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

[Pete Perkins]

The US product certification system seems confusing to those who have not grown 
up with it and used it.  It is divided, as has been discussed, between 
commercial/industrial (OHSA regulated) and retail/consumer (local AHJ 
controlled).  

OSHA has pretty clear requirements but enforcement is primarily done by 
investigating incidents.  

Consumer requirements are generally covered by the NEC (which requires NRTL 
listing) which is adopted in more than 10,000 jurisdictions in the US and 
enforced by AHJ inspectors.   This is also enforced at the retail level in that 
sellers won’t offer anything for sale which is not NRTL Listed as a contractual 
condition to the supplier.  AHJ facilities inspection is usually completed 
before most equipment is installed but anything installed earlier – including 
lighting, heating and air conditioning and other basic electrical appliances 
are fair game and can be ‘red tagged’ as not acceptable by the AHJ inspector.  

This has all been further confused by the enormous expansion of LV components 
used ubiquitously in both the work environment and the residential environment. 
 These LV devices used to be simple and could easily be evaluated during the 
inspection as being acceptable.  Today, however, the devices are much more 
complex and can give rise to hazards which are not obvious to a casual 
inspection (There have been numerous electric shock and/or fire issues 
developed from ‘walwarts’ which are always installed to operate connected 
equipment).  

Finally, in the American tradition the final enforcement is thru the legal 
system when there are incidents.  Any product involved which is not NRTL 
certified is condemned before the party starts.  

The manufacturer should beware and provide NRTL certification in more cases 
than not.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 1067

Albany, ORe  97321-0413

 

503/452-1201

 

IEEE Life Fellow

IEEE PSES 2020 Distinguished Lecturer

  p.perk...@ieee.org

 

From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org> 
Sent: Wednesday, February 19, 2020 7:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Hello Bernd,

 

The requirement from the National Electrical Code is either an NRTL Listing or 
approval by the local Authority Having Jurisdiction (AHJ). The latter option 
means that a local electrical inspector or building inspector will look at the 
equipment to determine whether they think it is safe and appropriate. In my 
opinion, this is a far more challenging option as opposed to getting an NRTL 
Listing. If the equipment does not meet the AHJ’s approval, it will get a “red 
tag” and will not be allowed to be operated until any corrections are made. 
Many customers will only accept NRTL Listed products.

 

Manufacturers of custom equipment will often seek “field certification”. For 
this option, the manufacturer hires an NRTL to come to the installation site to 
perform certification at that location. The NRTL can do field marking of the 
equipment if it meets approval. It then would meet the requirements of the NEC.

 

The NEC has no option for self-declaration. You either need an NRTL Listing or 
you need the approval of the AHJ. 

 

Ted Eckert

Microsoft Corporation

 

The opinions experessed are my own and do not necessarily reflect those of my 
employer.

 

 

From: Dürrer Bernd mailto:bernd.duer...@wilo.com> > 
Sent: Wednesday, February 19, 2020 7:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Hello Ted, hello Regan,

 

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

 

Thank you and kind regards,

 

Bernd

 

Von: Regan Arndt mailto:reganar...@gmail.com> > 
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG 

Re: [PSES] Mandatory certification

[Richard Nute]

 

Hi Dürrer:

 

1.  Self-declaration is not accepted by any jurisdiction (or by OSHA) in 
the USA.  However, safety certification is not mandatory (or enforced) in some 
local jurisdictions.
2.  Where the NEC is adopted by the local jurisdiction, the adoption may 
have exceptions and additions.  Note that some jurisdictions e.g., Chicago, Los 
Angeles, do not adopt the NEC, but have their own electrical code and rules for 
safety certification.
3.  Regarding the “market,” some retailers, e.g., Walmart, will not sell 
non-safety-certified products.

 

As a general rule (with exceptions), voluntary (mandatory for a workplace) 
safety certification by a NRTL is accepted everywhere in the USA.  Some 
certification houses offer individual product safety certification in situ.  

