Re: [PSES] Multiple electrical power sources

[Kevin Robinson]

You might want to take a look at UL/IEC/EN 60950-1 which I know definitely has 
requirements for multiple power sources.  62368 may have guidance as well

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From: Richard Nute 
Sent: Thursday, April 6, 2023 8:15:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Multiple electrical power sources






Hi Steve:



The TV broadcast industry electronic products have used two (redundant) AC 
sources for their products for many years.  You may have some help there.



Rich





From: Steve Brody 
Sent: Thursday, April 6, 2023 1:42 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Multiple electrical power sources



A new question.



A client's product is using two independent AC power sources on a product, but 
I can't find anything in 61010-1 60204-1 that provide any guidance on 
compliance.



The obvious is that the sections of the product that are fed from source A or B 
are not interrelated in any way that would create a hazard for for the other 
section, that there be a warning label adjacent to each input that says there 
are multiple AC sources, and that each section has it's own circuit protection 
and disconnect, even if a facility disconnect is used for both.



What am I missing?



Thanks,





Steve Brody

sgbr...@comcast.net

C - 603 617 9116



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Re: [PSES] Maintaining UL Label when Modifying Electrical Enclosures in the Field

[Kevin Robinson]

Ronan,

OSHA published a Safety and Health Information Bulletin on this topic.  It is 
available here 
https://www.osha.gov/sites/default/files/publications/shib021610.pdf

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From: Ronan Shanley <205e1cfd8f16-dmarc-requ...@listserv.ieee.org>
Sent: Friday, March 17, 2023 3:23:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: [PSES] Maintaining UL Label when Modifying Electrical Enclosures in 
the Field


Hi All,



I have a question about maintaining the UL label on electrical enclosures when 
modified in the field. We have our electrical enclosures built at a UL 508A 
shop.  We have a minor change to the design where we are removing a pushbutton 
from the front of the enclosure.  We will update the design, provide an updated 
schematic and other documents, create a procedure for the field change etc.  
Will this change impact the enclosure UL label or require any field evaluation?



Best,



RONAN SHANLEY

EE



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ALERT INNOVATION

ronan.shan...@alertinnovation.com

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Re: [PSES] To NRTL or not NRTL, that is the question

[Kevin Robinson]

OSHA requires any electrical product being used in the workplace to be tested 
and certified by an NRTL.  There is no lower voltage or power limit.

A “UL Listing” and “NRTL Certification” are the same thing.  The difference 
being the UL Listing is a NRTL Listing specifically from UL (similar to the 
difference between “Kleenex” and “facial tissue”

Kevin Robinson

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From: Dürrer Bernd 
Sent: Tuesday, September 27, 2022 7:56:08 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: [PSES] AW: [PSES] To NRTL or not NRTL, that is the question


Hello James,



I propose to check Annex A of the National Electrical Code NFPA 70 (NFPA 70®: 
National Electrical 
Code®<https://www.nfpa.org/codes-and-standards/all-codes-and-standards/list-of-codes-and-standards/detail?code=70>)
 that contains a list of product safety standards used for product listing 
where listing is required by the NEC. If the equipment in question is in the 
scope of a standard mentioned there, it requires listing (i.e. certification by 
a NRTL as defined in NEC article 110.3(C)).



Kind regards,



Bernd



Von: James Pawson (U3C) 
Gesendet: Dienstag, 27. September 2022 09:20
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: [PSES] To NRTL or not NRTL, that is the question



Hello experts,



I'm trying to understand what electrical products require NRTL approval for 
electrical safety for sale in the United States.



Looking on the OSHA website I find this page 
(https://www.osha.gov/nationally-recognized-testing-laboratory-program/products-requiring-approval)
 which links to this page (

https://www.osha.gov/nationally-recognized-testing-laboratory-program/1910-references#1910_303-307)



Taking this at face value, particularly 303(g)(2)(i), does this mean that 
equipment operating at less than 50V (I'm assuming DC and AC RMS) does not 
require NRTL approval?



The question comes from a customer who was emailed by one of his US customers 
stating that he should have "UL listing". I understand that NRTL approval and 
the Listing process are different with the latter being more involved? Would 
appreciate any comments on this.



Thanks as always.



All the best

James


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[PSES] Engineering Position - OSHA NRTL Program

[Kevin Robinson]

Good morning everyone,

The Department of Labor (DOL) Occupational Safety and Health Administration
(OSHA) is looking to hire an electrical engineer to work in its Nationally
Recognized Testing Laboratory (NRTL) Program.

Interested candidates may apply at: https://www.usajobs.gov/job/657774700

Kevin Robinson

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[PSES] Electrical Engineer for OSHA NRTL Program

[Kevin Robinson]

Hello Everyone,

I wanted to share a vacancy announcement for an Electrical Engineer in
OSHA's Nationally Recognized Testing Laboratory program.  Interested
candidates may apply at https://go.usa.gov/xt2QM

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[PSES] Follow-Up Questions October IEEE PSES Virtual Chapter - OSHA NRTL

[Kevin Robinson]

tion.  Certain conditions are placed
on component certifications that must be addressed in the end product.
Components not integrated into, or evaluated as part of an end product
certification are incomplete and are therefore not acceptable to OSHA.



OSHA determines an installation or equipment is acceptable to the Assistant
Secretary of Labor, and approved within the meaning of Subpart S of the
Occupational Safety and Health Act:

 (1) If it is accepted, or certified, or listed, or labeled, or otherwise
determined to be safe by a nationally recognized testing laboratory
recognized pursuant to § 1910.7; or



(2) With respect to an installation or equipment of a kind that no
nationally recognized testing laboratory accepts, certifies, lists, labels,
or determines to be safe, if it is inspected or tested by another Federal
agency, or by a State, municipal, or other local authority responsible for
enforcing occupational safety provisions of the National Electrical Code,
and found in compliance with the provisions of the National Electrical Code
as applied in this subpart; or



(3) With respect to custom-made equipment or related installations that are
designed, fabricated for, and intended for use by a particular customer, if
it is determined to be safe for its intended use by its manufacturer on the
basis of test data which the employer keeps and makes available for
inspection to the Assistant Secretary and his authorized representatives.



The NRTL Program Directive (Annex B 4.1B) requires the certification mark
of a NRTL to be applied to the product unless the size of the product makes
applying the mark impossible
https://www.osha.gov/sites/default/files/enforcement/directives/CPL_01-00-004.pdf



*QUESTION:*

Does OSHA recognize (or more importantly...approve) the widely used Field
evaluation process conducted by some NRTLs? If not, then why not? If the
Field evaluation is conducted whereby OSHA does not recognize this process,
is it assumed that the product is not compliant 'federally' but
'accepted/compliant' locally?



*ANSWER:*

OSHA regulations do not address what are typically referred to as “Field
Evaluations” or “Field Inspections”.  Field evaluations/inspections are
typically non-destructive investigations that address only a portion of the
requirements in a specific test standard.  The work is typically done at
the location of the end installation and is often done on unique or one of
a kind pieces of equipment.


Kevin Robinson

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Re: [PSES] Mandatory certification

[Kevin Robinson]

>From OSHA's perspective, the employer where the equipment is installed is
responsible for ensuring the equipment is "acceptable" as defined in 29 CFR
1910.399
https://www.govinfo.gov/content/pkg/CFR-2019-title29-vol5/pdf/CFR-2019-title29-vol5-sec1910-399.pdf
.

In reality, most manufacturers assume the burden of certification as it
helps with the sale of the product and certification requires intimate
knowledge of the product components and specifications.

That said, if the product is sold in retail stores, most major retailers
require product certification before the product can be sold on their
shelves.



On Fri, Feb 21, 2020 at 3:57 PM Stultz, Mark 
wrote:

> Hello Kevin,
>
>
>
> Thanks for the great explanation.  Who is ultimately responsible for
> ensuring that equipment is certified by a NRTL?  Does the final
> responsibility fall on the purchaser/end-user or on the manufacturer?
>
>
>
> Best regards,
>
>
>
> *Mark Stultz* | CMSE® | Sealed Air | Automated Packaging Systems |
> Streetsboro, OH | 330-342-2402
>
>
>
> *From:* Kevin Robinson 
> *Sent:* Friday, February 21, 2020 11:49 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Mandatory certification
>
>
>
>
>
>  *CAUTION:* This email originated from outside of the organization. Do
> not click links or open attachments unless you recognize the sender and
> know the content is safe.
>
>
>
> Brian,
>
>
>
> I manage the NRTL Program for OSHA.  As I am responding from my personal
> address, nothing I say here can be considered as a response from OSHA (but
> if you contact me at robinson.ke...@dol.gov, I will state the same thing
> I say here.)
>
>
>
> As for low production units, you might be able to save costs by utilizing
> families.  If you can determine the worst case condition(s) you might be
> able to simply test a few products and have that representative of all of
> the units you manufacture.  As for costs, when I worked for a NRTL (granted
> this was 12 years ago), three field evaluations were about the same cost as
> a full certification.  Yes, you might have factory surveillance costs and
> certification mark costs, but compared to the actual testing and
> certification, those costs are minimal.
>
>
>
> With regard to your interpretation of 29 CFR 1910.399:
>
>
>
> 1) This clause only covers NRTL Certification.  Field evaluations are NOT
> part of the NRTL program.  NRTLs who are issuing Field certificates and
> labels are doing so under their own name and not as a NRTL.
>
>
>
> 2) There are some products for which no NRTL has been able to demonstrate
> they have the necessary test equipment and procedures for.  For example,
> several years ago, OSHA  required crane insulating links to be tested and
> certified by a NRTL.  Until last year, there was no test standard for
> insulating links and the equipment required is very specialized.  OSHA has
> not yer recognized a NRTL to test and certify these insulating links.
> There are other examples where there are no standards for certain products,
> or where no NRTL has the capability to test to the standard.  In such an
> instance, the local AHJ may approve of the installation, or if another
> Federal Agency has jurisdiction, they may approve of the installation.  In
> my experience, this is very rare, but it is an option.
>
>
>
> 3) This option only applies to unique custom made equipment that is made
> specifically for an employer.  The example I always give is the requirement
> would apply if a potato farmer contracted with a company to make a custom
> machine that he designed to separate rocks from his potato crop.  This was
> a machine made to his exact and custom specifications, and there is nothing
> else like it.  The manufacturer could conduct some basic safety testing and
> prepare a report to give to the employer to present to OSHA if they ever
> asked for it. Either the manufacturer could do the testing themselves, or
> they could hire someone to conduct the testing for them.  The requirement
> however would NOT apply if you created a "Custom" computer purchased from a
> major manufacturer (ex Dell, Apple, Lenovo etc.) .  While you can go to
> their website and build a custom machine to your exact specifications, the
> big manufacturers aren't really making custom machines.
>
>
>
> *Everything below this represents my own personal opinion and is something
> I would not say in any official capacity (mostly because manufacturer self
> declaration has so many implications in a broad spectrum of areas).*
>
>
>
> As for allowing manufacturer self declaration, I would encourage you to
> look at a Request for Information (RFI) that OS

Re: [PSES] Mandatory certification

[Kevin Robinson]

Lauren,


1.   No NRTL per se offers field labeling because field labeling is not
in scope of NRTL ‘responsibilities’. An NRTL company might offer it, but it
is not an NRTL function.

