RE: NRTL in the U.S.

2003-01-15 Thread gr...@test4safety.com

Hi Rich,


I argue with some of your statements.  :-)
Thanks - at least I know that I'm alive and not dreaming!

   Dave's question - Does this apply to in-house test equipment?

   Hi Dave -  Good question (Please see attached). I'm sorry about the file
   size but I took it from the Department of Labor web site several years
ago
   when this topic first came up. (It repeats about every 6 months if my
memory
   serves)

I believe Dave's question was in regard to compliance
to local electrical codes, not to OSHA requirements.
Yes - but that is not the full story - and it would be easy to misapply a
YES-NO answer to a similar (but inappropriate) situation.


Local electrical codes (e.g., NEC) require all
electrical equipment that comprises an electrical
installation to be approved for the purpose.
This is taken to mean listed or otherwise certified
for safety.  Codes are enforced by local inspectors
and by licensed electricians who perform the
installation.

Department of Labor (OSHA) regulations require that
the electrical equipment used by employees be
certified for safety by an NRTL.  Regulations are
enforced by the employer as well as by periodically
by inspectors from OSHA.

While these two sets of rules are independent of
each other, one solution satisfies both rules:
listing.

As Albert Camus wrote (in The Plague)  The difference was slight - and the
result the same.

Perhaps someone can comment about FIRE and ELECTRIC SHOCK reports on
non-Listed versus LISTED products.


   However - the BEST and MOST RELEVANT people to ask are your Corporate
   Insurers.

   It would be little good meeting the local code to find that there is
small
   print in your corporate liability insurance leaves you with personal
   liability for any failure - injury or death!!!

   Even if you can avoid NRTL testing then you need to protect yourself -
NOT
   YOUR COMPANY - (people go to jail - companies don't).

As a general rule, employees cannot be held
personally liable if they are doing work in
accordance with direction from the employer.
IF THEY CAN PROVE IT!
I'm sure that no 'employer' would say I employed him as a professional - I
expected him to act accordingly - Had I known the outcome I would never
have instructed him to or even I did not - it is our policy to
comply with ALL legislation - he obviously made a mistake - let him prove
otherwise.

But, today's focus on profits motivates many
insurers to creatively find a way to prevent
payment of claims or to recover the loss from
some other source.
Gee - I can't imagine that ever happening

However, recovering from
the likes of you and me would not come close
to covering the loss.  There are bigger fish
and deeper pockets.
OK - but suppose it did - how long would it be before legal costs bankrupted
you? - Maybe that are others that do not share you optimism.

What about Joint and Several actions - if I wanted to bring a successful
action I would attack the designer - BECAUSE  I know that his funds would be
exhausted quickly AND that after disposing of him/her I would have the case
proven (will minimal cost) and then go to find the deep pockets.


   Try to think of 'compliance' not as PASS or  FAIL; but as a continuum
from
   DEPLORABLE  through ACCEPTABLE  to the UNATTAINABLE.

These abstractions, DEPLORABLE, ACCEPTABLE, and
UNATTAINABLE, are difficult to use because they
are not very measurable.  PASS and FAIL at least
provide a line by which to discriminate between
acceptable and unacceptable.
Correct - the word I used to describe them was CONTINUUM that is not
measurable either.

I was trying to set sights higher than Our product PASSED  - where PASSED
equals look-at-that   it passed! - pheeeweee


We, at HP and Agilent, use a three-block model
to evaluate safety:

   +-++-++-+
   |hazardous|| || |
   |energy   |---|safeguard|---|   body  |
   |source   || || |
   +-++-++-+

We say that, for every hazardous energy source,
there must be one or more safeguards interposed
between the source and the body.

The safeguard has a number of parameters that
must be controlled such that the safeguard
remains effective for the equipment lifetime.

If we do a thorough job, then we have a safe
product -- unless the safeguard is subjected
to influences greater than the design level.

This is a practical, powerful, and measurable
model for safety.
I agree - I use a similar model and do a forward and backward pass. The
problem with all these models and reviews is that if we cannot prove safety.

The best we can hope for is that our assessments fail to prove a hazard. So
if we are good at finding hazards we are better safety engineers than
someone that cannot find any.

Best regards

Gregg



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Re: NRTL in the U.S.

2003-01-15 Thread Rich Nute




Hi Gregg:


I argue with some of your statements.  :-)

   Dave's question - Does this apply to in-house test equipment?
   
   Hi Dave -  Good question (Please see attached). I'm sorry about the file
   size but I took it from the Department of Labor web site several years ago
   when this topic first came up. (It repeats about every 6 months if my
memory
   serves)

I believe Dave's question was in regard to compliance
to local electrical codes, not to OSHA requirements.

Local electrical codes (e.g., NEC) require all 
electrical equipment that comprises an electrical 
installation to be approved for the purpose.
This is taken to mean listed or otherwise certified
for safety.  Codes are enforced by local inspectors
and by licensed electricians who perform the 
installation.

Department of Labor (OSHA) regulations require that
the electrical equipment used by employees be 
certified for safety by an NRTL.  Regulations are
enforced by the employer as well as by periodically
by inspectors from OSHA.

