Re: [PSES] NRTL approval

[Pete Perkins]

Ian,The common issues as to whether or not it needs a 3rd party
safety approval is well argued outside of this email.  

By using a harmonized safety standard you will be able to have the Euro CE
and North American NRTL evaluation all done at once and easily show needed
compliance while protecting your company from liability by meeting these
requirements.   The CB Report and CB Certificate will also provide the basis
for getting approvals in countries which are involved in the IECEEE scheme =
same technical requirements but different registration requirements. 

   Further, the USB requirements from 60950 have been
incorporated into a new standard 62368-3 (by ACOS directive) which is
intended to provide requirements to prevent hazards from being propagated
between equipments when using communications cables to power equipment since
the available power levels in these cables is increasing toward 100W.

   More food for thought.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

  p.perk...@ieee.org

 

From: McBurney, Ian  
Sent: Tuesday, November 13, 2018 1:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] NRTL approval

 

Dear colleagues.

 

We are in the process of designing a USB bus powered audio product around
2.5W for professional/consumer use.

The product enclosure will be UL94 5VA flammability rated plastic.

Will this product have to be NRTL approved for sale in the USA/Canada?

The EU LVD doesn't apply because of the supply voltage is only 5V DC. The
GPSD probably will!

 

Many thanks in advance.

 

Ian McBurney

Lead Compliance Engineer.

 

Allen & Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com  

 

 

Allen & Heath Ltd is a registered business in England and Wales, Company
number: 4163451. Any views expressed in this email are those of the
individual and not necessarily those of the company. 

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Re: [PSES] NRTL approval

[Richard Nute]

 

Hi Ian:

 

In the USA (and, presumably Canada), because the supply voltage is 5 volts
dc, and the power is limited to about 15 watts, I believe the unit is exempt
from NRTL certification.  I have a number of USB powered products (e.g.,
keyboard, mouse, DVD, memory sticks, etc.), some of which are
NRTL-certified, some are not.  Clearly, NRTL is not required.

 

However, questions about the missing NRTL certification may arise that may
cause specific sales to stumble.  To avoid this, I would recommend NRTL
certification.  

 

Because the unit is USB-powered, there are no safety requirements that would
be applied to the unit (not even the 5VA plastic).  NRTL certification is
paperwork, with minimum testing, if any (probably an input test).  Your unit
would bear the certification mark which would avoid any questions.  And
power input markings.

 

There is some controversy whether the unit is subject to the LVD.  To avoid
such controversy, I suggest getting a CB report.  Most NRTLs can also issue
a CB report (for very little extra cost) which would back up a CE mark.  The
CE mark would qualify the unit for Europe.  

 

And, don't ignore the FCC and RED requirements and markings.

 

Good luck and best regards,

Rich 

 

 

 

From: McBurney, Ian  
Sent: Tuesday, November 13, 2018 1:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] NRTL approval

 

Dear colleagues.

 

We are in the process of designing a USB bus powered audio product around
2.5W for professional/consumer use.

The product enclosure will be UL94 5VA flammability rated plastic.

Will this product have to be NRTL approved for sale in the USA/Canada?

The EU LVD doesn't apply because of the supply voltage is only 5V DC. The
GPSD probably will!

 

Many thanks in advance.

 

Ian McBurney

Lead Compliance Engineer.

 


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Re: [PSES] NRTL approval

[Ted Eckert]

As far as I am aware, the lower voltage limit will not be removed from the Low 
Voltage 
Directive.
 That being said, a significant fraction of products include Bluetooth, Wi-Fi 
or other radios, thereby placing them under the Radio Equipment Directive 
(RED). The RED requires products to comply with the essential requirements of 
the Low Voltage Directive and the RED does so without the lower voltage limit. 
If Ian McBurney's product does not include any radios, I believe that he is 
entirely correct that the Low Voltage Directive does not apply and the General 
Product Safety Directive would apply for safety.

The OSHA question is a bit more complicated. OSHA's requirements are not 
mandatory for a product to be sold in the United States. They are mandatory for 
most businesses in the U.S. and the requirement apply to the products used by 
those businesses. Most electrical codes in the U.S. also require electrical 
products to either be Listed or they need to be deemed acceptable by the 
Authority Having Jurisdiction (AHJ).

For residential applications, the AHJ will typically only review products that 
are field wired and/or attached to building structure. Plug connected products 
are not likely to be reviewed by the AHJ because they are not likely to be 
present at the time of inspection. There is also the consideration that 
insurance companies may include requirements for NRTL 
Listing for plug-connected products, and 
these insurance companies may use this as justification for rejecting a claim 
if a non-certified product is determined to be the cause of an incident. 
However, I personally have never run into a case where either an AHJ or 
insurance company enforced this requirement for USB powered devices.