<<>> Correct.  As Field inspections/certifications are not a
function of OSHA's NRTL Program, if an NRTL is offering such an evaluation
(and most do), they are issuing it based on the reputation of their brand,
or possibly as accredited by an accreditation body to NFPA 790 & 791.  They
are however not operating as an NRTL.


2.   {Quite to my surprise!} the implication of 29 CFR 1910.399(2) is
that a company essentially has to try each NRTL to see if it “accepts,
certifies, lists, labels, or determines to be safe” an equipment as part of
their NRTL scope. Only if all NRTLs are reasonably investigated could one
‘advance’ in the clause to e.g., turning to a local authority (to the
location of installation) for enforcing occupational safety provisions of
the National Electrical Code etc… at which point field labeling could be
acceptable if such authority found it so.

<<>> OSHA has not said officially (in the form of an official
interpretation)
https://www.osha.gov/laws-regs/standardinterpretations/standardnumber/1910 to
what end a manufacturer must go to prove that no NRTL can certify a piece
of equipment, but yes, that is generally correct that you should reach out
to all of the NRTLs before invoking this clause.


3.   29 CFR 1910.399(3) is not really applicable to a case of equipment
customization such as adding customer specific bells or whistles to a
product that is otherwise common to units sold to other customers. It is
focused on ‘extremely’ bespoke equipment essentially designed by the
workplace owner.

<<>> Correct.

On Fri, Feb 21, 2020 at 3:52 PM  wrote:

> Kevin,
>
>
>
> Thanks for this detailed assessment.  I would like to make sure I
> understand your guidance.
>
>
>
> 1.   No NRTL per se offers field labeling because field labeling is
> not in scope of NRTL ‘responsibilities’. An NRTL company might offer it,
> but it is not an NRTL function.
>
> 2.   {Quite to my surprise!} the implication of 29 CFR 1910.399(2) is
> that a company essentially has to try each NRTL to see if it “accepts,
> certifies, lists, labels, or determines to be safe” an equipment as part of
> their NRTL scope. Only if all NRTLs are reasonably investigated could one
> ‘advance’ in the clause to e.g., turning to a local authority (to the
> location of installation) for enforcing occupational safety provisions of
> the National Electrical Code etc… at which point field labeling could be
> acceptable if such authority found it so.
>
> 3.   29 CFR 1910.399(3) is not really applicable to a case of
> equipment customization such as adding customer specific bells or whistles
> to a product that is otherwise common to units sold to other customers. It
> is focused on ‘extremely’ bespoke equipment essentially designed by the
> workplace owner.
>
>
>
> Are those roughly correct? (any further clarifications welcome).
>
>
>
> Regards,
>
> -Lauren Crane
>
>
>
> *From:* Kevin Robinson 
> *Sent:* Friday, February 21, 2020 10:49 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Mandatory certification
>
>
>
> Brian,
>
>
>
> I manage the NRTL Program for OSHA.  As I am responding from my personal
> address, nothing I say here can be considered as a response from OSHA (but
> if you contact me at robinson.ke...@dol.gov, I will state the same thing
> I say here.)
>
>
>
> As for low production units, you might be able to save costs by utilizing
> families.  If you can determine the worst case condition(s) you might be
> able to simply test a few products and have that representative of all of
> the units you manufacture.  As for costs, when I worked for a NRTL (granted
> this was 12 years ago), three field evaluations were about the same cost as
> a full certification.  Yes, you might have factory surveillance costs and
> certification mark costs, but compared to the actual testing and
> certification, those costs are minimal.
>
>
>
> With regard to your interpretation of 29 CFR 1910.399:
>
>
>
> 1) This clause only covers NRTL Certification.  Field evaluations are NOT
> part of the NRTL program.  NRTLs who are issuing Field certificates and
> labels are doing so under their own name and not as a NRTL.
>
>
>
> 2) There are some products for which no NRTL has been able to demonstrate
> they have the necessary test equipment and procedures for.  For example,
> several years ago, OSHA  required crane insulating links to be tested and
> certified by a NRTL.  Until last year, there was no test standard for
> insulating links and the equipmen

Re: [PSES] Mandatory certification

[Kevin Robinson]

Brian,

I manage the NRTL Program for OSHA.  As I am responding from my personal
address, nothing I say here can be considered as a response from OSHA (but
if you contact me at robinson.ke...@dol.gov, I will state the same thing I
say here.)

As for low production units, you might be able to save costs by utilizing
families.  If you can determine the worst case condition(s) you might be
able to simply test a few products and have that representative of all of
the units you manufacture.  As for costs, when I worked for a NRTL (granted
this was 12 years ago), three field evaluations were about the same cost as
a full certification.  Yes, you might have factory surveillance costs and
certification mark costs, but compared to the actual testing and
certification, those costs are minimal.

With regard to your interpretation of 29 CFR 1910.399:

1) This clause only covers NRTL Certification.  Field evaluations are NOT
part of the NRTL program.  NRTLs who are issuing Field certificates and
labels are doing so under their own name and not as a NRTL.

2) There are some products for which no NRTL has been able to demonstrate
they have the necessary test equipment and procedures for.  For example,
several years ago, OSHA  required crane insulating links to be tested and
certified by a NRTL.  Until last year, there was no test standard for
insulating links and the equipment required is very specialized.  OSHA has
not yer recognized a NRTL to test and certify these insulating links.
There are other examples where there are no standards for certain products,
or where no NRTL has the capability to test to the standard.  In such an
instance, the local AHJ may approve of the installation, or if another
Federal Agency has jurisdiction, they may approve of the installation.  In
my experience, this is very rare, but it is an option.

3) This option only applies to unique custom made equipment that is made
specifically for an employer.  The example I always give is the requirement
would apply if a potato farmer contracted with a company to make a custom
machine that he designed to separate rocks from his potato crop.  This was
a machine made to his exact and custom specifications, and there is nothing
else like it.  The manufacturer could conduct some basic safety testing and
prepare a report to give to the employer to present to OSHA if they ever
asked for it. Either the manufacturer could do the testing themselves, or
they could hire someone to conduct the testing for them.  The requirement
however would NOT apply if you created a "Custom" computer purchased from a
major manufacturer (ex Dell, Apple, Lenovo etc.) .  While you can go to
their website and build a custom machine to your exact specifications, the
big manufacturers aren't really making custom machines.

*Everything below this represents my own personal opinion and is something
I would not say in any official capacity (mostly because manufacturer self
declaration has so many implications in a broad spectrum of areas).*

As for allowing manufacturer self declaration, I would encourage you to
look at a Request for Information (RFI) that OSHA published almost 10 years
ago https://www.regulations.gov/document?D=OSHA-2008-0032-0099  You can
review all of the questions OSHA asked and the public responses here
https://www.regulations.gov/docket?D=OSHA-2008-0032.  The United States has
a very robust product safety system and as a result, there are very few
injuries as a direct result of products that are NRTL certified.  While you
may feel that $6000 - 8000 is expensive to product certification, I have to
ask, and I don't mean to get dramatic, but what is the cost of the loss of
someone's vision because a centrifuge exploded and a piece of shrapnel
landed in someone's eye? What is the cost of someone losing the use of
their hand due to an electric shock that caused nerve damage?  What is the
cost of someone's life because they received a lethal amount of leakage
current from an equipment enclosure and a nearby electrical conduit?
Regulatory testing always seems excessive, until it isn't.  Every
manufacturer and industry believes that their products are "low risk", so
where does the line get drawn?

Kevin Robinson

On Fri, Feb 21, 2020 at 10:35 AM Brian Kunde  wrote:

> Not all companies manufacturers high volume consumer goods. Our company
> designs and builds analytical test equipment (laboratory equipment) which
> is very expensive (relatively speaking) and built one at a time per our
> customer requirements.  We have about 50 Families of products; each with
> dozens of variations. Even our best selling product family might only sell
> less than 50 units per year, and many models may not see a single sale in a
> year.  Yet when someone needs one, we build it.
>
> Some of our customers require NRTL certification.
>
> We have approached several NRTLs requesting Certification for our
> production units.  Nope. 

Re: [PSES] Mandatory certification

[Kevin Robinson]

Clause 2 under the definition for “acceptable” can only be used under specific 
conditions, specifically if no NRTL has the capability to test and certify the 
equipment.  In such cases, the equipment/installation would be acceptable to 
OSHA if a state/federal agency determined it was safe.  The reality is however 
that most local jurisdictions don’t want to take on the liability of approving 
non certified equipment, so they will require the owner/employer to get a field 
evaluation.

