out rather extensively. OSHA realized that it could NEVER cover all electrical products with standards. Note that covered equipment (whatever that may be) can be acceptable by virtue of the proper labelling/lisitng, or simply inspected and found to be safe by one of the referenced authorities. Several have pointed out that such authorities typically require a NRTL listing/marking. If your proof is to be interpreted as you (and I) have been interpreting it, then every single electrical device sold in the U.S. would HAVE to have an NRTL marking. I know that a few years ago we were using internal PCs that bore no such markings. I will not mention the brand name here. I suspect that one could find many electrical products under $10 that do not display such markings either. Yes, ALL electrical equipment used by employees in the workplace must be approved (which means acceptable by one of the three definitions). (Obviously, OSHA ignores low-voltage and battery-operated equipment such as flashlights and calculators. I haven't located the out for these kinds of equipments.) If an OSHA inspector should find an electrical product that is not certified by an NRTL, I'm sure the employer will be notified! You can, of course, ask OSHA if the standards apply to ITE. I have no doubt of the answer. [I would
RE: U.S. National Product Safety Laws
Well, then it's resolved as far as I'm concerned. If anyone ever asks me to locate the law that requires approved equipment in a workplace, I'm going to point them to 29 CFR 1910.302(a)(1) - Covered. The provisions of 1910.302 through 1910.308 of this subpart cover electrical installations and utilization equipment installed or used within or on buildings, structures, and other premises including ... It was annoying to see the word system all over the place to include the title of the damn thing, then within one sentence the word equipment is there plain as day. Oh well, never too old to get hit upside the head ... Thanks for the discussion ... - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: U.S. National Product Safety Laws
Hi George: I've read these sections of the CFR many times, and always interpreted them to apply to end user equipment, as you imply. However, I am beginning to see that this may be somewhat like quoting the Bible out of context. The context in this section of the CFR (before and after) overwhelmingly refers to house wiring types of equipment. I don't agree that the text overwhelmingly refers to wiring (i.e., in OSHA words, utilization system). First, it would be derelict of OSHA to ignore the utilization equipment used by employees. One of the major construction site hazards was failure of insulation in portable electric tools. OSHA was the prime mover towards double-insulated electric tools! While our government often makes mistakes, they do NOT ignore utilization equipment. Second, the text refers to equipment and to utilization equiipment, both of which are defined terms. The definitions must be substituted EVERYWHERE the words appear in the text. When I apply the definitions, I cannot conclude as you do that the text refers overwhelmingly to wiring. Is it only me, or do others have problems reading into this that it does apply to end user products such as ITE or blenders? With so many pages dedicated to describing the exact requirements for the construction of an installation to provide power to equipment, why are there no pages dedicated to describing the requirements of the equipment? IEC 60950 contains 180 pages of such requirements. The OSHA standard for electrical equipment is that it be approved. Approved means acceptable. Acceptable has three definitions, one of which is certified by an NRTL, one of which is testing to NEC provisions, and one of which is testing by the manufacturer. In this way, OSHA skirts having to publish individual product safety standards. As near as I can tell, OSHA did this overtly and after having thought it out rather extensively. OSHA realized that it could NEVER cover all electrical products with standards. Note that covered equipment (whatever that may be) can be acceptable by virtue of the proper labelling/lisitng, or simply inspected and found to be safe by one of the referenced authorities. Several have pointed out that such authorities typically require a NRTL listing/marking. If your proof is to be interpreted as you (and I) have been interpreting it, then every single electrical device sold in the U.S. would HAVE to have an NRTL marking. I know that a few years ago we were using internal PCs that bore no such markings. I will not mention the brand name here. I suspect that one could find many electrical products under $10 that do not display such markings either. Yes, ALL electrical equipment used by employees in the workplace must be approved (which means acceptable by one of the three definitions). (Obviously, OSHA ignores low-voltage and battery-operated equipment such as flashlights and calculators. I haven't located the out for these kinds of equipments.) If an OSHA inspector should find an electrical product that is not certified by an NRTL, I'm sure the employer will be notified! You can, of course, ask OSHA if the standards apply to ITE. I have no doubt of the answer. Best regards, Rich - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: U.S. National Product Safety Laws