While these two sets of rules are independent of 
each other, one solution satisfies both rules:
listing.

   However - the BEST and MOST RELEVANT people to ask are your Corporate
   Insurers.
   
   It would be little good meeting the local code to find that there is small
   print in your corporate liability insurance leaves you with personal
   liability for any failure - injury or death!!!

   Even if you can avoid NRTL testing then you need to protect yourself - NOT
   YOUR COMPANY - (people go to jail - companies don't).

As a general rule, employees cannot be held 
personally liable if they are doing work in 
accordance with direction from the employer.

But, today's focus on profits motivates many
insurers to creatively find a way to prevent
payment of claims or to recover the loss from
some other source.  However, recovering from
the likes of you and me would not come close
to covering the loss.  There are bigger fish
and deeper pockets.

   Try to think of 'compliance' not as PASS or  FAIL; but as a continuum from
   DEPLORABLE  through ACCEPTABLE  to the UNATTAINABLE.

These abstractions, DEPLORABLE, ACCEPTABLE, and
UNATTAINABLE, are difficult to use because they 
are not very measurable.  PASS and FAIL at least 
provide a line by which to discriminate between 
acceptable and unacceptable.

We, at HP and Agilent, use a three-block model 
to evaluate safety:  

   +-++-++-+
   |hazardous|| || |
   |energy   |---|safeguard|---|   body  |
   |source   || || |
   +-++-++-+

We say that, for every hazardous energy source,
there must be one or more safeguards interposed
between the source and the body.

The safeguard has a number of parameters that
must be controlled such that the safeguard
remains effective for the equipment lifetime.

If we do a thorough job, then we have a safe
product -- unless the safeguard is subjected
to influences greater than the design level.

This is a practical, powerful, and measurable 
model for safety.


Best regards,
Rich




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Re: NRTL in the U.S.

2003-01-15 Thread Rich Nute




Hi Gary:


   Rich Nute (I think) wrote and excellent article or e-mail on this not 
 too
long ago and should be in the archives. Its pretty concise and clear but goes
into some pretty good specifics and the state laws and how they very and you
will find it very helpful.

Unfortunately, the archives are not available at
this time due to our web site transition from 
Akiva to Community Zero.

We hope to have the archives available in another
month or so.


Best regards,
Rich






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RE: NRTL in the U.S.

2003-01-15 Thread Ronald R. Wellman

Hello Sam,

Chances are if you are ever involved in a product liability law suit in the 
United States that the jury will look at you very unfavorably if your 
product is not NRTL Listed. Also, expect that the NRTL will not help defend 
you in a law suit even if your product is Listed with them. A Catch 22.

BTW, enforcement of law should never be a condition of compliance. Market 
surveillance does happen. Just because you have not been caught does not 
mean that the law is not being enforced. However, this really depends on 
the integrity of your company and its management, and whether they are 
willing to except risk of liability. Makes you wonder why we have whistle 
blowers.

Best regards,
Ron Wellman

At 05:48 PM 1/14/2003 -0600, Sam Davis wrote:

Another interpretation of the question may be Where is the NRTL requirement
strictly enforced?  (which is a much larger list than where it is
required.)  Where can you get away without a NRTL mark?  That depends in
part on the product, the market, and the distribution scheme.

Which brings this to mind- Is a law a law if it is not enforced?  (Many
politically controversial issues come to mind here.)

I have had many clients who actually want to waive tests based on the
argument We've been selling these for years, and have had no complaints
yet.  It is not uncommon to be able to sell laboratory equipment, with a CE
mark only, all over the US.  Even some medical equipment (which truly
surprised me).

Basically, if the client (or reseller) doesn't care, and the electrical
inspector doesn't see it, it can be sold and used without a NRTL mark.

The same logic can be used in illicit drug trafficking as well.  (If I don't
get caught, I'm not breaking the law).

I am not suggesting that any product to be sold in the US not be NRTL'ed,
but just expressing another viewpoint.  Besides the fact that my employer
makes money when we sell a NRTL job, my risk vs reward mindset tells me the
cash saved now (a few $k - not much reward) ain't worth the potential
injuries, deaths, and lawsuits (where the risk amount depends on your
company's assets).

NRTL it, and the question is moot.

Sam




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RE: NRTL in the U.S.

2003-01-15 Thread Garry Hojan

Good point Sam,

There is one other point on the whole to NRTL, or not scenario.

The more visibility a company attains in the marketplace, the more their
competition looks for a weakness in the competing product's armor.

Best case scenario: Your product is compliant, but is not listed, your
competitor will use ours has been independently tested and listed by a
Nationally Recognized Testing Laboratory for safety, theirs hasn't against
you every time while in front of the customer.

(some of you will say that this doesn't guarantee safety, and you are 100%
correct. But it makes no difference once the customer hears this, especially
for the well trained sales rep who uses this to their full advantage.)

Worst case scenario: Your product is not compliant, competitor reports the
non compliant product, so to level the playing field because they have spent
the additional funds on compliance, which puts the non compliant competitor
at an unfair advantage.

There are other side disasters for a non compliant company that's found out
through competitor whistle blowing. I won't go into them, but they all cost
money, large.