OSHA has not made an OFFICIAL interpretation of the regulations to say that a 
field evaluation could be used to meet the definition of “acceptable”.  
https://www.osha.gov/laws-regs/standardinterpretations/publicationdate/currentyear

Disclaimer: My positions posted here are my own and do not represent the 
official positions of my employer the US Department of Labor or OSHA.

Kevin Robinson

Get Outlook for iOS<https://aka.ms/o0ukef>

From: Richard Nute 
Sent: Thursday, February 20, 2020 8:15:36 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Mandatory certification




Hi Regan:



Yes, if that piece of equipment is not within any NRTL purview.



Best regards,

Rich





From: Regan Arndt 
Sent: Thursday, February 20, 2020 1:22 PM
To: Richard Nute 
Cc: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] Mandatory certification



Hi Rich.



If you are referring to clause (2):



(2) With respect to an installation or equipment of a kind that no nationally 
recognized testing laboratory accepts, certifies, lists, labels, or determines 
to be safe, if it is inspected or tested by another Federal agency, or by a 
State, municipal, or other local authority responsible for enforcing 
occupational safety provisions of the National Electrical Code, and found in 
compliance with the provisions of the National Electrical Code as applied in 
this subpart; or



Correct me if I am wrong, "BUT ONLY" if that piece of equipment cannot be 
certified by the NRTL's, which is almost rare nowadays when you look at the 
extensive scope of accreditation of the NRTL's.



Regan



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[PSES] Safety Engineer position

[Kevin Robinson]

The Occupational Safety and Health Administration has just posted a
position for an electrical engineer/auditor in the Nationally Recognized
Testing Laboratory (NRTL) Program.

Please share this with any individuals you think would be interested.

Interested parties may review the posting and apply at
https://www.usajobs.gov/GetJob/ViewDetails/541417400

Kevin Robinson

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Re: [PSES] Class 1 Div 2 in a pressurized enclosure requires NTRL?

[Kevin Robinson]

There are several references in the OSHA regulations where “approved” is 
mentioned.   “Approved is then defined in 29 CFR 1910.399 which is where the 
NRTL certification requirement is listed.

Kevin.

Kevin


From: Rodriguez, Daniel (ESP) 
Sent: Thursday, May 9, 2019 5:37 AM
To: emc-pstc@listserv.ieee.org
Subject: Re: [PSES] Class 1 Div 2 in a pressurized enclosure requires NTRL?

Thank you Robison for your reply!!

Then the summary is that a industrial controller to be used in  Class 1 Div 2 
needs to have NTRL approval for Hazloc and ordinary location. A self 
certification by the manufacturer for Hazloc is not accepted.

Which point of the regulation indicates it?
Perhaps below?

1910.307<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS_id=9884>
 - Hazardous (classified) locations
307(b) - Equipment, wiring methods, and installations of equipment in hazardous 
(classified) locations shall be intrinsically safe, approved for the hazardous 
(classified) location, or safe or for the hazardous (classified) location.

Thank you for your answer

Kind Regards
Daniel Rodríguez

From: Kevin Robinson 
Sent: Monday, May 06, 2019 5:53 PM
To: Rodriguez, Daniel (ESP) ; emc-pstc@listserv.ieee.org
Subject: Re: [PSES] Class 1 Div 2 in a pressurized enclosure requires NTRL?

Caution: This email originated from outside of the organization. DO NOT CLICK 
on links or open attachments unless you recognize the sender and know the 
content is safe.



Daniel,

Generally yes, the product must be certified by a NRTL, however I seem to 
recall seeing some enclosures that were approved with certain assumptions on 
the internal equipment that you might be able to rely on the enclosure 
certification.  Keep in mind that the equipment also needs to meet normal 
location requirements.

If you have any questions about the NRTL program, feel free to reach out to me 
at my office robinson.ke...@dol.gov<mailto:robinson.ke...@dol.gov> or 
202-693-1911 as I manage the NTRL program for OSHA.

Kevin Robinson



From: Rodriguez, Daniel (ESP) 
mailto:drodrig...@ecolab.com>>
Sent: Monday, May 6, 2019 11:09 AM
To: emc-pstc@listserv.ieee.org<mailto:emc-pstc@listserv.ieee.org>
Subject: [PSES] Class 1 Div 2 in a pressurized enclosure requires NTRL?

Good morning every body!!

In USA it is mandatory that Class 1 Div 2 in a pressurized enclosure is 
reviewED by a NTRL lab?
If it mandatory where I can find it?
Or with the enclosure certificate is enough?

I wish you a nice day!
Thank you for your answers

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen
Daniel Rodríguez

CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may 
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Re: [PSES] Class 1 Div 2 in a pressurized enclosure requires NTRL?

[Kevin Robinson]

Daniel,

Generally yes, the product must be certified by a NRTL, however I seem to 
recall seeing some enclosures that were approved with certain assumptions on 
the internal equipment that you might be able to rely on the enclosure 
certification.  Keep in mind that the equipment also needs to meet normal 
location requirements.

If you have any questions about the NRTL program, feel free to reach out to me 
at my office robinson.ke...@dol.gov or 202-693-1911 as I manage the NTRL 
program for OSHA.

Kevin Robinson



From: Rodriguez, Daniel (ESP) 
Sent: Monday, May 6, 2019 11:09 AM
To: emc-pstc@listserv.ieee.org
Subject: [PSES] Class 1 Div 2 in a pressurized enclosure requires NTRL?

Good morning every body!!

In USA it is mandatory that Class 1 Div 2 in a pressurized enclosure is 
reviewED by a NTRL lab?
If it mandatory where I can find it?
Or with the enclosure certificate is enough?

I wish you a nice day!
Thank you for your answers

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen
Daniel Rodríguez

CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may 
contain proprietary and privileged information for the use of the designated 
recipients named above. Any unauthorized review, use, disclosure or 
distribution is prohibited. If you are not the intended recipient, please 
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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 
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] CE non-conformity statistics

[Kevin Robinson]

Here are a few more resources that attempt to compare rates of compliance 
between SDoC and 3rd party conformity assessment.
http://www.ifia-federation.org/content/wp-content/uploads/IFIA_CIPC_239_2014-2016_Market_survey_report.pdf

https://www.regulations.gov/document?D=OSHA-2008-0032-0099




Kevin

From: Charlie Blackham 
Sent: Friday, November 2, 2018 4:28:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

Many consumer items that fall under the LVD are dealt with under the GPSD are 
reported on RAPEX

Many machines don’t “freely move” about the EU and the Machinery Directive is 
enforced under national legislation – for example in the UK, the Health and 
Safety Executive enforce and prosecute using the Supply of Machinery 
Regulations 2008 and Provision of Work Equipment Regulations 1998 – however in 
many (perhaps all) cases, this is only done after someone has been injured, or 
worse, at work. However details of all prosecutions are released 
http://www.hse.gov.uk/press/press.htm which includes details of fines and 
imprisonment and 100’s of historical cases can be found at 
http://www.hse.gov.uk/prosecutions/default.asp

Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: Regan Arndt 
Sent: 01 November 2018 23:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

Hi Pete. Yes, it's a sad state of affairs. Our profession needs to do more or 
something different to turn this around.

I wish AdCo could release where these products originated from so we can focus 
our attention on improvements in these regions.

Anybody know of some examples of penalties/fines that have occurred recently?

I'm also surprised there was no cross-border market surveillance of just LVD or 
Machinery.   It appears they are just cherry picking the high profile 
products/categories.

On Thu, Nov 1, 2018 at 9:01 AM Pete Perkins 
mailto:peperkin...@cs.com>> wrote:
Regan,  Thanx for chasing down these statistics; very 
interesting.  For most of the folks on this forum the most interesting are the 
technical non-conformity issues.  The best/lowest is 14% for EMC and higher 
24%/25% for safety/radio.  Doesn’t speak well for our profession and influence 
on industry.  Yes, there are many others but most of them are Technical File 
paperwork issues.

:>) 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: Regan Arndt mailto:reganar...@gmail.com>>
Sent: Wednesday, October 31, 2018 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

Thanks Charlie. I checked the latest on the RED. Below is an excerpt on the 
stats. Amazing. Wonder what the penalties were. h..

ADCO RED report to TCAM WG on market surveillance statistics for 2016

2. Results for 2016
Totally, 13,488 R equipment has been inspected by 25 market surveillance 
authorities in 2016: Austria, Cyprus, Denmark, Estonia, Finland, France, 
Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, Norway, 
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, The 
Netherlands and United Kingdom. About 10391 equipment were been found 
non-compliant to the provisions of the R Directive. However, due to the 
fact that not all provisions were checked by all involved market surveillance 
authorities, the effective amount of non compliant equipment may be higher.

Summary of the results: • Overall : 10391 non compliant equipment (13488 
inspected equipment)

  *   Declaration of conformity : 9372 non compliant DoC (13224 inspected 
equipment)
  *   CE marking : 8307 non complaint CE marking (13371 inspected equipment)
  *   Geographical area for use : 3773 not compliances (11750 inspected 
equipment)
  *   Essential requirements : 579 technical non compliances (of 2131 measured 
equipment)
  *   Safety (art.3.1.a): 116 technical non compliances (of 488 measured 
equipment)
  *   EMC (art 3.1.b.): 84 technical non compliances (of 583 measured equipment)
  *   Radio (art.3.2.) : 434 technical non compliances (of 1755 measured 
equipment)
  *   Technical documentation: 276 non compliances (of 651 inspected equipment)
  *   Test reports: 236 non compliances (of 603 inspected equipment)
  *   Drawings and explanations: 47 non compliances (of 212 inspected equipment)
  *   Other elements: 79 non compliances (of 326 inspected equipment)
Regan

On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham 
mailto:char...@sulisconsultants.com>> wrote:
Regan

Market enforcement reports from the 

Re: [PSES] Resource for info on cities which require field labeling/certification?