Rich, Like Doug, I've got to play the devil's advocate for a bit longer to ensure I understand this issue once the dust settles. I've read these sections of the CFR many times, and always interpreted them to apply to end user equipment, as you imply. However, I am beginning to see that this may be somewhat like quoting the Bible out of context. The context in this section of the CFR (before and after) overwhelmingly refers to house wiring types of equipment. Is it only me, or do others have problems reading into this that it does apply to end user products such as ITE or blenders? With so many pages dedicated to describing the exact requirements for the construction of an installation to provide power to equipment, why are there no pages dedicated to describing the requirements of the equipment? IEC 60950 contains 180 pages of such requirements. I assume UL 1950 is about the same number ofpages. If the sections you cite apply to ITE (or any other electrical end product), where are the equivalent 180 pages of construction requirements, including such things as leakage current and creepage/clearance distances. Note that covered equipment (whatever that may be) can be acceptable by virtue of the proper labelling/lisitng, or simply inspected and found to be safe by one of the referenced authorities. Several have pointed out that such authorities typically require a NRTL listing/marking. If your proof is to be interpreted as you (and I) have been interpreting it, then every single electrical device sold in the U.S. would HAVE to have an NRTL marking. I know that a few years ago we were using internal PCs that bore no such markings. I will not mention the brand name here. I suspect that one could find many electrical products under $10 that do not display such markings either. Regards, George Alspaugh -- Forwarded by George Alspaugh/Lex/Lexmark on 08/17/99 12:57 PM --- richn%sdd.hp@interlock.lexmark.com on 08/17/99 12:20:32 PM To: George_Alspaugh/Lex/Lexmark@LEXMARK cc: emc-pstc%majordomo.ieee@interlock.lexmark.com Subject: Re: U.S. National Product Safety Laws Hi George: So here is the challenge. Can anyone prove that 29 CFR 1900 or the NEC specifically requires ITE to meet more than some grounding/marking requirements, or be required to be approved by an NRTL. Proof is citing clearly stated sections obviously applicable to typical ITE products. Sorry, but vague references to something I once saw. are not allowed. Here is the proof you requested. Note that the wordings for approval, approved, and equipment of both OSHA and the NEC are identical! I wonder how that happened? :-) Best regards, Rich ... OSHA: = 1910.303 (a) Approval. The conductors and equipment required or permitted by this subpart shall be acceptable only if approved. 1910.399 (a) Definitions applicable to 1910.302 through 1910.330 - Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which 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 (iii) With respect to custom-made equipment or related installations which 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. Refer to 1910.7 for definition of nationally recognized testing laboratory. Approved. Acceptable to the authority enforcing this subpart. The authority enforcing this subpart is the Assistant Secretary of Labor for Occupational Safety and Health. The definition of acceptable indicates what is acceptable to the Assistant Secretary of Labor, and therefore approved within the meaning of this Subpart. Equipment. A general term including material, fittings, devices, appliances, fixtures, apparatus, and the like, used as a part of, or in connection with, an electrical installation
RE: U.S. National Product Safety Laws
Here's how a local Denver area OSHA inspector explained it to me... OSHA considers worker safety to be the responsibility of the company employing them. Electrical safety for both the facility and it's infrastructure and the equipment connecting into it's electrical system is the responsibility of the work-place. Subpart S-Electrical ref. 1910.302(a) scope: states that this section covers electrical installations and utilization equipment. ref. 1910.399 definition for utilization equipment: equipment which utilizes electric energy for mechanical, chemical, heating, lighting, or similar useful purpose. Comment: Most any equipment that plugs into a 110V outlet has useful purpose. ref. 1910.303 (a) The conductors and equipment required or permitted by this subpart shall be acceptable if approved. ref. 1910.399: Equipment is defined as, material, fittings, devices, appliances, fixtures, apparatus, and the like, used as a part of, or in connection with an electrical installation. Comment: Anything that plugs into a standard 110V outlet is in connection with an electrical installation. ref. 1910.399: Approved is defined as Acceptable to OSHA. ref. 1910.399: Accepted is defined as accepted, certified or listed by a nationally recognized testing laboratory (NRTL). In the case of purchased equipment which is not