Garry Hojan
Strategic Compliance Services
www.regulatory-compliance.com


From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Sam Davis
Sent: Tuesday, January 14, 2003 3:49 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: NRTL in the U.S.



Another interpretation of the question may be Where is the NRTL requirement
strictly enforced?  (which is a much larger list than where it is
required.)  Where can you get away without a NRTL mark?  That depends in
part on the product, the market, and the distribution scheme.

Which brings this to mind- Is a law a law if it is not enforced?  (Many
politically controversial issues come to mind here.)

I have had many clients who actually want to waive tests based on the
argument We've been selling these for years, and have had no complaints
yet.  It is not uncommon to be able to sell laboratory equipment, with a CE
mark only, all over the US.  Even some medical equipment (which truly
surprised me).

Basically, if the client (or reseller) doesn't care, and the electrical
inspector doesn't see it, it can be sold and used without a NRTL mark.

The same logic can be used in illicit drug trafficking as well.  (If I don't
get caught, I'm not breaking the law).

I am not suggesting that any product to be sold in the US not be NRTL'ed,
but just expressing another viewpoint.  Besides the fact that my employer
makes money when we sell a NRTL job, my risk vs reward mindset tells me the
cash saved now (a few $k - not much reward) ain't worth the potential
injuries, deaths, and lawsuits (where the risk amount depends on your
company's assets).

NRTL it, and the question is moot.

Sam



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RE: NRTL in the U.S.

2003-01-14 Thread Sam Davis

Another interpretation of the question may be Where is the NRTL requirement
strictly enforced?  (which is a much larger list than where it is
required.)  Where can you get away without a NRTL mark?  That depends in
part on the product, the market, and the distribution scheme.

Which brings this to mind- Is a law a law if it is not enforced?  (Many
politically controversial issues come to mind here.)

I have had many clients who actually want to waive tests based on the
argument We've been selling these for years, and have had no complaints
yet.  It is not uncommon to be able to sell laboratory equipment, with a CE
mark only, all over the US.  Even some medical equipment (which truly
surprised me).

Basically, if the client (or reseller) doesn't care, and the electrical
inspector doesn't see it, it can be sold and used without a NRTL mark.

The same logic can be used in illicit drug trafficking as well.  (If I don't
get caught, I'm not breaking the law).

I am not suggesting that any product to be sold in the US not be NRTL'ed,
but just expressing another viewpoint.  Besides the fact that my employer
makes money when we sell a NRTL job, my risk vs reward mindset tells me the
cash saved now (a few $k - not much reward) ain't worth the potential
injuries, deaths, and lawsuits (where the risk amount depends on your
company's assets).

NRTL it, and the question is moot.

Sam



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RE: NRTL in the U.S.

2003-01-14 Thread Ronald R. Wellman

Hello Peter,

This is probably true when an electrician is involved in a product 
installation. However, the majority of products that we are dealing with do 
not require an electrician to install. They are either installed by the 
Customer or a representative of the product manufacturer. The acceptance of 
liability in using a Non-Listed product is no different in accepting the 
liability of using a Listed one because being NRTL Listed doesn't always 
mean your product is safe. Just take a look at all the products that are 
being recalled by the Consumer Product Safety Commission (CPSC) that are 
NRTL Listed.

Best regards,
Ron Wellman

At 03:06 PM 1/14/2003 -0500, peter.a.manfredo...@us.ul.com wrote:


The truth is that an independent licensed electrician will not connect a
product that is not Listed.

  In commercial or industrial environments, there may be a Licensed
Professional Engineer on staff, who can approve a product but he takes the
personal liability for Non-Listed products.


Manfredonia




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Re: NRTL in the U.S.

2003-01-14 Thread Rich Nute




Hi Dave:


   Does this apply to in-house test equipment? That is, equipment that is
built
   in-house and remains on site? In the past I have designed in-house
equipment
   to meet the safety standards but did not send the equipment out for testing
   and certification.

Yes.

If you check with your local electrical code inspectors
(or, if you have one, your in-house electrician ), you 
will find that custom-built equipment used in your
factory or site must meet the electrical code, which 
means it must be certified for safety.

Many of the certification houses offer on-site 
investigations of such equipment.  UL has a standard
(I don't recall the number) for such equipment.  Upon
successful completion of the investigation, the cert
house will put a sticker on the equipment, and the 
electrical code inspector will accept the equipment.

(Such certification also protects your employer against 
violation of OSHA rules.)


Best regards,
Rich





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RE: NRTL in the U.S.

2003-01-14 Thread gr...@test4safety.com
This is a multi-part message in MIME format.
Dave's question - Does this apply to in-house test equipment?

Hi Dave -  Good question (Please see attached). I'm sorry about the file
size but I took it from the Department of Labor web site several years ago
when this topic first came up. (It repeats about every 6 months if my memory
serves)

Beware of defining the situation incorrectly.

Between RD - Prototyping - Manufacturing - customer site.

As you change location the to NRTL or not to NRTL conditions may change -
so .

FIRST - THINK IT THROUGH VERY CAREFULLY - short term - long term. Document
your CONDITIONS of acceptable USE






However - the BEST and MOST RELEVANT people to ask are your Corporate
Insurers.