[Kevin Robinson]

Lauren,

If the product is NRTL certified, there should be no need to have the product 
Field labeled.  If it is an electrical product used in the workplace, you 
almost certainly need to have the product NRTL certified as that is a Federal 
requirement (there are alternatives to NRTL certification, but they apply only 
to custom made equipment and equipment that no NRTL can certify.

Kevin Robinson

Kevin

From: Lauren Crane 
Sent: Thursday, October 18, 2018 11:15:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Resource for info on cities which require field 
labeling/certification?

Hello All,

I am looking for a consolidated resource indicating which US cities/states 
require “field certification” (a.k.a. “field labeling”) for industrial 
machinery (e.g., to NFPA 79 / UL 1010). Some cities have this information 
prominently on websites, others do not.

I am particularly interested in the city of Albuquerque, but so far, no luck.

Regards,
Lauren Crane
Tokyo Electron

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Re: [PSES] Product Standards for Aircon Systems

[Kevin Robinson]

For the US  safety standards UL 1995 or UL 60335 & UL 60335-2-40

If it is a room air conditioner UL484

Kevin Robinson

On Thu, Jul 19, 2018 at 10:16 AM, Vincent Lee <
08e6c8d35910-dmarc-requ...@ieee.org> wrote:

> Hi John
>
> Good afternoon,
>
> The countries of interest for Aircon Systems are:
>
> 1) USA
> 2) EU
> 3) South East Asia countries
>
> Hope to hear from you soon. Thank alot.
>
> Regards,
> Vincent
>
>
> On Thursday, July 19, 2018, 6:31:37 AM GMT+8, John Woodgate <
> j...@woodjohn.uk> wrote:
>
>
> It helps if you say which countries you are interested in.
>
> John Woodgate OOO-Own Opinions Only
> J M Woodgate and Associates www.woodjohn.uk
> Rayleigh, Essex UK
>
> On 2018-07-18 23:22, Vincent Lee wrote:
>
> Hi all,
>
> Good afternoon,
>
> 1) May I know what are some of the common product safety standards for
> aircon systems ?
>
> 2) May I know what are some of the common energy efficiency standards of 
> aircon
> systems ?
>
> Hope to hear from you soon. Thank you.
>
> Regards, Vincent
> -
> 
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Re: [PSES] What are the OSHA requirements for a NRTL Mark for the following items

[Kevin Robinson]

Leo,

The requirement for NRTL approval comes from Subpart S of the OSH Act
(which begins at 29 CFR 1910.301)
https://www.gpo.gov/fdsys/pkg/CFR-2017-title29-vol5/pdf/CFR-2017-title29-vol5-sec1910-301.pdf


Subpart S applies to all electrical equipment used in the workplace

1910.303 establishes the approval requirements: "  The conductors and
equipment required or permitted by this subpart shall be acceptable only if
approved, as defined in §1910.399"
https://www.gpo.gov/fdsys/pkg/CFR-2017-title29-vol5/pdf/CFR-2017-title29-vol5-sec1910-303.pdf


1910.399 provides the definitions for "Acceptable" and "Approved"
https://www.gpo.gov/fdsys/pkg/CFR-2017-title29-vol5/pdf/CFR-2017-title29-vol5-sec1910-399.pdf
 The definition for "Acceptable" is where the NRTL approval requirements
are mentioned

If you need any more information, feel free to contact me in the office

Kevin Robinson
Director - OTPCA - NRTL Program
robinsion.ke...@dol.gov
202-693-1911

On Thu, Jul 19, 2018 at 3:37 PM, Leo Eisner  wrote:

> A medical device/system (AAM ES 60601-1) & a separate wall power adapter?
>
>  be approved via a NRTL?
>
> Where in 29 CFR or elsewhere is this mandated.  I can’t find a good
> reference and 29 CFR seems very circuitous
>
> Thx,
> [image: photo] Leonard (Leo) Eisner, P.E.
> Principal Consultant, Eisner Safety Consultants
> Phone: (503) 244-6151
> Mobile: (503) 709-8328
> Email: l...@eisnersafety.com
> Website: www.EisnerSafety.com <http://www.eisnersafety.com/>
> <http://www.eisnersafety.com/Industry_News/>
> <http://us.linkedin.com/in/leoeisnersafetyconsultants>
> <http://www.twitter.com/EisnerSafety>
> <http://skype:Eisner_Safety_Consultants/>
> <http://plus.google.com/+LeoEisner>
> <http://www.youtube.com/channel/UC6obaID27sjS-bbk0qv0AmQ>
> *** 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,
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> 
>
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Re: [PSES] Temp rise measurement

[Kevin Robinson]

Specifications can be found here 
https://www.atecorp.com/products/biddle/577500-57j.  Manufacturer ratings 3 
phase at 20A, single phase at 40 A

Lots of places used to rent, where I used to work, we purchased one used, but 
that was 15+ years ago so I don’t recall the price, perhaps $800 -$1000?

Kevin

From: Scott Xe <scott...@gmail.com>
Sent: Wednesday, December 20, 2017 9:18:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Temp rise measurement

Thanks for all helpful replies!  I will look into the alternative method, rise 
of resistance.

Kevin, it sounds your test gear is a simplest method for temperature rise 
measurement.  What is the price range and any restriction?

In addition, is there any method to detect a few turns of winding being 
short-circuited during product life?  It may be due to poor production process 
introducing the damage of enamel insulation of wire in the winding.

Thanks and regards,

Scott

From: Kevin Robinson <kevinrobinso...@gmail.com>
Reply-To: Kevin Robinson <kevinrobinso...@gmail.com>
Date: Wednesday, 20 December 2017 at 3:40 AM
To: <EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Temp rise measurement

I have used a Biddle 57J Energized Winding Resistance Meter.  Connect the motor 
or transformer and you can take  measurements while the device is powered.

Kevin

From: John Woodgate <j...@woodjohn.uk>
Sent: Tuesday, December 19, 2017 1:18:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Temp rise measurement


I made a box with a double-pole, double-throw switch, an appliance toggle 
switch which is inherently break-before-make. This disconnects the supply and 
connects the ohmmeter in about 0.2 seconds. It takes longer to read off the 
resistance!

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2017-12-19 17:55, Ted Eckert wrote:
I’ve used the rise of resistance method without problems. The challenge is 
making the measurement before the windings cool off. The rise of resistance 
method can be more challenging when you have a small winding that doesn’t hold 
heat well. It is practically impossible to make the measurement the instance 
power is removed. You may want to record the resistance over time to see the 
winding cooling off, allowing you to extrapolate back to time zero.

In a previous job, I had a product with a motorized impeller fan. The engineer 
from a NRTL asked me to use thermocouples. When I explained that the winding 
was spinning with the impeller, the engineer finally figured out that 
thermocouples wouldn’t work. It took 60 – 90 seconds to access the terminals on 
the winding from the time power was removed. I measured the resistance and 
recorded every 5 seconds to get enough information to extrapolate back to the 
time when power was removed. The windings were enclosed well enough that they 
were not getting much cooling from the moving air. As such, I did not expect 
that there was overshoot when power was removed and the fan stopped.

Ted Eckert
Microsoft Corporation

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

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Tuesday, December 19, 2017 9:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Temp rise measurement


Yes, there is a much better method. It measures the average temperature of the 
whole winding, rather than the temperature at a particular spot. IEC 62368-1 
incorrectly says that the thermocouple method measures the average temperature. 
You will find it explained in Annex E of IEC 60950-1. Incredibly, both IEC 
60065 and IEC 62368-1 refer to the 'resistance method' without either detailing 
it or providing a cross reference. This is a serious omission.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.woodjohn.uk=02%7C01%7Cted.eckert%40microsoft.com%7Cab807d4d91914046799308d547020132%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636492996306140994=3pJSgrFNNR2ypYnKwhCm4Yj4WBMWXEoLtvD1NJpqU9c%3D=0>

Rayleigh, Essex UK
On 2017-12-19 16:12, Scott Xe wrote:

I will be conducting the temp rise measurements on windings of AC motors for 
electrical appliances such as washing machines, dishwashers, etc.  It said the 
thermal couple method is commonly adopted for safety assessment.  I can 
dismantle the windings and place the couples inside the windings using 
cyanoacrylate adhesive.  However it may change the original shape of windings 
giving non representative measurement result.  Is there any practically 
acceptable solution?



Does the measurement result include the overshoot temperature after the power 
is cut?



Thanks and regards,



Scott



-

---

Re: [PSES] Temp rise measurement

[Kevin Robinson]

I have used a Biddle 57J Energized Winding Resistance Meter.  Connect the motor 
or transformer and you can take  measurements while the device is powered.

Kevin

From: John Woodgate 
Sent: Tuesday, December 19, 2017 1:18:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Temp rise measurement


I made a box with a double-pole, double-throw switch, an appliance toggle 
switch which is inherently break-before-make. This disconnects the supply and 
connects the ohmmeter in about 0.2 seconds. It takes longer to read off the 
resistance!

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

On 2017-12-19 17:55, Ted Eckert wrote:
I’ve used the rise of resistance method without problems. The challenge is 
making the measurement before the windings cool off. The rise of resistance 
method can be more challenging when you have a small winding that doesn’t hold 
heat well. It is practically impossible to make the measurement the instance 
power is removed. You may want to record the resistance over time to see the 
winding cooling off, allowing you to extrapolate back to time zero.

In a previous job, I had a product with a motorized impeller fan. The engineer 
from a NRTL asked me to use thermocouples. When I explained that the winding 
was spinning with the impeller, the engineer finally figured out that 
thermocouples wouldn’t work. It took 60 – 90 seconds to access the terminals on 
the winding from the time power was removed. I measured the resistance and 
recorded every 5 seconds to get enough information to extrapolate back to the 
time when power was removed. The windings were enclosed well enough that they 
were not getting much cooling from the moving air. As such, I did not expect 
that there was overshoot when power was removed and the fan stopped.