preapproved by a NRTL, said equipment may be inspected or tested on site by a NRTL, or federal, state municipal or local safety authority. In the case of equipment manufactured on site for on site uses, said equipment may deemed safe if tested or inspected by methods indicated in the previous statement or by the manufacturer. If the latter method is to be used testing must be per national safety standards and test inspection information must be kept on file, on site and made available to OSHA inspectors if called upon to do so. Although they have the authority to do so, OSHA does not routinely inspect business for compliance. They do not have the time, money or personnel to do so. OSHA will check a business for safety concern/s if there is a complaint from an employee within the organization. In the latter case the extent of the investigation is usually limited to the review of the complaint, but OSHA as always has the option to look as far as they choose into safety aspects of the business. If there is a serious injury or death as a result of a safety related concern OSHA may then look into all aspects of safety within the business. This includes not only the physical aspects of safety (which would include electrical safety hazards such as unsafe equipment), but records (e.g. training, injury, illness, etc.)as well. Gail Birdsall Compliance Engineer Hach Co. -Original Message- From: geor...@lexmark.com [mailto:geor...@lexmark.com] Sent: Tuesday, August 17, 1999 7:11 AM To: emc-p...@majordomo.ieee.org Subject: Re: U.S. National Product Safety Laws This discussion is opening more issues than it is closing. No one can merely skim through 29 CFR 1900 or the NEC and find what they are looking for, so I may have missed what I was looking for given the time that I had. Like Doug, I cannot find a single definitive statement, or combination thereof, that would require an appliance, in this case a PC or peripheral, to meet any requirement other earth gounding and/or double insulation. Likewise with the NEC. Section 645 addresses ITE. A good deal is said about the installation for ITE, but little about the actual ITE equipment itself. Items that ARE mentioned include that all exposed noncurrent-carrying metal parts of an ITE system must be grounded or double insulated (645-15), and that a marking of rated voltages etc. must be affixed (645-16). So here is the challenge. Can anyone prove that 29 CFR 1900 or the NEC specifically requires ITE to meet more than some grounding/marking requirements, or be required to be approved by an NRTL. Proof is citing clearly stated sections obviously applicable to typical ITE products. Sorry, but vague references to something I once saw. are not allowed. Like many product safety professionals, I received much verbal input on the known requirements when I took this position. It is becoming more obvious that some facts passed down through generations of PSEs may not be entirely accurate. They are definitely not clear, or this discussion would not be taking place. BTW, I would like the phone number of any lawyer capable of providing definitive answers. -- Forwarded by George Alspaugh/Lex/Lexmark on 08/17/99 08:47 AM --- roger.viles%wwgsolutions@interlock.lexmark.com on 08/17/99 05:03:28 AM Please respond to roger.viles%wwgsolutions@interlock.lexmark.com To: dmckean%corp.auspex@interlock.lexmark.com cc: emc-pstc%majordomo.ieee@interlock.lexmark.com Subject: Re: U.S. National Product Safety Laws Doug, I agree entirely! Yesterday I sent the below mail
RE: U.S. National Product Safety Laws
Has anyone reviewed Jon Curtis' work in the June 1999 issue of Conformity? Its title is OSHA's Electrical Standards, What it Covers and What it Doesn't. It is a very complete assessment of the laws pertaining to this subject. Anton (Tony) J. Nikolassy Project Engineer, Electrical Section Factory Mutual Research Corp. Ph: 781-255-4819 Fx: 781-762-9375 e-mail: anton.nikola...@factory-mutual.com -Original Message- From: geor...@lexmark.com [mailto:geor...@lexmark.com] Sent: Tuesday, August 17, 1999 8:11 AM To: emc-p...@majordomo.ieee.org Subject: Re: U.S. National Product Safety Laws This discussion is opening more issues than it is closing. No one can merely skim through 29 CFR 1900 or the NEC and find what they are looking for, so I may have missed what I was looking for given the time that I had. Like Doug, I cannot find a single definitive statement, or combination thereof, that would require an appliance, in this case a PC or peripheral, to meet any requirement other earth gounding and/or double insulation. Likewise with the NEC. Section 645 addresses ITE. A good deal is said about the installation for ITE, but little about the actual ITE equipment itself. Items that ARE mentioned include that all exposed noncurrent-carrying metal parts of an ITE system must be grounded or double insulated (645-15), and that a marking of rated voltages etc. must be affixed (645-16). So here is the challenge. Can anyone prove that 29 CFR 1900 or the NEC specifically requires ITE to meet more than some grounding/marking requirements, or be required to be approved by an NRTL. Proof is citing clearly stated sections obviously