Although the OSHA mandate for businesses can be read broadly, I have also never 
heard of either an OSHA inspector or a corporate purchasing policy that 
required NRTL Listing on USB powered devices. I'm sure you could find a USB 
powered device that is NRTL Listed, but It has been a long time since I have 
seen NRTL certification for a thumb drive, USB dongle or other USB device. You 
may find NRTL Listing on USB mice and keyboards, but this may be for other 
reasons. If a manufacturer is selling a UL Listed computer, and the manufacture 
includes a USB mouse and keyboard in the retail package, UL would likely 
require that mouse and keyboard to be UL Listed Accessories. This, however, is 
UL's requirement that all accessories shipped with a UL Listed product must 
also meet UL requirements. It is not necessarily based on OSHA or electrical 
codes.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer, the European Commission, OSHA, the Department of Labor or the 
International Association of Electrical Inspectors.

From: Joe Randolph 
Sent: Tuesday, November 13, 2018 5:12 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] NRTL approval

Hi Ian:
I have a vague recollection that the lower voltage limit either has been, or 
will be, withdrawn in the EU.  The change may be specifically related to the 
use of EN 62368-1, but I can't recall where I saw it.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com
http://www.randolph-telecom.com

From: McBurney, Ian [mailto:ian.mcbur...@allen-heath.com]
Sent: Tuesday, November 13, 2018 4:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] NRTL approval

Dear colleagues.

We are in the process of designing a USB bus powered audio product around 2.5W 
for professional/consumer use.
The product enclosure will be UL94 5VA flammability rated plastic.
Will this product have to be NRTL approved for sale in the USA/Canada?
The EU LVD doesn't apply because of the supply voltage is only 5V DC. The GPSD 
probably will!

Many thanks in advance.

Ian McBurney
Lead Compliance Engineer.

Allen & Heath Ltd.
Kernick Industrial Estate,
Penryn, Cornwall. TR10 9LU. UK
T: 01326 372070
E: ian.mcbur...@allen-heath.com


Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company.
-


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

Re: [PSES] NRTL approval

[John Woodgate]

There is a lot that is off-beam, I'm afraid. See my notes below.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-11-13 17:54, Matthew Wilson wrote:


Yes an interesting point is that ‘consumer’ use invokes the GPSD and 
could start to fall in to scope of "BS EN 60335-1:2012+A13:2017 
Household and similar electrical appliances. Safety. General 
requirements" which has no ‘safe low voltage limit in it’ even though 
this is a LVD harmonised standard.


JMW: The product described does not fall under 60335 but under 62368-1. 
60065 is in its twilight years and should not be looked at for new 
products. The absence of a low voltage limit in any of these standards 
is because some battery and other low-voltage products have enough 
energy to cause a fire, even though there is no electric shock hazard.


USB power is limited, but the power limits are different for the 
different generations, and there may be even higher-power generations in 
the future.


Although the LVD does not apply to the 'audio product' in regards CE 
marking because of the USB nominal 5V input the general product safety 
directive (GPSD) does, as you point out.


So what to use in regards due diligence against that GPSD directive?

JMW: It would be prudent to check that nothing disastrous happens in 
fault conditions no matter which version of USB is supplying the power.


Lurking in the scope of 60335-1 is, " This European Standard deals 
with the safety of electrical appliances for household environment and 
commercial purposes, their rated voltage being not more than 250 V for 
single-phase and 480 V for others. NOTE 1 Battery-operated appliances 
and other d.c. supplied appliances are within the scope of this 
standard.".


Ah ha, this scope contradicts the LVD supply voltage. So could be 
applicable to GPSD?


For the audio product EN 60335’s scope goes on to exclude ‘audio, 
video and similar electronic apparatus’ in its wording, pointing to 
IEC 60065.


So EN 60065 or maybe the newer EN 62368-1 and its hazard based class 1 
energy source etc are more relevant for the audio product in the 
original post below.



JMW: See above. It's on the way out. The future is 62368-1.


EN 60065 is in the harmonised list for GPSD so why would this not be 
applied?



JMW: See above.


 It’s scope says, “This International Safety Standard applies to 
electronic apparatus designed to be fed from the MAINS, from a SUPPLY 
APPARATUS, from batteries or from REMOTE POWER FEEDING and intended 
for reception, generation, recording or reproduction respectively of 
audio, video and associated signals. It also applies to apparatus 
designed to be used exclusively in combination with the 
above-mentioned apparatus. This standard primarily concerns apparatus 
intended for household and similar general use but which may also be 
used in places of public assembly such as schools, theatres, places of 
worship and the workplace. PROFESSIONAL APPARATUS intended for use as 
described above is also covered unless falling specifically within the 
scope of other standards.”