 

Best regards,

Rich

 

 

From: Dürrer Bernd  
Sent: Wednesday, February 19, 2020 7:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Hello Ted, hello Regan,

 

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

 

Thank you and kind regards,

 

Bernd

 


-

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


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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

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

[Chuck August-McDowell]

I think an example of the field inspection/label program not part of OSHA's 
NRTL program would be the City of Los Angles Department of Building and Safety.
http://www.ladbs.org/services/core-services/plan-check-permit/product-approval/electrical-test-lab

Note, I did not confirm they are not also an NRTL.

Respectfully,

Charles August-McDowell
Compliance Specialist

From: Regan Arndt 
Sent: Wednesday, February 19, 2020 10:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification


[EXTERNAL EMAIL]
Hello Dave/Bernd.

Just a comment/clarification. The field inspection/label program is not part of 
OSHA's NRTL program despite some NRTL's that conducted this service. I know it 
can seem confusing but there are also some non-NRTL's that conduct these field 
evaluations, all of which are under state jurisdiction.

Some may think they are abiding by OSHA rules with obtaining a field evaluation 
by an NRTL. That is not the case.

Regan

On Wed, Feb 19, 2020 at 7:11 AM Nyffenegger, Dave 
mailto:dave.nyffeneg...@bhemail.com>> wrote:
Bernd,

I don’t know any jurisdiction that would accept a manufacturer self-declaration 
if the jurisdiction is requiring a safety certification.  An alternative to an 
NRTL listing is an NRTL field inspection/label which is unique to each product 
at each  installation.

-Dave

From: Dürrer Bernd 
[mailto:bernd.duer...@wilo.com]
Sent: Wednesday, February 19, 2020 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Hello Ted, hello Regan,

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

Thank you and kind regards,

Bernd

Von: Regan Arndt mailto:reganar...@gmail.com>>
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

OSHA & the related NRTL mandatory certification is only for the 
commercial/office/industrial workplace. OSHA has no jurisdiction in the 
consumer environment.
The FCC is for both environments.

Regan

On Mon, Feb 17, 2020, 8:29 PM 
<06cee064502d-dmarc-requ...@ieee.org>
 wrote:
Thank you Ted, Rich and Regan,

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

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

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

Let me add to Rich and Regan’s comments.

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

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

That being said, you can choose not to get NRTL 

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

[Regan Arndt]

Hello Dave/Bernd.

Just a comment/clarification. The field inspection/label program is not
part of OSHA's NRTL program despite some NRTL's that conducted this
service. I know it can seem confusing but there are also some non-NRTL's
that conduct these field evaluations, all of which are under state
jurisdiction.

Some may think they are abiding by OSHA rules with obtaining a field
evaluation by an NRTL. That is not the case.

Regan

On Wed, Feb 19, 2020 at 7:11 AM Nyffenegger, Dave <
dave.nyffeneg...@bhemail.com> wrote:

> Bernd,
>
>
>
> I don’t know any jurisdiction that would accept a manufacturer
> self-declaration if the jurisdiction is requiring a safety certification.
> An alternative to an NRTL listing is an NRTL field inspection/label which
> is unique to each product at each  installation.
>
>
>
> -Dave
>
>
>
> *From:* Dürrer Bernd [mailto:bernd.duer...@wilo.com]
> *Sent:* Wednesday, February 19, 2020 10:02 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> Hello Ted, hello Regan,
>
>
>
> Thank you for your clear statements on NRTL certification. Can you please
> provide some guidance on the interpretation of the National Electrical Code
> NFPA 70 (2020 edition), article 110.3, on the suitability of installation
> and use in conformity with the NEC? Informational note no. 2 explains, that
> this suitability “may” be evidenced by listing or labelling. Informative
> Annex A “provides a list of product safety standards used for product
> listing where that listing is required by the NEC.” This lists includes
> many product safety standards for consumer products like appliances that
> are typically plug connected. In the case that the NEC has been adopted by
> local jurisdiction and that the equipment is in the scope of a product
> safety standard listed in Annex A, is NRTL certification and listing then a
> mandatory requirement, or is there another option (e.g. self-declaration of
> the manufacturer that the product is suitable for installation and use in
> conformity with the NEC) that is accepted both by jurisdiction and the
> market?
>
>
>
> Thank you and kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Regan Arndt 
> *Gesendet:* Dienstag, 18. Februar 2020 18:01
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> OSHA & the related NRTL mandatory certification is only for the
> commercial/office/industrial workplace. OSHA has no jurisdiction in the
> consumer environment.
>
> The FCC is for both environments.
>
>
>
> Regan
>
>
>
> On Mon, Feb 17, 2020, 8:29 PM <06cee064502d-dmarc-requ...@ieee.org>
> wrote:
>
> Thank you Ted, Rich and Regan,
>
> The product is classified as IT and is sold to pro market. i.e it is used
> by professional and not consumer market. There two types of products. Class
> I as well as Class III. They are mainly used in corporation conference
> rooms.
>
>
>
> With that in mind, what are your thoughts about mandatory NRTL
> certification as well as FCC?
>
>
>
> Thanks
>
> Peter
>
> -Original Message-
> From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
> To: EMC-PSTC 
> Sent: Mon, Feb 17, 2020 6:16 pm
> Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
> Hello Peter,
>
>
>
> Let me add to Rich and Regan’s comments.
>
>
>
> The question for residential installations isn’t as clear as for the
> workplace. Most jurisdictions in the United States have adopted the
> National Electrical Code which requires many electrical and electronic
> products to either be Listed or to be investigated and approved by the
> local Authority Having Jurisdiction. In practice, this typically will apply
> to hard-wired products or products attached to building structure. The
> enforcement is typically through an electrical inspection which will often
> not cover plug-connected devices.
>
>
>
> In the workplace, any product that has a direct connection to the mains
> will need NRTL approval. At the other end of the spectrum, a product like a
> USB mouse or remote control using alkaline batteries likely won’t need NRTL
> approval. In theory, I believe an OSHA inspector could enforce the NRTL
> requirement on any electrical product, but that won’t necessarily be what
> happens in practice.
>
>
>
> That being said, you can choose not to get NRTL approval for your product.
> However, you need to understand the risks your product may pose. If you
> sell products to commercial customers, are you meeting their needs? Will
> your products be acceptable to them? If you have a low-voltage device that
> isn’t mains connected, you will need to understand your customer’s needs
> before you make any determination about skipping NRTL approval.
>
>
>
> Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL
> approval, you can state that you are selling a product to the general
> public for home use where NRTL approval for a mouse is 

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

[Ted Eckert]

Hello Bernd,

The requirement from the National Electrical Code is either an NRTL Listing or 
approval by the local Authority Having Jurisdiction (AHJ). The latter option 
means that a local electrical inspector or building inspector will look at the 
equipment to determine whether they think it is safe and appropriate. In my 
opinion, this is a far more challenging option as opposed to getting an NRTL 
Listing. If the equipment does not meet the AHJ’s approval, it will get a “red 
tag” and will not be allowed to be operated until any corrections are made. 
Many customers will only accept NRTL Listed products.

Manufacturers of custom equipment will often seek “field certification”. For 
this option, the manufacturer hires an NRTL to come to the installation site to 
perform certification at that location. The NRTL can do field marking of the 
equipment if it meets approval. It then would meet the requirements of the NEC.

The NEC has no option for self-declaration. You either need an NRTL Listing or 
you need the approval of the AHJ.

Ted Eckert
Microsoft Corporation

The opinions experessed are my own and do not necessarily reflect those of my 
employer.


From: Dürrer Bernd 
Sent: Wednesday, February 19, 2020 7:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Hello Ted, hello Regan,

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

Thank you and kind regards,

Bernd

Von: Regan Arndt mailto:reganar...@gmail.com>>
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

OSHA & the related NRTL mandatory certification is only for the 
commercial/office/industrial workplace. OSHA has no jurisdiction in the 
consumer environment.
The FCC is for both environments.

Regan

On Mon, Feb 17, 2020, 8:29 PM 
<06cee064502d-dmarc-requ...@ieee.org>
 wrote:
Thank you Ted, Rich and Regan,

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

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

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

Let me add to Rich and Regan’s comments.

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

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

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

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

[Nyffenegger, Dave]

Bernd,

I don’t know any jurisdiction that would accept a manufacturer self-declaration 
if the jurisdiction is requiring a safety certification.  An alternative to an 
NRTL listing is an NRTL field inspection/label which is unique to each product 
at each  installation.