applicable to typical ITE products. Sorry, but vague references to something I once saw. are not allowed. Like many product safety professionals, I received much verbal input on the known requirements when I took this position. It is becoming more obvious that some facts passed down through generations of PSEs may not be entirely accurate. They are definitely not clear, or this discussion would not be taking place. BTW, I would like the phone number of any lawyer capable of providing definitive answers. -- Forwarded by George Alspaugh/Lex/Lexmark on 08/17/99 08:47 AM --- roger.viles%wwgsolutions@interlock.lexmark.com on 08/17/99 05:03:28 AM Please respond to roger.viles%wwgsolutions@interlock.lexmark.com To: dmckean%corp.auspex@interlock.lexmark.com cc: emc-pstc%majordomo.ieee@interlock.lexmark.com Subject: Re: U.S. National Product Safety Laws Doug, I agree entirely! Yesterday I sent the below mail to a fellow emc-pstc groupie: I have struggled through the OSHA webpages before, including SubPart S: SubPart Title: Electrical - Design Safety Standards for Electrical Systems where it does clearly say: Approval. The conductors and equipment required or permitted by this subpart shall be acceptable only if approved. Under definitions, approved refers to acceptable which is defined as: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory So it is quite clear that conductors and equipment for electrical systems must be listed or similar. However nowhere does it make clear what is covered under equipment. Is a PC covered? Probably yes. Is a palmtop with mains adaptor covered? Maybe. Is a pocket calculator covered? Surely not. So I too would like a definitive answer! (Well, if the answer is definitive, it probably comes from a lawyer, so I might not like it!). Regards, Roger Viles WWG Doug McKean dmck...@corp.auspex.com on 17/08/99 04:48:09 Please respond to Doug McKean dmck...@corp.auspex.com To: emc-p...@majordomo.ieee.org cc:(bcc: Roger Viles/PLY/Global) Subject: Re: U.S. National Product Safety Laws Dear Fellow Professionals, Let me be the devil's advocate for the moment. I normally do not like to pick apart standards, but this one has been kicking around my mind for years. I will refer all to the following websites so we're all on the same playing field. http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc.html http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910_SUBPART_S.html Would you please note that in 29 CFR 1910.301 Introduction, that the practical safeguarding of employees in their workplaces has four parts to it: ... a) Electrical systems. b) Safety-realted work practices. c) Safety-related maintenance requirements. d) Safety requirements for special equipment. ... Of the four major divisions for safeguarding employees, please note the first one - Electrical Systems. As stated in 29 CFR - 1910.399 Definitions, a system is defined as Utilization system. A utilization system is a system which provides electric power and light for employee workplaces, and includes the premises wiring system and utilization equipment. Had the standard used the word
Re: U.S. National Product Safety Laws
Hi George: So here is the challenge. Can anyone prove that 29 CFR 1900 or the NEC specifically requires ITE to meet more than some grounding/marking requirements, or be required to be approved by an NRTL. Proof is citing clearly stated sections obviously applicable to typical ITE products. Sorry, but vague references to something I once saw. are not allowed. Here is the proof you requested. Note that the wordings for approval, approved, and equipment of both OSHA and the NEC are identical! I wonder how that happened? :-) Best regards, Rich ... OSHA: = 1910.303 (a) Approval. The conductors and equipment required or permitted by this subpart shall be acceptable only if approved. 1910.399 (a) Definitions applicable to 1910.302 through 1910.330 - Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which 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 (iii) With respect to custom-made equipment or related installations which 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. Refer to 1910.7 for definition of nationally recognized testing laboratory. Approved. Acceptable to the authority enforcing this subpart. The authority enforcing this subpart is the Assistant Secretary of Labor for Occupational Safety and Health. The definition of acceptable indicates what is acceptable to the Assistant Secretary of Labor, and therefore approved within the meaning of this Subpart. Equipment. A general term including material, fittings, devices, appliances, fixtures, apparatus, and the like, used as a part of, or in connection with, an electrical installation. ... NEC: 110.Requirements for Electrical Installations. 110-2. Approval. The conductors and equipment required by this Code shall be acceptable only if approved. (FPN): See Examination of Equipment for Safety, Section 90-7, and Examination Identification, INstallation, and Use of Equipment, Section 110-3. See definitions of Approved, Identified, Labeled, and Listed. 100.Definitions. Approved: Acceptable to the authority having jurisdiction. Equipment: A general term including material, fittings, devices, appliances, fixtures, apparatus, and the like used as part of, or in connection with, an electrical installation. ... - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: U.S. National Product Safety Laws