Ted Eckert
Microsoft Corporation

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

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Tuesday, December 19, 2017 9:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Temp rise measurement


Yes, there is a much better method. It measures the average temperature of the 
whole winding, rather than the temperature at a particular spot. IEC 62368-1 
incorrectly says that the thermocouple method measures the average temperature. 
You will find it explained in Annex E of IEC 60950-1. Incredibly, both IEC 
60065 and IEC 62368-1 refer to the 'resistance method' without either detailing 
it or providing a cross reference. This is a serious omission.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk

Rayleigh, Essex UK
On 2017-12-19 16:12, Scott Xe wrote:

I will be conducting the temp rise measurements on windings of AC motors for 
electrical appliances such as washing machines, dishwashers, etc.  It said the 
thermal couple method is commonly adopted for safety assessment.  I can 
dismantle the windings and place the couples inside the windings using 
cyanoacrylate adhesive.  However it may change the original shape of windings 
giving non representative measurement result.  Is there any practically 
acceptable solution?



Does the measurement result include the overshoot temperature after the power 
is cut?



Thanks and regards,



Scott



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 can be used for graphics (in well-used formats), large files, etc.



Website:  

Re: [PSES] Hosedown test

[Kevin Robinson]

Ralph is correct, if the lab is NRTL recognized, the work can be done at any of 
the recognized sites listed on the OSHA website (provided they have the 
equipment).

If you have any questions, contact me at my work address.

Kevin Robinson
Director- OSHA NRTL Program
robinson.ke...@dol.gov<mailto:robinson.ke...@dol.gov>
202-693-1911


Kevin
_
From: Ralph McDiarmid 
<ralph.mcdiar...@schneider-electric.com<mailto:ralph.mcdiar...@schneider-electric.com>>
Sent: Wednesday, May 3, 2017 6:39 PM
Subject: Re: [PSES] Hosedown test
To: <emc-pstc@listserv.ieee.org<mailto:emc-pstc@listserv.ieee.org>>


I think if accredited by OSHA, the lab can be located almost anywhere.  For 
example, CSA is an NRTL and they have offices across Canada and in India, ITS 
has offices in China, etc.

https://www.osha.gov/dts/otpca/nrtl/nrtllist.html


Ralph McDiarmid
Product Compliance
Solar Business
Schneider Electric


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Re: [PSES] Which Safety Test Agency Reports are accepted by City of LA Test Lab (please provide text of requirement or code)

[Kevin Robinson]

Hi Leo,

The City of LA maintains an online list of laboratories that can be viewed
here
http://www.ladbs.org/services/core-services/plan-check-permit/product-approval/electrical-test-lab
.

Kevin Robinson

On Wed, Nov 23, 2016 at 2:21 AM, Leo Eisner <l...@eisnersafety.com> wrote:

> Hi All,
>
> I am working with a client that will be installing a pretty big medical
> device in various types of locations across the country and so they want to
> make sure to meet all city and state electrical codes.  From my memory of
> when I used to work at UL many many years ago I remember that City of LA
> has a test lab and they won’t just take anyone’s test reports but they
> I believe accepted some of the NRTL test reports.  Does anyone have any
> info on this detail and also if there is a written requirement or language
> on this specific issue.  A weblink or a reference to a City of LA code or
> similar would be really great to get too.
>
> Thx much,
>
> Leonard (Leo) Eisner, P.E.
> Principal Consultant, Eisner Safety Consultants
> Phone: (503) 244-6151
> Mobile: (503) 709-8328
> Email: l...@eisnersafety.com <l...@eisnersafety.com>
> Website: www.EisnerSafety.com <http://www.eisnersafety.com>
>
>
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>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) <http://www.ieee-pses.org/list.html>
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[PSES] Job opening - OSHA NRTL Program

[Kevin Robinson]

Hello All,

I wanted to share a position opening in OSHA's Nationally Recognized
Testing Laboratory (NRTL) Program as an engineer and laboratory assessor.

The position is located in Washington DC.

Additional details can be found at:
https://www.usajobs.gov/GetJob/ViewDetails/451085800

If you have any questions about what the position entails, please let me
know, however, DO NOT send resumes or salary inquiries to me as it can
disqualify you from consideration.

Kevin Robinson

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[PSES] Measurement Accuracy

[Kevin Robinson]

I was wondering if anyone was aware of any guidance documents that provided
acceptable levels of uncertainty when conducting various tests.  The
specific measurement that I am interested in this case is temperature
measurements, but I would be interested in seeing other guidance for other
measurements as well (voltage, current, force etc.)

I know the IECEE has published a CTL decision sheet on equipment accuracy,
but I was wondering if there was other industry guidance available.

I have a situation where a product was subjected to a temperature test
three times by three different individuals using the same test equipment,
and the delta in some instances was nearly 12 degrees C (53.3 - 64.8) for
the same component.  Just looking for some additional guidance documents or
standards that would help me convince the powers that be that such errors
are unacceptable.

Kevin Robinson

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Re: [PSES] Spark Ignition Source

[Kevin Robinson]

A common source used for calibration of the spark test chamber for intrinsic 
safety testing is a 95 mH air core inductor connected to a 24vDC source with 
current limiting that is adjusted based on the gas group you are using.  

Kevin Robinson




On Tue, Aug 16, 2016 at 7:57 PM -0400, "Doug Powell" <doug...@gmail.com> wrote:










All,
I am looking for a supplier of electrical spark ignition sources used in 
flammable vapor or dust testing.  It needs to have a calibrated energy level 
and be able to provide two sparks per second with sufficient energy to ignite 
natural gas.  Any help is much appreciated.
All the best, Doug


-- 

Douglas E Powell

doug...@gmail.com
http://www.linkedin.com/in/dougp01


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Re: [PSES] Safety requirements in US

[Kevin Robinson]

Scott,

>>> What about OSHA? Is it applicable too or to certain product categories
only?

OSHA NRTL approval requirements apply to ALL electrical equipment as well
as some non electrical equipment
https://www.osha.gov/dts/otpca/nrtl/prodcatg.html

Most local AHJs, and most retailers also want NRTL approval even though
legally NRTL approval may not be required.

Kevin Robinson

On Sun, Jul 24, 2016 at 1:18 AM, Scott Xe <scott...@gmail.com> wrote:

> Hi Rich,
>
>
>
> Thanks for your advice!  For consumer and household products, compliance
> with CPSC requirements is required.  What about OSHA? Is it applicable too
> or to certain product categories only?
>
>
>
> Scott
>
>
>
>
>
>
>
>
>
> *From: *Richard Nute <ri...@ieee.org>
> *Reply-To: *<ri...@ieee.org>
> *Date: *Sunday, 24 July 2016 at 4:02 AM
> *To: *Raymond Li <scott...@gmail.com>, <EMC-PSTC@LISTSERV.IEEE.ORG>
> *Subject: *RE: [PSES] Safety requirements in US
>
>
>
>
>
> Within EU, most of electrical products are covered by LVD and GPSD.  In
> US, which body, law and standards are responsible for the similar
> regulatory?
>
>
>
> In the USA, we have a number of entities that oversee electrical safety:
>
>
>
> AHJ, enforcing the local (state, county, or city) electrical code
> (certification and construction) for all local installations.
>
> OSHA (federal), which governs workplace safety by requiring electrical
> equipment to be NRTL.
>
> CPSC (federal), which maintains a list of substantial product hazards
> which must comply with a safety standard, and which orders recalls of
> “dangerous” products (after incidents).
>
> FDA (federal), which governs medical electrical equipment.
>
>
>
> There may be others.
>
>
>
>
>
> Rich
>
>
>
>
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to 
> 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/
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>
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>

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Re: [PSES] Safety requirements in US

[Kevin Robinson]

Scott, 
In the US, the regulations rounds on the type of product and where it will be 
used.  For example:
If the product will be used in the workplace then Osha NRTL regs apply. 
If the product will be used in the home or around schools, then CPSC regs 
apply. 
If the product is a medical device then FDA regs apply
Most products fall under multiple regulators as for example, a hospital is both 
a medical space as well as a workplace.  Thankfully, most us regulations 
reference voluntary consensus standards so one round of testing will often 
satisfy all safety regulators. 
Kevin Robinson
Get Outlook for iOS

_
From: Scott Xe <scott...@gmail.com>
Sent: Saturday, July 23, 2016 1:30 AM
Subject: [PSES] Safety requirements in US
To:  <emc-pstc@listserv.ieee.org>




Within EU, most of electrical products are covered by LVD and GPSD.  In US, 
which body, law and standards are responsible for the similar regulatory?-



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[PSES] Job announcement

[Kevin Robinson]

Hello all
I wanted to make you aware of a job opening at OSHA in the NRTL program office 
for an electrical engineer and auditor.  
The announcement can be found here. 
https://www.usajobs.gov/GetJob/ViewDetails/445451700. 
Kevin Robinson

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Re: [PSES] For Your Information NRTL Directive Draft and Comment

[Kevin Robinson]

Hi Brian,

You are correct that the NRTL Directive is 17025/17065 with "national
differences".  I am glad that was obvious in the first read as that was the
approach that we were trying to take.