It would be little good meeting the local code to find that there is small
print in your corporate liability insurance leaves you with personal
liability for any failure - injury or death!!!








NEXT - is it legal? - If 'yes' then.


 - ASK WHY AM I DOING THIS?
If you answer  legal requirements then think again.

If you answer  to reduce liability then think again

If the answer is to prevent injury, etc then consider what if things go
wrong - what protection do you would have in law.



I thought it was OK  is not good.

I was only doing my job or  I'm not paid to do that  are worst

Will there be any evidence (maybe even years after you have left the
company) you made any assessment?

Will there be any record of any changes to 'your' design?





Even if you can avoid NRTL testing then you need to protect yourself - NOT
YOUR COMPANY - (people go to jail - companies don't).


You would be most wise to create a UL-Style Product Description AND UL style
test Report so that you have some sort of evidence of due diligence AND A
CONFIGURATION RECORD OF WHAT YOU TESTED.

It have seen too many modifications that have made products
d-a-n-g-e-r-o-u-s.



Whereas I believe that there is may be no single one right answer to your
question there will be, I am sure, plenty of wrong ones. Hopefully those
will not be posted here!!!





STEP OUTSIDE THE BOX

Try to think of 'compliance' not as PASS or  FAIL; but as a continuum from
DEPLORABLE  through ACCEPTABLE  to the UNATTAINABLE.


Whereas there is a basic legal need to reach ACCEPTABLE there is a
commercial need (6-sigma - zero-defect - fault-free : call it what you will)
that strives for better things. (Which is just as well because the standards
have become stricter and will continue to do so.)


My company has clients at all points along that continuum and work with them
to progress their knowledge and to show them how they can reduce their
personal and corporate risks.

Before someone shoots COSTS at me - please let me add - we find that the
cost (of training and implementation) is more than offset by cost saving
that result from the compliance improvement exercise.

There are free downloads under the eLearning section of our web site -
please help yourself.


Best regards

Gregg

Gregg Kervill DipIM, MIMgt, MIEEE
VP Engineering
Test4Safety.com Inc
PO Box 310,
Reedville, VA
22539. USA
Phone  ( 804) 453-3141
Fax(804) 453-9039
http://www.test4safety.com/

From: drcuthbert [mailto:drcuthb...@micron.com]
Sent: Tuesday, January 14, 2003 12:53 PM
To: 'Gregg Kervill'; 'Joe P Martin'; emc-p...@majordomo.ieee.org
Subject: RE: NRTL in the U.S.

Does this apply to in-house test equipment? That is, equipment that is built
in-house and remains on site? In the past I have designed in-house equipment
to meet the safety standards but did not send the equipment out for testing
and certification.

   Dave


From: Gregg Kervill [mailto:gr...@test4safety.com]
Sent: Tuesday, January 14, 2003 7:50 AM
To: 'Joe P Martin'; emc-p...@majordomo.ieee.org
Subject: RE: NRTL in the U.S.
Importance: High



Joe,

You are correct that NRTL LISTING is a specified requirement by some cities
and states.

You are incorrect in that all products used where OSHA applies are required
to be NRTL LISTED.

NEC Code makes that same requirement

Furthermore most (I have yet to find an exception) cities and states base
their code upon NEC


There may be local exception but I believe that to make a 'blanket statement
that .. NRTL is not required in the US... is I believe at best confusing
and at that the worst very dangerous.

The following is a statement from the US NOL:

All electrical equipment, except those kinds which no NRTL accepts,
certifies,
lists, labels, or otherwise determines to be safe, must be approved, as
that term
is defined at 29 CFR 1910.399. Except as indicated in the following this
means
that a NRTL must accept, certify, label, list, or otherwise determine that
equipment is safe for it to be considered approved.

The requirement mandating that electrical equipment be approved is set
forth at
29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that
approved equipment be used in conformance with its approval.

Electrical equipment

RE: NRTL in the U.S.

2003-01-14 Thread Gary McInturff

Rich Nute (I think) wrote and excellent article or e-mail on this not 
too
long ago and should be in the archives. Its pretty concise and clear but goes
into some pretty good specifics and the state laws and how they very and you
will find it very helpful.
Rich if it wasn't you sorry but you better get writing!
Gary


From: Ronald R. Wellman [mailto:rwell...@wellman.com]
Sent: Tuesday, January 14, 2003 8:53 AM
To: peter.a.manfredo...@us.ul.com; Joe P Martin
Cc: emc-p...@majordomo.ieee.org; owner-emc-p...@majordomo.ieee.org
Subject: Re: NRTL in the U.S.



Hello Peter,

Those of us who have had to list products in the United States already know 
this. What is required by law versus what is a customer requirement are two 
different things. NRTL listing is a Customer requirement as viewed from a 
product manufacturer. However, there are some cities, states, and counties, 
that require NRTL listing by law.

To answer Martin's question, I believe it is Cook County, Illinois and just 
the City (not county) of Los Angeles that require NRTL listing. I also 
remember that the State of Oregon requires NRTL listing as well as some 
counties in Florida.