This discussion is opening more issues than it is closing. No one can merely skim through 29 CFR 1900 or the NEC and find what they are looking for, so I may have missed what I was looking for given the time that I had. Like Doug, I cannot find a single definitive statement, or combination thereof, that would require an appliance, in this case a PC or peripheral, to meet any requirement other earth gounding and/or double insulation. Likewise with the NEC. Section 645 addresses ITE. A good deal is said about the installation for ITE, but little about the actual ITE equipment itself. Items that ARE mentioned include that all exposed noncurrent-carrying metal parts of an ITE system must be grounded or double insulated (645-15), and that a marking of rated voltages etc. must be affixed (645-16). So here is the challenge. Can anyone prove that 29 CFR 1900 or the NEC specifically requires ITE to meet more than some grounding/marking requirements, or be required to be approved by an NRTL. Proof is citing clearly stated sections obviously applicable to typical ITE products. Sorry, but vague references to something I once saw. are not allowed. Like many product safety professionals, I received much verbal input on the known requirements when I took this position. It is becoming more obvious that some facts passed down through generations of PSEs may not be entirely accurate. They are definitely not clear, or this discussion would not be taking place. BTW, I would like the phone number of any lawyer capable of providing definitive answers. -- Forwarded by George Alspaugh/Lex/Lexmark on 08/17/99 08:47 AM --- roger.viles%wwgsolutions@interlock.lexmark.com on 08/17/99 05:03:28 AM Please respond to roger.viles%wwgsolutions@interlock.lexmark.com To: dmckean%corp.auspex@interlock.lexmark.com cc: emc-pstc%majordomo.ieee@interlock.lexmark.com Subject: Re: U.S. National Product Safety Laws Doug, I agree entirely! Yesterday I sent the below mail to a fellow emc-pstc groupie: I have struggled through the OSHA webpages before, including SubPart S: SubPart Title: Electrical - Design Safety Standards for Electrical Systems where it does clearly say: Approval. The conductors and equipment required or permitted by this subpart shall be acceptable only if approved. Under definitions, approved refers to acceptable which is defined as: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory So it is quite clear that conductors and equipment for electrical systems must be listed or similar. However nowhere does it make clear what is covered under equipment. Is a PC covered? Probably yes. Is a palmtop with mains adaptor covered? Maybe. Is a pocket calculator covered? Surely not. So I too would like a definitive answer! (Well, if the answer is definitive, it probably comes from a lawyer, so I might not like it!). Regards, Roger Viles WWG Doug McKean dmck...@corp.auspex.com on 17/08/99 04:48:09 Please respond to Doug McKean dmck...@corp.auspex.com To: emc-p...@majordomo.ieee.org cc:(bcc: Roger Viles/PLY/Global) Subject: Re: U.S. National Product Safety Laws Dear Fellow Professionals, Let me be the devil's advocate for the moment. I normally do not like to pick apart standards, but this one has been kicking around my mind for years. I will refer all to the following websites so we're all on the same playing field. http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc.html http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910_SUBPART_S.html Would you please note that in 29 CFR 1910.301 Introduction, that the practical safeguarding of employees in their workplaces has four parts to it: ... a) Electrical systems. b) Safety-realted work practices. c) Safety-related maintenance requirements. d) Safety requirements for special equipment. ... Of the four major divisions for safeguarding employees, please note the first one - Electrical Systems. As stated in 29 CFR - 1910.399 Definitions, a system is defined as Utilization system. A utilization system is a system which provides electric power and light for employee workplaces, and includes the premises wiring system and utilization equipment. Had the standard used the word equipment, then as such 29 CFR - 1910.399 Definitions would have used the following definition Utilization equipment. Utilization equipment means equipment which utilizes electric energy for mechanical, chemical, heating, lighting, or similar useful purpose. Therefore, people, I submit that since 29 CFR 1910 directs it's attention to systems, it is strictly concerned with that which provides electrical power or lighting and does NOT concern itself with equipment, i.e. that utiliizes said power. Comments? Regards, Doug McKean - This message is coming from the emc-pstc discussion list
Re: U.S. National Product Safety Laws