I should have stated that the draft version of the NRTL directive is the
latest iteration of a document that was published almost 20 years ago
(loosely based off of Guide 25 & Guide 65).  The goal with this revision
was to "translate" existing OSHA policy into the common ISO 17025/17065
language that most of us speak as well as to add some clarity to some areas
that were previously ambiguous.  Our goal was not to make too many
significant changes.  More significant changes will be introduced in future
updates over the next several years

The Directive establishes the minimum performance standards that an NRTL
must meet in a given area, I would say that all of the current NRTLs exceed
these minimum standards in one or more areas.  Having worked for an NRTL,
and now working for the NRTL Program at OSHA I can say that the assessments
we conduct are probably one of the most technical assessments that a
laboratory will likely ever undergo, and I suspect that is the reason for
the high level of scrutiny that the NRTLs give to manufacturers and other
3rd party test labs.  I would say that we would lean more towards the
"authoritative source" rather that meeting only the basic ISO
requirements.  If we don't have a lot of clarity in certain areas, we are
likely working on the text for a future update  (Staff training and
qualification is one of those areas that we are looking hard at for future
updates).

"Recognition" is going to be roughly equivalent to "Accreditation"
throughout the document.   Looks like we have another definition to write.


Kevin

if you (or anyone) has any questions, feel free to contact me through my
"Official" channels:

Kevin Robinson
Director - Office of Technical Programs and Coordination Activities
NRTL Program
202-693-1911
robinson.ke...@dol.gov
or
nrtlprog...@dol.gov



On Thu, Jun 9, 2016 at 7:50 PM, Brian O'Connell <oconne...@tamuracorp.com>
wrote:

> Nothing that follows necessarily represents the opinions or policies of my
> employer or my dog; and certainly not my cat. Did a quick browse (ok, not
> so quick - took several hours for the transformer temp to stabilize). But
> will have to clear with senior management before more of my
> thought-provoking, insightful (?) comments are formally submitted. But need
> to understand some things before these deep and meaningful thoughts are
> forwarded for the entertainment of the U.S. OSHA.
>
> Appears that intent is to adopt/harmonize with ISO17025 and 17065 but with
> 'national differences'. This is a good base-line for writing administrative
> law, but is effectively less demanding in both personnel competence and
> test equipment traceability and control (annex A) than that of some NRTLs
> that have audited my humble company lab.
>
> Does OSHA want an NRTL to be an authoritative source, or only
> representative of the basic requirements per IEC/ISO?
>
> The term "Recognized" is defined per the physical site, but the text also
> uses 'recognition' in the general sense for the company's personnel and
> labs. Is this intended to be same or something other than the "Accredited"
> definition in annex C?
>
> R/S,
> Brian
>
> From: Kevin Robinson [mailto:kevinrobinso...@gmail.com]
> Sent: Thursday, June 09, 2016 2:10 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] For Your Information NRTL Directive Draft and Comment
>
> Hello All,
>
> I wanted to advise you that the Draft NRTL Program Directive has been
> published on the OSHA website for public comment.  We encourage you all to
> review the draft directive and to submit any questions, comments, revisions
> or concerns you may have to OSHA.
>
> In previous communications OSHA indicated that the Directive would be
> published in the Federal Register for comments.  Due to some complications
> in that process, and in the interest in sharing the draft Directive with
> you as soon as possible, we will not be publishing the Directive in or
> seeking comments through the Federal Register.
>
> Please submit your comments no later than 11:59pm Eastern Time  Tuesday
> August 9, 2016
>
> To submit via email, send comments to nrtlprog...@dol.gov  Please title
> your submissions as “NRTL Directive Comment” .
>
> To submit in hard copy, please use the following address:
>
> OSHA
> NRTL Program
> Office of Technical Programs and Coordination Activities
> 200 Constitution Avenue NW, Room N3653
> Washington, DC 20210
>
> *** Please note, comments sent via U.S. Mail may take an additional ten
> days to be received due to security screenin

[PSES] For Your Information NRTL Directive Draft and Comment

[Kevin Robinson]

Hello All,


I wanted to advise you that the Draft NRTL Program Directive has been
published on the OSHA website for public comment.  We encourage you all to
review the draft directive and to submit any questions, comments, revisions
or concerns you may have to OSHA.



In previous communications OSHA indicated that the Directive would be
published in the Federal Register for comments.  Due to some complications
in that process, and in the interest in sharing the draft Directive with
you as soon as possible, *we will not be publishing the Directive in or
seeking comments through the Federal Register.*



*Please submit your comments no later than 11:59pm Eastern Time  Tuesday
August 9, 2016*



To submit via email, send comments to nrtlprog...@dol.gov
  Please title your
submissions as “NRTL Directive Comment” .



To submit in hard copy, please use the following address:



OSHA

NRTL Program

Office of Technical Programs and Coordination Activities

200 Constitution Avenue NW, Room N3653

Washington, DC 20210



*** Please note, comments sent via U.S. Mail may take an additional ten
days to be received due to security screening procedures.***



To submit comments via fax, please send comments to 202-693-1644.





Draft NRTL Directive:
http://www.osha.gov/dts/otpca/nrtl/nrtl_draftdirective_public_comment.pdf



Additional information, including a list of Frequently Asked Questions may
be found at: http://www.osha.gov/dts/otpca/nrtl/nrtlnews.html

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Re: [PSES] Meet some of the list admins at the PSES Symposium next week

[Kevin Robinson]

While not specifically what was originally asked, I was able to locate some
data specifically on Product Safety rates of compliance.

Back in 2008 OSHA (where I was at the time and currently am employed)
published a Request for information  on Supplier's Declaration of
Conformity.  OSHA received 73 comments from the public, many of which
provided data to support their position (for or against SDoC).  You can
view the entire docket here
https://www.regulations.gov/#!docketDetail;D=OSHA-2008-0032

I'll make a general statement to point out that critics on both sides of
this issue have questioned the data and its accuracy/independence/bias, so
with that, I will let you draw your own conclusions:

UL Study on the rate of compliance of Field evaluated products
https://www.regulations.gov/#!documentDetail;D=OSHA-2008-0032-0073.  The
results are only for field evaluations (not full certifications), but they
found 81% with issues.  A large portion were deficient markings, but 20-30%
had potential fire or electric shock hazards.

American Council of Independent Laboratories (ACIL) found the rate of non
compliance to be between 47-51%, and for some products, as high as 80% non
compliance
https://www.regulations.gov/#!documentDetail;D=OSHA-2008-0032-0037

Study by the European Commission on Luminaires that were available for sale
in the EU .
https://www.regulations.gov/#!documentDetail;D=OSHA-2008-0032-0011
They tested 226 luminaires.  162 had 1 or more technical requirements fail.
 74 had severe deficiencies, 43 had moderate deficiencies.  11 (out of 226)
were fully compliant.  Page 17-18 of this report has a breakdown of the
violations

OSHA's summary and analysis of all of the data and comments are available
here https://www.regulations.gov/#!documentDetail;D=OSHA-2008-0032-0099

Many other commenters provided data, most of it from memory was similar.
The above are just comments that I recall as specifically having data.

Kevin Robinson



On Tue, May 10, 2016 at 10:55 PM, Jim Bacher <j.bac...@ieee.org> wrote:

> John, for EMC (and safety) most of the labs do not want to provide details
> as to what the failures were. One lab that does both safety and EMC,
> happened to mention that the 90% rule applied to safety as well as EMC, but
> would no discuss details, nor do they want me to mention their name. It
> points out we need to do a better job in the development stage of
> products..
>
> On EMC I can provide a little better detail as one of the labs found my
> comments about failure rates interesting and stared tracking the rates. I
> mentioned it as part of a general conversation about a experience at a EMC
> lab back when the CE mark first started. I had taken 3 products to a lab to
> have them generate the EMC reports for Europe. They did the radiated
> emissions first. As the products had been previously tested to FCC Class A
> they did not have issues with radiated emissions. Then we went to the RF
> susceptibility tests. About half way through the first units test the
> technician stopped the tests and started playing with his equipment. He
> seemed flustered so I ask what was up. He said that there had to be
> something wrong with the equipment. I ask him why he through that and he
> said they had never had a product pass that far in to the testing on the
> first trip to the lab. So I told him I would have been surprised it it had
> failed. I got a weird look from him, so he went in and talked to others,
> came back out and finished the tests. All three products passed with no
> changes, so I broke their streak. After that I always asked the person
> running the tests what percentage they felt passed on the first trip. They
> were just guessing but gave very low numbers. I have used a number of
> different labs and they all responded about the same. The information from
> John is a little old, so by now he likely would have more significant
> numbers.
>
> Here is what John Barnes gave me to use in my presentation on EMC:
>
> I've (John Barnes)  been doing an informal study of dBi's first-try pass
> rates for over 3 years now, and it is still incomplete.  But having
> electromagnetic-compatibility (EMC)/ electromagnetic interference (EMI)/
> electrostatic discharge (ESD) tested over 360 products since February 2002,
> my gut feel is that:
>
> About 5 to 10% of the 323 products brought to us for official testing
> passed with no changes.
> *  About 45-50% passed with only minor changes-- and we completed the
> testing on the first try, within our budgetary estimate.
> *  About 45-50% passed after major changes, which sometimes took 6+ months
> to complete.  Changes to printed circuit boards are especially painful and
> costly!
>
>
> I would guess the same percentages are probably true for safety such as 45
> - 50 % had minor issues.
>
>
>
> Jim

Re: [PSES] UL Certification status of a re-sold UPS

[Kevin Robinson]

Hello Lauren,

OSHA issued a Safety and Health Information Bulletin (SHIB) on a similar
topic dealing with resold/refurbished equipment
http://www.osha.gov/dts/shib/shib021610.html

Assuming there have been no modifications made to the equipment and it
appears to be as it was when it left the factory, the product certification
would still be acceptable to OSHA.  If modifications were made to the
product, the certification may be void.

In either case, depending on how old the product is, there may have been
significant updates to the test standard that may have addressed
significant deficiencies in the standard or updated the standard to comply
with the applicable electric code, so it may be best to replace the device
completely.