Best regards,
Ron Wellman

At 08:37 AM 1/14/2003 -0500, peter.a.manfredo...@us.ul.com wrote:



Local municipalities throughout the U.S.  adopt the National Electrical
code NFPA 70 as a way to assure consistent administration and enforcement
of a standardized electrical code.   The Code provides that wiring and
installed electrical equipment ...Need not be inspected at the
time of installation of the equipment, except to detect  alterations or
damage, if the equipment  has been LISTED by a qualified  electrical
testing laboratory




  Manfredonia



 

 Joe P 
 Martin 

 MartinJP@appliedbiosys   To: 
 emc-p...@majordomo.ieee.org
 tems.com cc: 

 Sent by:  Subject: NRTL in 
 the U.S.
 owner-emc-pstc@majordom 

 o.ieee.org 

 

 

 01/13/2003 11:22 
 PM 

 Please respond to 
 Joe 

 P 
 Martin 

 

 






Greetings,

As has been discussed in previous threads, NRTL Listing is not a
requirement to sell electronic products in the U.S.  However, there are
cities, counties, etc. within the U.S. that do require NRTL Listing.
These include Los Angeles and Chicago.  Does anyone have a comprehensive
list of all the cities, counties or states that do require NRTL Listing.

Any and all comments are appreciated.

Regards

Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com



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RE: NRTL in the U.S.

2003-01-14 Thread Ronald R. Wellman

Hello Gregg,

Martin is correct that NRTL Listing is not a requirement to sell 
electronic products in the U.S. Product usage is something entirely 
different and may require compliance under OSHA regulations.

Best regards,
Ron Wellman

At 09:50 AM 1/14/2003 -0500, Gregg Kervill wrote:

Joe,

You are correct that NRTL LISTING is a specified requirement by some cities
and states.

You are incorrect in that all products used where OSHA applies are required
to be NRTL LISTED.

NEC Code makes that same requirement

Furthermore most (I have yet to find an exception) cities and states base
their code upon NEC


There may be local exception but I believe that to make a 'blanket statement
that .. NRTL is not required in the US... is I believe at best confusing
and at that the worst very dangerous.

The following is a statement from the US NOL:

All electrical equipment, except those kinds which no NRTL accepts,
certifies,
lists, labels, or otherwise determines to be safe, must be approved, as
that term
is defined at 29 CFR 1910.399. Except as indicated in the following this
means
that a NRTL must accept, certify, label, list, or otherwise determine that
equipment is safe for it to be considered approved.

The requirement mandating that electrical equipment be approved is set
forth at
29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that
approved equipment be used in conformance with its approval.

Electrical equipment which no NRTL accepts, certifies, lists, labels, or
determines to be safe is acceptable to OSHA under the following if the
equipment 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 NEC and found in compliance with the provisions of the NEC
as
applied to Subpart S of 29 CFR 1910 standards.

Custom made equipment which is designed, fabricated for, and intended for
use
by a particular customer does not have to be approved if it is determined to
be
safe for its intended use by its manufacturer. The determination must be
made
on the basis of test data that the employer keeps and makes available to the
Assistant Secretary of Labor for OSHA.

In summary then if there are ten different models of a particular kind of
equipment, but only one of them is accepted, certified, listed, labeled or
otherwise determined to be safe by a NRTL only that one would be considered
to
be approved; unless of course it is custom made equipment.

Only those entities that have applied and been approved pursuant to the
requirements of 29 CFR 1910.7 are considered to be a NRTL. Recently the
Canadian Standards Association was the first foreign laboratory approved
as
an NRTL. Enclosed find a copy of a directive that discusses NRTLs.


Best regards

Gregg Kervill

Gregg Kervill DipIM, MIMgt, MIEEE
VP Engineering
Test4Safety.com Inc
PO Box 310,
Reedville, VA
22539. USA
Phone  ( 804) 453-3141
Fax(804) 453-9039
http://www.test4safety.com/

-Original Message-
From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Joe P Martin
Sent: Monday, January 13, 2003 11:22 PM
To: emc-p...@majordomo.ieee.org
Subject: NRTL in the U.S.


Greetings,

As has been discussed in previous threads, NRTL Listing is not a
requirement to sell electronic products in the U.S.  However, there are
cities, counties, etc. within the U.S. that do require NRTL Listing.
These include Los Angeles and Chicago.  Does anyone have a comprehensive
list of all the cities, counties or states that do require NRTL Listing.

Any and all comments are appreciated.

Regards

Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com



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RE: NRTL in the U.S.

2003-01-14 Thread richwo...@tycoint.com

Add Orange County California, City of San Francisco, states of Maryland
(consumer products only as I recall), North Carolina and Washington.

Richard Woods
Sensormatic Electronics
Tyco International



From: Brian Epstein [mailto:brian.epst...@veeco.com]
Sent: Tuesday, January 14, 2003 2:36 PM
To: 'Ronald R. Wellman'; peter.a.manfredo...@us.ul.com; Joe P Martin
Cc: emc-p...@majordomo.ieee.org; owner-emc-p...@majordomo.ieee.org
Subject: RE: NRTL in the U.S.



Add Santa Clara County and the Commonwealth of Virginia to that list.