Doug, I agree entirely! Yesterday I sent the below mail to a fellow emc-pstc groupie: I have struggled through the OSHA webpages before, including SubPart S: SubPart Title: Electrical - Design Safety Standards for Electrical Systems where it does clearly say: Approval. The conductors and equipment required or permitted by this subpart shall be acceptable only if approved. Under definitions, approved refers to acceptable which is defined as: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory So it is quite clear that conductors and equipment for electrical systems must be listed or similar. However nowhere does it make clear what is covered under equipment. Is a PC covered? Probably yes. Is a palmtop with mains adaptor covered? Maybe. Is a pocket calculator covered? Surely not. So I too would like a definitive answer! (Well, if the answer is definitive, it probably comes from a lawyer, so I might not like it!). Regards, Roger Viles WWG Doug McKean dmck...@corp.auspex.com on 17/08/99 04:48:09 Please respond to Doug McKean dmck...@corp.auspex.com To: emc-p...@majordomo.ieee.org cc:(bcc: Roger Viles/PLY/Global) Subject: Re: U.S. National Product Safety Laws Dear Fellow Professionals, Let me be the devil's advocate for the moment. I normally do not like to pick apart standards, but this one has been kicking around my mind for years. I will refer all to the following websites so we're all on the same playing field. http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc.html http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910_SUBPART_S.html Would you please note that in 29 CFR 1910.301 Introduction, that the practical safeguarding of employees in their workplaces has four parts to it: ... a) Electrical systems. b) Safety-realted work practices. c) Safety-related maintenance requirements. d) Safety requirements for special equipment. ... Of the four major divisions for safeguarding employees, please note the first one - Electrical Systems. As stated in 29 CFR - 1910.399 Definitions, a system is defined as Utilization system. A utilization system is a system which provides electric power and light for employee workplaces, and includes the premises wiring system and utilization equipment. Had the standard used the word equipment, then as such 29 CFR - 1910.399 Definitions would have used the following definition Utilization equipment. Utilization equipment means equipment which utilizes electric energy for mechanical, chemical, heating, lighting, or similar useful purpose. Therefore, people, I submit that since 29 CFR 1910 directs it's attention to systems, it is strictly concerned with that which provides electrical power or lighting and does NOT concern itself with equipment, i.e. that utiliizes said power. Comments? Regards, Doug McKean - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: U.S. National Product Safety Laws
Dear Fellow Professionals, Let me be the devil's advocate for the moment. I normally do not like to pick apart standards, but this one has been kicking around my mind for years. I will refer all to the following websites so we're all on the same playing field. http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc.html http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910_SUBPART_S.html Would you please note that in 29 CFR 1910.301 Introduction, that the practical safeguarding of employees in their workplaces has four parts to it: ... a) Electrical systems. b) Safety-realted work practices. c) Safety-related maintenance requirements. d) Safety requirements for special equipment. ... Of the four major divisions for safeguarding employees, please note the first one - Electrical Systems. As stated in 29 CFR - 1910.399 Definitions, a system is defined as Utilization system. A utilization system is a system which provides electric power and light for employee workplaces, and includes the premises wiring system and utilization equipment. Had the standard used the word equipment, then as such 29 CFR - 1910.399 Definitions would have used the following definition Utilization equipment. Utilization equipment means equipment which utilizes electric energy for mechanical, chemical, heating, lighting, or similar useful purpose. Therefore, people, I submit that since 29 CFR 1910 directs it's attention to systems, it is strictly concerned with that which provides electrical power or lighting and does NOT concern itself with equipment, i.e. that utiliizes said power. Comments? Regards, Doug McKean - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: U.S. National Product Safety Laws