Kevin Robinson
robinson.ke...@dol.gov
202-693-1911



On Thu, Mar 17, 2016 at 3:43 PM, Crane, Lauren <lauren.cr...@kla-tencor.com>
wrote:

> Hello all,
>
>
>
> I am looking for some insight on how to understand the certification
> status of a UPS that was originally UL Certified but is being resold after
> having spent some time with another owner.
>
>
>
> I see in the UL YEDU.GuideInfo for Uninterruptible Power-supply Equipment
> a paragraph which says…
>
>
>
> *REBUILT PRODUCTS*
>
> This category also covers UPS equipment that is rebuilt by the original
> manufacturer or another party having the necessary facilities, technical
>
> knowledge and manufacturing skills. Rebuilt UPS equipment is rebuilt to
> the extent necessary by disassembly and reassembly using new or
>
> reconditioned parts. Rebuilt UPS equipment is subject to the same
> requirements as new UPS equipment.
>
>
>
> I think my basic question is – if an item is bought used and it bears a
> proper certification mark, should one consider it still certified? Or, does
> certification only extend to the first user, and if resold an item must be
> re-inspected to the original criteria and “certified again”?
>
>
>
> I think there is a difference between “re-sold” and “rebuilt”, but I’m not
> quite sure what the details must be.
>
>
>
>
>
> Lauren Crane
>
> KLA-Tencor
>
>
> -
> 
>
> 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
>
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>
> Attachments are not permitted but the IEEE PSES Online Communities site at
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Re: [PSES] Acceptance of CB EMC Test Reports and Certificates

[Kevin Robinson]

The most concise information I have found is available at 
http://members.iecee.org/iecee/ieceemembers.nsf/ACRFList?readform. Select your 
country, scheme and certification body and download their response which will 
advise of the regulatory requirements and whether they will accept your CB 
report. 


Kevin Robinson 

> On Nov 2, 2015, at 7:59 PM, Grace Lin <graceli...@gmail.com> wrote:
> 
> Dear Members,
> 
> I am curious to learn the acceptance (value) of CB EMC test reports and 
> certificates by the (government) regulatory agencies.
> 
> Is there any regulatory agencies accept CB EMC test reports and certificates 
> (without additional evaluation and testing)?  Countries interested are China, 
> Japan, Korea, Malaysia, Mexico, and Singapore.
> 
> In the US, for unintentional radiators, FCC accepts test reports per 47CFR 
> Part 15 Subpart B (not CCISPR 22, etc.).  In EU, a DoC with appropriate 
> directive(s) supported by test reports works (no need for a CB one).
> 
> Thank you very much for your time and I look forward to hearing from you.
> 
> Best regards,
> Grace
> 
> -
> 
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> <emc-p...@ieee.org>
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Re: [PSES] OSHA and UL60974-1 Engine Driven Arc Welders

[Kevin Robinson]

Hi John,

My name is Kevin Robinson, and I am the Director of the office that
administers the NRTL Program for OSHA.  While this response is not an
"official" response from OSHA (as I am sending it from my personal
account), I would say the same thing if you were to contact me at work (
robinson.ke...@dol.gov).

Before I answer your question, I would like to help set the stage a bit.
The NRTL Program was created by OSHA and for OSHA.  OSHA NRTL Approval
requirements while adopted by many state and local AHJs do not officially
travel down to that level.  Whether an AHJ would accept a certification is
really up to that AHJ.  Additionally, only certain types of equipment (
http://www.osha.gov/dts/otpca/nrtl/prodcatg.html) are required by OSHA
regulations to be "acceptable" (certified by an  NRTL).  You will notice
that engine driven arc welders do not appear on the list of products
requiring NRTL approval, therefore, NRTL approval is not required to
satisfy OSHA (but your local AHJ may require some independent
certification).

With that said, any organization recognized by OSHA as an NRTL can
evaluate, test and certify equipment that is not on their NRTL scope and
issue a certification, however, if the standard is not in their NRTL scope
of recognition (http://www.osha.gov/dts/otpca/nrtl/nrtllist.html) then they
may not represent themselves as an NRTL (either in the quotation,
contracts, but most importantly, on the certification mark that they
authorize you to apply to your product.  If an organization recognized by
OSHA as an NRTL were to test and certify a product outside their NRTL scope
that would be fine.  An AHJ may accept that certification, but the
certification would NOT be acceptable to OSHA (assuming NRTL certification
was even required).

If you have any additional questions, feel free to contact me directly.

Kevin Robinson
202-693-1911
robinson.ke...@dol.gov



On Thu, Oct 8, 2015 at 2:54 PM, John Allen <jral...@productsafetyinc.com>
wrote:

> Hi guys,
>
>
> Question on the subject -
>
> UL60974-1 (Engine Driven Arc Welders) is not on the OSHA list of
> "Appropriate Test Standards".  UL551 (Transformer Arc Welders) is on the
> list.  No NRTLs have UL60974-1 coverage by OSHA.  Can we still use
> UL60974-1 for USA Certification?
>
> Our issue is that UL551 does not cover our product - an Engine Driven Arc
> Welder.
>
> Stated another way, if a Standard is not on the "Appropriate Test
> Standard" list, and no NRTLs have OSHA coverage for it, can we still
> Certify to it and have it be accepted by OSHA or any AHJ?
>
> Thanks,
>
> John
> -
> 
>
> 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
>
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>
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>
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Re: [PSES] FW: [PSES] PSES Symposium 2016 - Compliance 101 Track

[Kevin Robinson]

About 10-15 years ago, there was an advertising video for a Bapco Safety 
Analyzer that was making the rounds. As I recall the President of the company 
said he had all of his sales engineers experience what high leakage current 
felt like by having them hold on to the bare conductors of a circuit he 
designed and he walked through sensing the current, experiencing pain, and let 
go current. 

I would love to see that video again. 

Kevin Robinson

 On Aug 24, 2015, at 11:32 AM, Pete Perkins 
 0061f3f32d0c-dmarc-requ...@ieee.org wrote:
 
 John, et al,
 
Well, no demonstration... Looked into it several years ago and the
 IEEE didn't want to cover the liability for such.  Too, bad, I've always
 felt that EE product folks should always know what allowable electric shock
 feels like.  But I do get to describe my own reaction to electric shock (bus
 not as satisfying for the audience).  
 
 :) br, Pete
 
 Peter E Perkins, PE
 Principal Product Safety Engineer
 PO Box 23427
 Tigard, ORe  97281-3427
 
 503/452-1201 fone/fax
 p.perk...@ieee.org
 
 
 -Original Message-
 From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
 Sent: Sunday, August 23, 2015 11:14 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] PSES Symposium 2016 - Compliance 101 Track
 
 In message 001801d0de2a$ab67e590$0237b0b0$@cs.com, dated Sun, 23 Aug 2015,
 Pete Perkins 0061f3f32d0c-dmarc-requ...@ieee.org writes:
 
I did the Electric Shock for Dummies pitch last year and had a great 
 group attending.  I?m willing to do it again this year, building on 
 last years session with some improvements.
 
 With demonstrations? (;-)
 --
 OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I
 turn my back on the sun, it's to look for a rainbow John Woodgate, J M
 Woodgate and Associates, Rayleigh, Essex UK
 
 -
 
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Re: [PSES] CB Philosophy Questions

[Kevin Robinson]

All,

You may want to reach out to the National Committee in your Country, For
the US National Committee (USNC), the best point of contact would be Joel
Solis at NEMA who serves as the Secretary.  They might be able to bring
this up at a future CB Scheme meeting and encourage all countries to
establish similar guidelines for mentioning alternate components in CB
reports.

Brian is correct about the NRTL Program removing component standards from
its list of appropriate test standards.  The NRTL Program was never
intended to include components as it only applies to end products used in
the workplace, but over the years, some predominantly component standards
were added to the list, and OSHA is in the process of removing those
standards. That said, NRTLs will still be allowed to accept component
certifications from others when evaluating end products.


Kevin Robinson
a.k.a The OSHA NRTL Director Guy :-)
robinson.ke...@dol.gov

On Thu, Apr 30, 2015 at 9:21 PM, Brian Oconnell oconne...@tamuracorp.com
wrote:

 Doug,

 Thanks, will look for this stuff. The only stuff seen to date for
 component evaluation is in UL PAGs, CSA informs, and the IECEE CTL stuff.
 Are these component acceptance 'guides' part of the National Differences in
 a TRF, or regulatory law administered by the state?

 According to the OSHA guy that is the NRTL program director, they are in
 process of removing component standards from their official listing (do a
 search on the EMC-PSTC listserv archives for his comments).

 Do not understand Having a CB report is not a foregone guarantee that it
 will always be accepted. Do you mean that the TRF was rejected because of
 poor component descriptions, or that changes to the C/C table in the TRF
 was rejected, or something else?

 Brian

 -Original Message-
 From: dougp01 [mailto:doug...@gmail.com]
 Sent: Thursday, April 30, 2015 5:53 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] CB Philosophy Questions

 Brian

 I suggest you reference the IECEE website and read through the component
 acceptance requirements for each target country, including the USA. I
 haven't checked but there may also be such a document for the -2-29 you
 mention.  These can be found in the same general area as the national
 differences documents. Both are interesting reading.   If you are not able
 to access these contact your certifying agency and they should be willing
 to supply copies.

 As for what is typical in each country, I have learned that this is
 variable. In general the office tasked with reviewing and accepting your CB
 report‎ definitely feels they have the authority to do as they please. And
 to a large extent this is true.   Having a CB report is not a foregone
 guarantee that it will always be accepted.

 ‎Regards, - doug

 Douglas Powell
 http://www.linkedin.com/in/dougp01
   Original Message
 From: Brian Oconnell‎
 Sent: Thursday, April 30, 2015 6:39 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Reply To: Brian Oconnell
 Subject: Re: [PSES] CB Philosophy Questions

 In both procedural controls and scoped test standards, North America
 (NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar
 where state-enforced codes do not contradict the scoped standard.