Brian Epstein
Sr Regulatory Compliance Engineer
Veeco Instruments


From: Ronald R. Wellman [mailto:rwell...@wellman.com]
Sent: Tuesday, January 14, 2003 8:53 AM
To: peter.a.manfredo...@us.ul.com; Joe P Martin
Cc: emc-p...@majordomo.ieee.org; owner-emc-p...@majordomo.ieee.org
Subject: Re: NRTL in the U.S.



Hello Peter,

Those of us who have had to list products in the United States already know 
this. What is required by law versus what is a customer requirement are two 
different things. NRTL listing is a Customer requirement as viewed from a 
product manufacturer. However, there are some cities, states, and counties, 
that require NRTL listing by law.

To answer Martin's question, I believe it is Cook County, Illinois and just 
the City (not county) of Los Angeles that require NRTL listing. I also 
remember that the State of Oregon requires NRTL listing as well as some 
counties in Florida.

Best regards,
Ron Wellman

At 08:37 AM 1/14/2003 -0500, peter.a.manfredo...@us.ul.com wrote:



Local municipalities throughout the U.S.  adopt the National Electrical
code NFPA 70 as a way to assure consistent administration and enforcement
of a standardized electrical code.   The Code provides that wiring and
installed electrical equipment ...Need not be inspected at the
time of installation of the equipment, except to detect  alterations or
damage, if the equipment  has been LISTED by a qualified  electrical
testing laboratory




  Manfredonia



 

 Joe P 
 Martin 

 MartinJP@appliedbiosys   To: 
 emc-p...@majordomo.ieee.org
 tems.com cc: 

 Sent by:  Subject: NRTL in 
 the U.S.
 owner-emc-pstc@majordom 

 o.ieee.org 

 

 

 01/13/2003 11:22 
 PM 

 Please respond to 
 Joe 

 P 
 Martin 

 

 






Greetings,

As has been discussed in previous threads, NRTL Listing is not a
requirement to sell electronic products in the U.S.  However, there are
cities, counties, etc. within the U.S. that do require NRTL Listing.
These include Los Angeles and Chicago.  Does anyone have a comprehensive
list of all the cities, counties or states that do require NRTL Listing.

Any and all comments are appreciated.

Regards

Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com



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  Richard Nute:   ri...@ieee.org
  Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
 http://ieeepstc.mindcruiser.com/
 Click on browse and then emc-pstc mailing list






-- For more information about UL, its Marks, and its services for
EMC, quality registrations and product certifications for global
markets, please access our web sites at http://www.ul.com and
http://www.ulc.ca, or contact your local sales representative. --

*  Internet E-mail Confidentiality Disclaimer  **

This e-mail message may contain privileged or confidential
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disclose, use, disseminate, distribute, copy or rely upon this
message or attachment in any way.  If you received this e-mail
message in error, please return by forwarding the message and
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Underwriters Laboratories Inc. and its affiliates do
not accept liability for any errors, omissions, corruption
or virus in the contents of this message or any attachments that
arise as a result of e-mail transmission.
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RE: NRTL in the U.S.

2003-01-14 Thread peter.a.manfredo...@us.ul.com



The truth is that an independent licensed electrician will not connect a
product that is not Listed.

 In commercial or industrial environments, there may be a Licensed
Professional Engineer on staff, who can approve a product but he takes the
personal liability for Non-Listed products.


Manfredonia




-- For more information about UL, its Marks, and its services for
EMC, quality registrations and product certifications for global
markets, please access our web sites at http://www.ul.com and
http://www.ulc.ca, or contact your local sales representative. --

*  Internet E-mail Confidentiality Disclaimer  **

This e-mail message may contain privileged or confidential
information.  If you are not the intended recipient, you may not
disclose, use, disseminate, distribute, copy or rely upon this
message or attachment in any way.  If you received this e-mail
message in error, please return by forwarding the message and
its attachments to the sender.

Underwriters Laboratories Inc. and its affiliates do
not accept liability for any errors, omissions, corruption
or virus in the contents of this message or any attachments that
arise as a result of e-mail transmission.
*



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Re: NRTL in the U.S.

2003-01-14 Thread Rich Nute




Hi Joe:


   As has been discussed in previous threads, NRTL Listing is not a
   requirement to sell electronic products in the U.S.  However, there are
   cities, counties, etc. within the U.S. that do require NRTL Listing.
   These include Los Angeles and Chicago.  Does anyone have a comprehensive
   list of all the cities, counties or states that do require NRTL Listing.

The list would be very much shorter if the
list contained those cities or counties that
do NOT require safety certification.

(I would venture to say there are none.)

You could probably get such a list from UL
or CSA or MET or ETL other safety 
certification house that has applied for and 
been accepted in those jurisdictions.  Just 
ask for a list of states, counties, and cities 
where their mark is accepted.

Personally, I know of no city, county, or
state that does not require safety certification
(listing) of electrical products.

Your mention of cities, counties, and states 
implies the local electrical code requirements 
(usually the NEC).   

NRTL is a concept of the Occupational 
Safety and Health Adminstration (OSHA).  OSHA 
is a federal government entity that addresses 
workplace safety, not local electrical codes.  
NRTL certification of an electrical product
used in the workplace satisfies an employer's
requirement (under OSHA) to supply a safe 
electrical device for use by employees.