So, the scope of the standards extends beyond that of the LVD ‘limits’ 
to include a nominal 5V D.C. USB powered item. Therefore be careful 
anyone thinking these ‘LVD’ standards can be ignored and aren’t 
applicable to USB powered ‘consumer’ items where the GPSD applies – 
they do.


Anyway just a quirk we found when dealing with a ‘consumer’ household 
item recently. Consumer end users – try and avoid them I would!  :-)



JMW: I would advise looking immediately at conforming to 62368-1, not 60065.


Matthew Wilson,

Technical Director,

GB Electronics (UK) Ltd.




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Re: [PSES] NRTL approval

[Matthew Wilson]

Yes an interesting point is that ‘consumer’ use invokes the GPSD and could 
start to fall in to scope of "BS EN 60335-1:2012+A13:2017 Household and similar 
electrical appliances. Safety. General requirements" which has no ‘safe low 
voltage limit in it’ even though this is a LVD harmonised standard.  Although 
the LVD does not apply to the 'audio product' in regards CE marking because of 
the USB nominal 5V input the general product safety directive (GPSD) does, as 
you point out.

So what to use in regards due diligence against that GPSD directive?

Lurking in the scope of 60335-1 is, " This European Standard deals with the 
safety of electrical appliances for household environment and commercial 
purposes, their rated voltage being not more than 250 V for single-phase and 
480 V for others. NOTE 1 Battery-operated appliances and other d.c. supplied 
appliances are within the scope of this standard.".

Ah ha, this scope contradicts the LVD supply voltage. So could be applicable to 
GPSD?

For the audio product EN 60335’s scope goes on to exclude ‘audio, video and 
similar electronic apparatus’ in its wording, pointing to IEC 60065.

So EN 60065 or maybe the newer EN 62368-1 and its hazard based class 1 energy 
source etc are more relevant for the audio product in the original post below.

EN 60065 is in the harmonised list for GPSD so why would this not be applied?  
It’s scope says, “This International Safety Standard applies to electronic 
apparatus designed to be fed from the MAINS, from a SUPPLY APPARATUS, from 
batteries or from REMOTE POWER FEEDING and intended for reception, generation, 
recording or reproduction respectively of audio, video and associated signals. 
It also applies to apparatus designed to be used exclusively in combination 
with the above-mentioned apparatus. This standard primarily concerns apparatus 
intended for household and similar general use but which may also be used in 
places of public assembly such as schools, theatres, places of worship and the 
workplace. PROFESSIONAL APPARATUS intended for use as described above is also 
covered unless falling specifically within the scope of other standards.”

So, the scope of the standards extends beyond that of the LVD ‘limits’ to 
include a nominal 5V D.C. USB powered item. Therefore be careful anyone 
thinking these ‘LVD’ standards can be ignored and aren’t applicable to USB 
powered ‘consumer’ items where the GPSD applies – they do.

Anyway just a quirk we found when dealing with a ‘consumer’ household item 
recently.  Consumer end users – try and avoid them I would!  :-)

Matthew Wilson,
Technical Director,
GB Electronics (UK) Ltd.

From: McBurney, Ian 
Sent: 13 November 2018 09:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] NRTL approval

Dear colleagues.

We are in the process of designing a USB bus powered audio product around 2.5W 
for professional/consumer use.
The product enclosure will be UL94 5VA flammability rated plastic.
Will this product have to be NRTL approved for sale in the USA/Canada?
The EU LVD doesn’t apply because of the supply voltage is only 5V DC. The GPSD 
probably will!

Many thanks in advance.

Ian McBurney
Lead Compliance Engineer.

Allen & Heath Ltd.
Kernick Industrial Estate,
Penryn, Cornwall. TR10 9LU. UK
T: 01326 372070
E: ian.mcbur...@allen-heath.com


Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company.
-


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Matthew Wilson
Technical Director


[GBE]
https://gbelectronics.uk


T: +44 (0)1903 244500
F: +44 (0)1903 700715


Ascot House // Mulberry Close // Woods Way
Goring-by-Sea // West Sussex // BN12 4QY // UK



Electronics Design // Manufacturing // Component Distribution
[ISO 9001 | ISO 14001] 

Want to send us a file? 

Re: [PSES] NRTL approval

[Campling, Robert]

Hi Ian,

Also my own words, (but shamefully stolen from our website):


OSHA safety standards are part of US law and specify requirements for 
"approval" (i.e., testing and certification) of certain products by a 
Nationally Recognized Testing Laboratory (NRTL). The original intent of these 
requirements was the safety of workers, but market forces and fear of 
litigation have moved safety certification into the mainstream for all 
electrical devices used or sold in the US.
The OSHA Product Catalog can be found here: 
http://www.osha.gov/dts/otpca/nrtl/prodcatg.html
Beyond mandatory approval of products used in the US workplace, NRTL approval 
is "market driven", meaning that any electrical device that will be sold or 
distributed in the US may need an NRTL approval for open acceptance in the 
marketplace. Without NRTL approval many retailers will not distribute a product.