George, To add to your statements;--- It is not just cities that may require NRTL marking on equipment, but also the insurance carriers of the various businesses where the equipment is installed. In many cities the Fire Department inspects for NRTL markings on business premises; they don't normally do this in homes. Also, the city codes may include (and usually do) equipment installed in business locations, not just for the home consumer. After all they might be held liable for poor plumbing and electrical installations, and they don't want to be held liable. Tania Grant, tgr...@lucent.com tgr...@lucent.com Lucent Technologies, Communications Applications Group -- From: geor...@lexmark.com [SMTP:geor...@lexmark.com] Sent: Monday, August 16, 1999 2:07 PM To: emc-p...@majordomo.ieee.org Subject: U.S. National Product Safety Laws Here is my understanding of this issue relative to ITE. I post this both to inform, and solicit comments which could improve my understanding. The only U.S. Federal law I am aware of pertaining to product safety is that covered in 29 CFR 1900 (the OSHA section). Electrical equipment to be used in the U.S. workplace must either (1) comply with a detailed list of construction requirements, or (2) be accepted, certified, listed, labelled, or otherwise determined to be safe by a nationally recognized testing laboratory [29 CFR 1900.399 (a) (ii)]. There are seventeen OSHA approved NRTLs, half of which can test to UL 1950. Summary: For workplace ITE, an NRTL certification is the easiest option. Note that this is an option, not the only path. Note also that UL and other NRTLs are private companies, not U.S. government agencies. What about non-workplace ITE for consumers? These are outside the OSHA requirements. Some of the major cities in the U.S. (e.g. New York, Los Angeles, Chicago) have local electrical codes that include the electrical requirements for household eletrical equipment. However, these are usually in the absence of any NRTL listing, which is generally acceptable. Summary: Again, an NRTL certification is the easiest path to market home electrical products in all parts of the U.S. One CAN find electrical products on the market that bear no agency markings that are being sold in ways that do not conform to OSHA requirements or city electrical codes. However, these tend to be very cheap low end products like Christmas lighting, extension cords, etc. The Consumer Products Safety Commission (CPSC) is a Federal agency. It does not establish product safety requirements. However, its mission is to identify and remove from the marketplace any products found prone to expose hazards. It is an after-the-fact enforcement agency that can apply pressure for a a product recall. Moral: A manufacturer can either negotiate the mine field of specific OSHA (for workplace) or city (for home use) electrical requirements, or go with an NRTL certification. George Alspaugh Corporate Product Safety Lexmark International Inc. - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: U.S. National Product Safety Laws
On Mon, 16 Aug 1999 geor...@lexmark.com wrote: Here is my understanding of this issue relative to ITE. I post this both to inform, and solicit comments which could improve my understanding. The only U.S. Federal law I am aware of pertaining to product safety is that covered in 29 CFR 1900 (the OSHA section). Electrical equipment to be used in the U.S. workplace must either (1) comply with a detailed list of construction requirements, or (2) be accepted, certified, listed, labelled, or otherwise determined to be safe by a nationally recognized testing laboratory [29 CFR 1900.399 (a) (ii)]. There are seventeen OSHA approved NRTLs, half of which can test to UL 1950. For what it's worth, not related to workplace safety, but related to product safety, see also 16 CFR. Section 1500 covers a broad ground, section 1505 covers electrical toys, section 1512 covers bicycles. If you have any wonder whether we are subjects in a nanny state, see the banned list at section 1500.18. Regards, Chuck - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: U.S. National Product Safety Laws
Hi George: Just a clarification and amplification or your message... There are TWO laws that govern product safety: 1) OSHA. Your remarks thoroughly covered this law. 2) The National Electrical Code. This is a model building code intended for adoption by local building code jurisdictions. The NEC includes the requirement that all appliances must be listed. It leaves to the jurisdiction to determine what constitutes listed and how to enforce it. All jurisdictions have an electrical code. Most adopt the NEC. A few write their own, e.g., Los Angeles, Chicago. Jurisdictions adopting electrical codes include the following governmental entities: - cities, e.g., Los Angeles, Chicago. - counties, e.g., San Mateo. - states, e.g., Washington, Oregon. These codes apply to new constructions and to alterations to exisiting constructions. Enforcement is by the electrical inspection of the installation. (Obviously, cord-connected appliances installed AFTER completion of the building electrical installation are not inspected for the listed mark.) At one time, the State of Oregon employed two inspectors who inspected electrical appliances and construction materials offered for sale in retail stores. If an appliance is found without a suitable mark, then the store is ordered by the State Electrical Board to remove the products from their shelves. The City of Los Angeles inspects appliances offered for sale at commercial shows. Any offered appliance without a NRTL mark is identified and a letter is sent to the manufacturer warning the manufacturer that any such product sold in Los Angeles must have a suitable certification mark. For all practical purposes, NRTL certification satisfies both the workplace law and the building code laws. Best regards, Rich - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