There is no connection between local electrical
codes and NRTL.  But, we know what you mean!
:-)  


Best regards,
Rich





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RE: NRTL in the U.S.

2003-01-14 Thread drcuthbert

Does this apply to in-house test equipment? That is, equipment that is built
in-house and remains on site? In the past I have designed in-house equipment
to meet the safety standards but did not send the equipment out for testing
and certification.

   Dave


From: Gregg Kervill [mailto:gr...@test4safety.com]
Sent: Tuesday, January 14, 2003 7:50 AM
To: 'Joe P Martin'; emc-p...@majordomo.ieee.org
Subject: RE: NRTL in the U.S.
Importance: High



Joe,

You are correct that NRTL LISTING is a specified requirement by some cities
and states.

You are incorrect in that all products used where OSHA applies are required
to be NRTL LISTED.

NEC Code makes that same requirement

Furthermore most (I have yet to find an exception) cities and states base
their code upon NEC


There may be local exception but I believe that to make a 'blanket statement
that .. NRTL is not required in the US... is I believe at best confusing
and at that the worst very dangerous.

The following is a statement from the US NOL:

All electrical equipment, except those kinds which no NRTL accepts,
certifies,
lists, labels, or otherwise determines to be safe, must be approved, as
that term
is defined at 29 CFR 1910.399. Except as indicated in the following this
means
that a NRTL must accept, certify, label, list, or otherwise determine that
equipment is safe for it to be considered approved.

The requirement mandating that electrical equipment be approved is set
forth at
29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that
approved equipment be used in conformance with its approval.

Electrical equipment which no NRTL accepts, certifies, lists, labels, or
determines to be safe is acceptable to OSHA under the following if the
equipment 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 NEC and found in compliance with the provisions of the NEC
as
applied to Subpart S of 29 CFR 1910 standards.

Custom made equipment which is designed, fabricated for, and intended for
use
by a particular customer does not have to be approved if it is determined to
be
safe for its intended use by its manufacturer. The determination must be
made
on the basis of test data that the employer keeps and makes available to the
Assistant Secretary of Labor for OSHA.

In summary then if there are ten different models of a particular kind of
equipment, but only one of them is accepted, certified, listed, labeled or
otherwise determined to be safe by a NRTL only that one would be considered
to
be approved; unless of course it is custom made equipment.

Only those entities that have applied and been approved pursuant to the
requirements of 29 CFR 1910.7 are considered to be a NRTL. Recently the
Canadian Standards Association was the first foreign laboratory approved
as
an NRTL. Enclosed find a copy of a directive that discusses NRTLs.


Best regards

Gregg Kervill

Gregg Kervill DipIM, MIMgt, MIEEE
VP Engineering
Test4Safety.com Inc
PO Box 310,
Reedville, VA
22539. USA
Phone  ( 804) 453-3141
Fax(804) 453-9039
http://www.test4safety.com/


From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Joe P Martin
Sent: Monday, January 13, 2003 11:22 PM
To: emc-p...@majordomo.ieee.org
Subject: NRTL in the U.S.


Greetings,

As has been discussed in previous threads, NRTL Listing is not a
requirement to sell electronic products in the U.S.  However, there are
cities, counties, etc. within the U.S. that do require NRTL Listing.
These include Los Angeles and Chicago.  Does anyone have a comprehensive
list of all the cities, counties or states that do require NRTL Listing.

Any and all comments are appreciated.

Regards

Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com




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 Jim Bacher: j.bac...@ieee.org

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 Dave Heald

Re: NRTL in the U.S.

2003-01-14 Thread Ronald R. Wellman

Hello Peter,

Those of us who have had to list products in the United States already know 
this. What is required by law versus what is a customer requirement are two 
different things. NRTL listing is a Customer requirement as viewed from a 
product manufacturer. However, there are some cities, states, and counties, 
that require NRTL listing by law.

To answer Martin's question, I believe it is Cook County, Illinois and just 
the City (not county) of Los Angeles that require NRTL listing. I also 
remember that the State of Oregon requires NRTL listing as well as some 
counties in Florida.

Best regards,
Ron Wellman

At 08:37 AM 1/14/2003 -0500, peter.a.manfredo...@us.ul.com wrote:



Local municipalities throughout the U.S.  adopt the National Electrical
code NFPA 70 as a way to assure consistent administration and enforcement
of a standardized electrical code.   The Code provides that wiring and
installed electrical equipment ...Need not be inspected at the
time of installation of the equipment, except to detect  alterations or
damage, if the equipment  has been LISTED by a qualified  electrical
testing laboratory




  Manfredonia



 

 Joe P 
 Martin 

 MartinJP@appliedbiosys   To: 
 emc-p...@majordomo.ieee.org
 tems.com cc: 

 Sent by:  Subject: NRTL in 
 the U.S.
 owner-emc-pstc@majordom 

 o.ieee.org 

 

 

 01/13/2003 11:22 
 PM 

 Please respond to 
 Joe 

 P 
 Martin 

 

 






Greetings,

As has been discussed in previous threads, NRTL Listing is not a
requirement to sell electronic products in the U.S.  However, there are
cities, counties, etc. within the U.S. that do require NRTL Listing.
These include Los Angeles and Chicago.  Does anyone have a comprehensive
list of all the cities, counties or states that do require NRTL Listing.