Many Thanks!
Rob

Robert Campling
Manager (Global Market Access)
TÜV SÜD Product Service
Mob: +44 (0) 7967 650973
Email: robert.campl...@tuv-sud.co.uk

From: McBurney, Ian 
Sent: 13 November 2018 09:27
To: EMC-PSTC@listserv.ieee.org
Subject: {Ext} [PSES] NRTL approval

Dear colleagues.

We are in the process of designing a USB bus powered audio product around 2.5W 
for professional/consumer use.
The product enclosure will be UL94 5VA flammability rated plastic.
Will this product have to be NRTL approved for sale in the USA/Canada?
The EU LVD doesn't apply because of the supply voltage is only 5V DC. The GPSD 
probably will!

Many thanks in advance.

Ian McBurney
Lead Compliance Engineer.

Allen & Heath Ltd.
Kernick Industrial Estate,
Penryn, Cornwall. TR10 9LU. UK
T: 01326 372070
E: ian.mcbur...@allen-heath.com


Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company.
-


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Re: [PSES] NRTL approval

[Joe Randolph]

Hi Ian:



I have a vague recollection that the lower voltage limit either has been, or
will be, withdrawn in the EU.  The change may be specifically related to the
use of EN 62368-1, but I can't recall where I saw it.

 

 

Joe Randolph

Telecom Design Consultant

Randolph Telecom, Inc.

781-721-2848 (USA)

  j...@randolph-telecom.com

  http://www.randolph-telecom.com

 

From: McBurney, Ian [mailto:ian.mcbur...@allen-heath.com] 
Sent: Tuesday, November 13, 2018 4:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] NRTL approval

 

Dear colleagues.

 

We are in the process of designing a USB bus powered audio product around
2.5W for professional/consumer use.

The product enclosure will be UL94 5VA flammability rated plastic.

Will this product have to be NRTL approved for sale in the USA/Canada?

The EU LVD doesn't apply because of the supply voltage is only 5V DC. The
GPSD probably will!

 

Many thanks in advance.

 

Ian McBurney

Lead Compliance Engineer.

 

Allen & Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com  

 

 

Allen & Heath Ltd is a registered business in England and Wales, Company
number: 4163451. Any views expressed in this email are those of the
individual and not necessarily those of the company. 

-


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Attachments are not permitted but the IEEE PSES Online Communities site at
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Re: [PSES] NRTL approval

[Kevin Robinson]

Hello Ian,

This is my unofficial answer, but if you were to email me at work, the answer 
would be the same ...

OSHA regulations do not provide for limits on voltage or current, so any 
product that uses electrical energy must be tested and certified by a NRTL or 
otherwise determined "acceptable" as defined in 29 CFR 1910.399.  If the 
product is going into a workplace it requires NRTL approval.

Kevin Robinson
(Unofficially here) Director OSHA NRTL Program
202-693-1911
robinson.ke...@dol.gov

Kevin

From: McBurney, Ian 
Sent: Tuesday, November 13, 2018 4:27:22 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] NRTL approval

Dear colleagues.

We are in the process of designing a USB bus powered audio product around 2.5W 
for professional/consumer use.
The product enclosure will be UL94 5VA flammability rated plastic.
Will this product have to be NRTL approved for sale in the USA/Canada?
The EU LVD doesn’t apply because of the supply voltage is only 5V DC. The GPSD 
probably will!

Many thanks in advance.

Ian McBurney
Lead Compliance Engineer.

Allen & Heath Ltd.
Kernick Industrial Estate,
Penryn, Cornwall. TR10 9LU. UK
T: 01326 372070
E: ian.mcbur...@allen-heath.com


Allen & Heath Ltd is a registered business in England and Wales, Company 
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[PSES] NRTL approval

[McBurney, Ian]

Dear colleagues.

We are in the process of designing a USB bus powered audio product around 2.5W 
for professional/consumer use.
The product enclosure will be UL94 5VA flammability rated plastic.
Will this product have to be NRTL approved for sale in the USA/Canada?
The EU LVD doesn't apply because of the supply voltage is only 5V DC. The GPSD 
probably will!

Many thanks in advance.

Ian McBurney
Lead Compliance Engineer.

Allen & Heath Ltd.
Kernick Industrial Estate,
Penryn, Cornwall. TR10 9LU. UK
T: 01326 372070
E: ian.mcbur...@allen-heath.com


Allen & Heath Ltd is a registered business in England and Wales, Company 
number: 4163451. Any views expressed in this email are those of the individual 
and not necessarily those of the company.

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

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