-Dave

From: Dürrer Bernd [mailto:bernd.duer...@wilo.com]
Sent: Wednesday, February 19, 2020 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Hello Ted, hello Regan,

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

Thank you and kind regards,

Bernd

Von: Regan Arndt 
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

OSHA & the related NRTL mandatory certification is only for the 
commercial/office/industrial workplace. OSHA has no jurisdiction in the 
consumer environment.
The FCC is for both environments.

Regan

On Mon, Feb 17, 2020, 8:29 PM 
<06cee064502d-dmarc-requ...@ieee.org>
 wrote:
Thank you Ted, Rich and Regan,

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

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

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

Let me add to Rich and Regan’s comments.

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

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

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

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

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

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


Hi Peter:

I can only speak 

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

[Dürrer Bernd]

Hello Ted, hello Regan,

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

Thank you and kind regards,

Bernd

Von: Regan Arndt 
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

OSHA & the related NRTL mandatory certification is only for the 
commercial/office/industrial workplace. OSHA has no jurisdiction in the 
consumer environment.
The FCC is for both environments.

Regan

On Mon, Feb 17, 2020, 8:29 PM 
<06cee064502d-dmarc-requ...@ieee.org>
 wrote:
Thank you Ted, Rich and Regan,

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

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

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

Let me add to Rich and Regan’s comments.

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

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

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

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

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

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


Hi Peter:

I can only speak to NRTL certification.

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

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

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

Best regards,
Rich


-

Re: [PSES] Keeping cellphone noise out of audio op-amps

[John Woodgate]

Thank you very much.

Best wishes
John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK

On 2020-02-19 12:20, Gert Gremmen wrote:


Basically any connection to an opamp can create unwanted susceptibility.

So a small cap to ground preceded by a suitable impedance for the 
frequencies to be suppressed


will do the job.

What pins ?

Those that have a substantial length (compared to wavelength) on PCB 
(or off PCB).


By placing impedance in series with each input/output/supply the 
effects will already greatly be reduced.


Do not rely on feedback mechanism for this so the 47 pF will do a 
great job until the max freq of the opamp is exceeded.


Gert Gremmen


On 19-2-2020 13:11, John Woodgate wrote:


I see two apparent ways of keeping cellphone noise out of audio op-amps:

- 10 pF between + and - inputs;

- 47 pF (or similar) from output to inverting input.

Which is usually more effective? I suspect that the first one is, but 
I see it less often.

--
Best wishes
John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK
-


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 mailto:emc-p...@ieee.org>>


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


Attachments are not permitted but the IEEE PSES Online Communities 
site at http://product-compliance.oc.ieee.org/ can be used for 
graphics (in well-used formats), large files, etc.


Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to 
unsubscribe)

List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcantw...@ieee.org>>

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>


--
Independent Expert on CE marking
EMC Consultant
Electrical Safety Consultant


-

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

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Keeping cellphone noise out of audio op-amps

[Gert Gremmen]

Basically any connection to an opamp can create unwanted susceptibility.

So a small cap to ground preceded by a suitable impedance for the 
frequencies to be suppressed


will do the job.

What pins ?

Those that have a substantial length (compared to wavelength) on PCB (or 
off PCB).


By placing impedance in series with each input/output/supply the effects 
will already greatly be reduced.


Do not rely on feedback mechanism for this so the 47 pF will do a great 
job until the max freq of the opamp is exceeded.


Gert Gremmen


On 19-2-2020 13:11, John Woodgate wrote:


I see two apparent ways of keeping cellphone noise out of audio op-amps:

- 10 pF between + and - inputs;

- 47 pF (or similar) from output to inverting input.

Which is usually more effective? I suspect that the first one is, but 
I see it less often.

--
Best wishes
John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK
-


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 mailto:emc-p...@ieee.org>>


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


Attachments are not permitted but the IEEE PSES Online Communities 
site at http://product-compliance.oc.ieee.org/ can be used for 
graphics (in well-used formats), large files, etc.


Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to 
unsubscribe)

List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcantw...@ieee.org>>

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>


--
Independent Expert on CE marking
EMC Consultant
Electrical Safety Consultant


-

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

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 
<>

[PSES] Keeping cellphone noise out of audio op-amps

[John Woodgate]

I see two apparent ways of keeping cellphone noise out of audio op-amps:

- 10 pF between + and - inputs;

- 47 pF (or similar) from output to inverting input.

Which is usually more effective? I suspect that the first one is, but I 
see it less often.


--
Best wishes
John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK


-

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

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] SV: [PSES] Ground copper fill on signal layer on multilayer PCB

[James Pawson (U3C)]

Hi Amund,

 

If you have the space on the board then a ground fill around the perimeter (on 
all layers) probably won’t do any harm. Whatever ground fill strategy you 
decide on for the signal layer I would make sure it is well connected with vias 
to both of the adjacent planes along the edge nearest to the signals and around 
the perimeter of the PCB. The distance between these vias probably isn’t that 
critical but you often see the figure of wavelength/20 or wavelength/10 used as 
a guideline. For a digital signal you could use 0.35/Trise as a rule of thumb 
for working out the frequency. Lambda = c/f takes care of the rest.

 

Edge plating (as Ken points out) is an option but obviously adds cost to the 
PCB.

 

Part of the aim will be to maintain the correct characteristic impedance of 
your transmission line to help ensure good signal quality. You could model the 
PCB stackup and trace geometry in something like Polar or Hyperlynx (this free 
tool   doesn’t 
account for a co-planar ground) and see how far away the co-planar ground needs 
to be to maintain the correct impedance. Or just choose an arbitrarily large, 
conservative (small c) number like 10h (h being height of the smallest gap 
between trace and plane).

 

If you have noise leakage, that would suggest that your “differential” lines 
might not be as differential as you think. Unequal rise/fall times and skew 
between rising and falling edges will create common mode noise on these pairs. 
This is usually a fundamental characteristic of the driver circuit itself and 
there’s not much you can do about it. May be worth trying a HF common mode 
choke at the source – Wurth, Murata and TDK make good ones.

 

Local ground via where your HF signals transition between layers to ensure that 
the return path currents can transfer from one side of the plane to the other 
(skin effect). This should be balanced, that is equidistant between the traces, 
or use two in symmetrical layout, to avoid imbalance in parasitic capacitance. 
You may also want to think about via “anti pads” to improve your impedance 
matching.

 

What bus technology are you using for these high speed traces?

 

HTH

James

 

 

James Pawson

EMC Problem Solver

 

Unit 3 Compliance

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

  www.unit3compliance.co.uk -- 07811 139957

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

 

From: Amund Westin  
Sent: 19 February 2020 06:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] Ground copper fill on signal layer on multilayer PCB

 

Hi Ken

 

No, I have not considered edge-plating. I’ll look into this now.

We have some high frequency noise (400-500MHz) from differential lines leaking 
out from an inner layer of a multilayer pcb. Edge-plating might be a good 
solution.

Thanks for the tip.

 

BR
Amund

 

Fra: IBM Ken 
Sendt: 18. februar 2020 23:18
Til: EMC-PSTC@LISTSERV.IEEE.ORG  
Emne: Re: [PSES] Ground copper fill on signal layer on multilayer PCB

 

Hi Amund!  Have you also considered edge-plating?  Are you trying to reduce 
radiated noise outside your product, or cross-talk within the product (or both)?

 

On Tue, Feb 18, 2020 at 3:03 AM Amund Westin mailto:am...@westin-emission.no> > wrote:

Between two solid ground planes, we have a signal layer, routing high speed 
differential lines.

 

What do you recommend: 

I.  fill the remaining area with copper in the signal layer 
II. fill only the border of the layer (5mm ground copper trace around the 
layer edge)
III.no fill at all

 

 

Best regards

Amund

 

-


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

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

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) 
 
List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators:
Scott Douglas sdoug...@ieee.org  
Mike Cantwell mcantw...@ieee.org   

For policy questions, send mail to:
Jim Bacher j.bac...@ieee.org  
David Heald dhe...@gmail.com   

-


This message is from the IEEE Product Safety Engineering