Any and all comments are appreciated.

Regards

Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com



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  Richard Nute:   ri...@ieee.org
  Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
 http://ieeepstc.mindcruiser.com/
 Click on browse and then emc-pstc mailing list






-- For more information about UL, its Marks, and its services for
EMC, quality registrations and product certifications for global
markets, please access our web sites at http://www.ul.com and
http://www.ulc.ca, or contact your local sales representative. --

*  Internet E-mail Confidentiality Disclaimer  **

This e-mail message may contain privileged or confidential
information.  If you are not the intended recipient, you may not
disclose, use, disseminate, distribute, copy or rely upon this
message or attachment in any way.  If you received this e-mail
message in error, please return by forwarding the message and
its attachments to the sender.

Underwriters Laboratories Inc. and its affiliates do
not accept liability for any errors, omissions, corruption
or virus in the contents of this message or any attachments that
arise as a result of e-mail transmission.
*


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RE: NRTL in the U.S.

2003-01-14 Thread Gregg Kervill

Joe,

You are correct that NRTL LISTING is a specified requirement by some cities
and states.

You are incorrect in that all products used where OSHA applies are required
to be NRTL LISTED.

NEC Code makes that same requirement

Furthermore most (I have yet to find an exception) cities and states base
their code upon NEC


There may be local exception but I believe that to make a 'blanket statement
that .. NRTL is not required in the US... is I believe at best confusing
and at that the worst very dangerous.

The following is a statement from the US NOL:

All electrical equipment, except those kinds which no NRTL accepts,
certifies,
lists, labels, or otherwise determines to be safe, must be approved, as
that term
is defined at 29 CFR 1910.399. Except as indicated in the following this
means
that a NRTL must accept, certify, label, list, or otherwise determine that
equipment is safe for it to be considered approved.

The requirement mandating that electrical equipment be approved is set
forth at
29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that
approved equipment be used in conformance with its approval.

Electrical equipment which no NRTL accepts, certifies, lists, labels, or
determines to be safe is acceptable to OSHA under the following if the
equipment 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 NEC and found in compliance with the provisions of the NEC
as
applied to Subpart S of 29 CFR 1910 standards.

Custom made equipment which is designed, fabricated for, and intended for
use
by a particular customer does not have to be approved if it is determined to
be
safe for its intended use by its manufacturer. The determination must be
made
on the basis of test data that the employer keeps and makes available to the
Assistant Secretary of Labor for OSHA.

In summary then if there are ten different models of a particular kind of
equipment, but only one of them is accepted, certified, listed, labeled or
otherwise determined to be safe by a NRTL only that one would be considered
to
be approved; unless of course it is custom made equipment.

Only those entities that have applied and been approved pursuant to the
requirements of 29 CFR 1910.7 are considered to be a NRTL. Recently the
Canadian Standards Association was the first foreign laboratory approved
as
an NRTL. Enclosed find a copy of a directive that discusses NRTLs.


Best regards

Gregg Kervill

Gregg Kervill DipIM, MIMgt, MIEEE
VP Engineering
Test4Safety.com Inc
PO Box 310,
Reedville, VA
22539. USA
Phone  ( 804) 453-3141
Fax(804) 453-9039
http://www.test4safety.com/


From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Joe P Martin
Sent: Monday, January 13, 2003 11:22 PM
To: emc-p...@majordomo.ieee.org
Subject: NRTL in the U.S.


Greetings,

As has been discussed in previous threads, NRTL Listing is not a
requirement to sell electronic products in the U.S.  However, there are
cities, counties, etc. within the U.S. that do require NRTL Listing.
These include Los Angeles and Chicago.  Does anyone have a comprehensive
list of all the cities, counties or states that do require NRTL Listing.

Any and all comments are appreciated.

Regards

Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com




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Re: NRTL in the U.S.

2003-01-14 Thread peter.a.manfredo...@us.ul.com



Local municipalities throughout the U.S.  adopt the National Electrical
code NFPA 70 as a way to assure consistent administration and enforcement
of a standardized electrical code.   The Code provides that wiring and
installed electrical equipment ...Need not be inspected at the
time of installation of the equipment, except to detect  alterations or
damage, if the equipment  has been LISTED by a qualified  electrical
testing laboratory




 Manfredonia



  
 
Joe P Martin
 
MartinJP@appliedbiosys   To:
emc-p...@majordomo.ieee.org   
tems.com cc: 
 
Sent by:  Subject: NRTL in the
U.S. 
owner-emc-pstc@majordom   
 
o.ieee.org
 
  
 
  
 
01/13/2003 11:22 PM   
 
Please respond to Joe
 
P Martin 
 
  
 
  
 





Greetings,

As has been discussed in previous threads, NRTL Listing is not a
requirement to sell electronic products in the U.S.  However, there are
cities, counties, etc. within the U.S. that do require NRTL Listing.
These include Los Angeles and Chicago.  Does anyone have a comprehensive
list of all the cities, counties or states that do require NRTL Listing.

Any and all comments are appreciated.

Regards

Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com




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