 It has been several years since the NRTLs and other test agencies have
 routinely accepted a blanket 'equivalent' in the C/C table of submitted
 reports for all components. Typically stuff such as components that not
 across mains, or are not bridging insulation or a safety boundary can be
 cited in general terms with no particular mfr name or part no.

 The issue is that the agency assessment engineer cannot be certain which
 characteristics of a component are important to something on the C/C table.
 So they test your box with the assumption that the design team has verified
 performance only for the particular combination of stuff on the BoM and the
 board layout that was submitted for assessment.

 The other issue is that there is no formal IEC or SCC or OSHA standard or
 regulation that defines how to assess an equivalent component, or whom in
 the company shall be the qualified signatory for equivalent item approval
 (exceptions for programs such as CSA cat cert and others).

 Do not agree with much of the shenanigans employed by the various agencies
 to effectively control market share through pseudo-engineering principles,
 but do agree in principle with the reductions in 'equivalent' components
 allowed on the critical component table.

 Brian


 From: Brian Ceresney [mailto:bceres...@delta-q.com]
 Sent: Thursday, April 30, 2015 4:09 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: [PSES] CB Philosophy Questions

 Greetings, Compliance Experts,

 I'm finding myself in a curious situation, and wondering if you have had
 similar experiences, and may have some advice to share.
 We are in the process of using a CB report for an industrial battery
 charger( to IEC60335-2-29) to obtain an in-country certification in an
 Asian

Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?

[Kevin Robinson]

OSHA Conducted a Request for Information (RFI) back in 2008 that compared
the effectiveness and overall costs of SDoC vs 3rd Party Conformity
assessment, the full summary report can be found here
http://www.regulations.gov/#!documentDetail;D=OSHA-2008-0032-0099 .  While
there was no clean data (products that were purely SDoC vs products that
were purely 3rd party) available to draw firm conclusions, some of the
findings were interesting:


   - Recorded injuries from electrical equipment were double (per 100,000
   workers) in the EU vs the US
   - A European study found that 58% of extension cords that were available
   for sale in the EU were sufficiently unsafe to justify a sales ban/product
   recall
   - In the 2008 RFI, OSHA estimated that implementing an SDoC system in
   the U.S. could cost the Agency approximately $360 million annually. In
   contrast, the current budget associated with operating the NRTL Program is
   approximately $1 million per year. Based on this estimate, operating an
   effective SDoC program would require OSHA to incur substantial additional
   costs. OSHA's current budget for all of its operations is about $558
   million. Thus, based on OSHA's estimate, adopting an SDoC system would
   increase OSHA's entire current budget by more than 150%.


Kevin Robinson


On Fri, Feb 20, 2015 at 5:36 PM, McDiarmid, Ralph 
ralph.mcdiar...@schneider-electric.com wrote:

 I'm drifting ever so slightly off topic now but . . .

 legislation certainly keeps NRTLs in business.   I've long admired the EU
 model, where manufactures declare compliance and are responsible for it.
 Do we really need 3rd party certification in USA, Canada, Australia, etc?
   I think the new approach directives and CE mark in Europe is working.

 ___

 * Ralph McDiarmid*  |  * Schneider Electric **  |  Solar Business*  |
 *CANADA*  |   *Regulatory Compliance Engineering*





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Re: [PSES] OSHA NRTL lists

[Kevin Robinson]

Hi Brian,

I am currently serving as the Acting Director of OSHA's NRTL Program, and
the list available on the OSHA website
https://www.osha.gov/dts/otpca/nrtl/list_standards.html is current.  There
is a current proposal to add and remove several standards from this list
http://www.regulations.gov/#!documentDetail;D=OSHA-2013-0012-0011 but until
we are able to publish a Final Federal Register notice (currently
undergoing review) the list is current.

Just a note about the list of appropriate test standards, the process of
adding new standards to the list is largely driven by requests from NRTLs
manufacturers and trade groups.  Any group or individual can ask OSHA to
consider adding a new standard to the list (easiest way is to email
nrtlprog...@dol.gov) and we will take the request under consideration
during our periodic review of standards.

If you have any additional questions, feel free to contact me at:

robinson.ke...@dol.gov or 202-693-1911

Kevin Robinson

On Wed, Feb 4, 2015 at 2:27 PM, Brian Oconnell oconne...@tamuracorp.com
wrote:

 Can the Recognized Testing Standards lists on the OSHA (NRTL) web site be
 considered current ?

 If not, what is the canonical and authoritative listing for each
 recognized NRTL?

 Thanks,
 Brian

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Re: [PSES] Certification of Unique Equipment

[Kevin Robinson]

Hi Rick,

I work in the office that administer's OSHA's NRTL Program, so my answer
will be focused exclusively on product safety of equipment intended for use
in a U.S. workplace.

OSHA only has regulatory authority over employers, so from OSHA's
perspective, you as an equipment manufacturer have no legal requirement to
have your equipment tested or certified.  The employer (your customers)
have the legal requirement to demonstrate to OSHA that the equipment is
Acceptable as defined in 29 CFR 1910.399
http://www.gpo.gov/fdsys/pkg/CFR-2014-title29-vol5/pdf/CFR-2014-title29-vol5-sec1910-399.pdf
which reads:

Acceptable. An installation or equipment is acceptable to the Assistant
Secretary of Labor, and approved within the meaning of this subpart S:
(1) If it is accepted, or certified, or listed, or labeled, or otherwise
determined to be safe by a nationally recognized testing laboratory
recognized pursuant to §1910.7; or
(2) With respect to an installation or equipment of a kind that no
nationally recognized testing laboratory accepts, certifies, lists, labels,
or determines to be safe, if it is inspected or tested by
another Federal agency, or by a State, municipal, or other local authority
responsible for enforcing occupational safety provisions of the National
Electrical Code, and found in compliance
with the provisions of the National Electrical Code as applied in this
subpart;
or
(3) With respect to custom-made equipment or related installations that are
designed, fabricated for, and intended for use by a particular customer, if
it is determined to be safe for its intended use by its manufacturer on the
basis of test data which the employer keeps and makes available for
inspection to the Assistant Secretary and his authorized representatives.


However, as you are likely aware, most manufacturers take on the burden of
having their products certified to minimize liability, to minimize problems
with local inspectors, and as a selling point to their clients.

One of a kind equipment would fall under item 3 above.  To be acceptable
(to OSHA), you as the manufacturer must evaluate and test the equipment and
provide the data to your customer so they can provide it to OSHA if asked.
While there has been no official interpretation, the general feeling within
OSHA is if you make 1 product, you are fine with option 3 above.  If you
make 2, you now must comply with option 1 above (certified by an NRTL).

Of course, the requirements imposed by a local AHJ may be different, and my
responses do not consider any liability risks.

If you have nay further questions, feel free to contact me at my OSHA
account:

Kevin Robinson
OSHA NRTL Program
robinson.ke...@dol.gov
202-693-1911

On Sun, Dec 14, 2014 at 3:32 PM, Rick Busche rick.bus...@qnergy.com wrote:

  It is always my desire to provide products that are CE Marked for Europe
 and NRTL listed for North America. That said, I continue to find products
 delivered for our own production environment that carry no safety marking
 that I can identify. I have discussed this concern with other engineers who
 worked in previous companies who indicated that they NEVER were required to
 have certification on their products.



 As I understand it I could deliver a one of a kind system to a unique
 customer without certification in North America. At what point is
 certification required? Is it based on the quantity of systems, the
 customer, the AHJ, OSHA or marketing?  Is it allowable to ship a unique,
 prototype system to a specialized customer, without NRTL?



 Thanks



 Rick


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Re: [PSES] NRTL marks

[Kevin Robinson]

Brian,

I am responding from my personal account which is where I monitor the
EMC-PSTC, so this can not serve as an Official Response from OSHA, but if
you would like something, more official, I have included my work e-mail
below.  For the purpose of this discussion, I will keep my comments generic
and not tied to a specific NRTL.  If you wish to discuss the markings of a
specific NRTL, please contact me at one of the e-mail addresses below with
the appropriate details.

The use of what I will call supplemental information around an NRTL's
certification mark became an administrative headache for OSHA late last
year, and it was determined that OSHA would simply include on its website a
sample of the Core certification mark on its website
https://www.osha.gov/dts/otpca/nrtl/nrtlmrk.html .  We then asked NRTLs to
create a web page that described the different variations of its mark and
what each one means.  For example, several NRTLs use a US designation
and/or an NRTL designation or other additional text in conjunction with
their mark.  These clarification web pages can be found by clicking on the
NRTL name that you are interested in at:
https://www.osha.gov/dts/otpca/nrtl/.

If you have any questions about this, or any NRTL related matter, please
contact me directly at:  robinson.ke...@dol.gov or send an e-mail to the
general NRTL Program mail box at: nrtlprog...@dol.gov


Kevin Robinson
(Unofficially in this e-mail) Acting Director
OSHA NRTL Program
202-693-1911


On Mon, Sep 29, 2014 at 3:19 PM, Brian Oconnell oconne...@tamuracorp.com
wrote:

 Good People,

 Per OSHA and 29CFR1910, the images for the various marks shall be
 registered. For the third time, yet another NRTL has mandated a mark change
 where there is no record of the image in the OSHA database for registered
 NRTL marks. Previously, an NRTL has issued a change notice so an ECO was
 issued to update marking labels. After questioning the NRTL about the
 'official' mark, they said never mind, just use the old marks, so we had
 to eat several rolls of useless labels.

 Am at these same cross-roads - agency demanding that I change NRTL mark
 image on labels where there is no official image in the OSHA database.

 Sent a message to OSHA requesting clarification, but no answer. Any ideas
 on what OSHA officials would be appropriate for escalation of this issue?

 Thanks,
 Brian

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Re: [PSES] Battery certification issue

[Kevin Robinson]

I do want to chime in here on a few issues to stop any misconceptions about
the NRTL program.  First a disclaimer, in my former life, I worked for an
NRTL, I now work for OSHA in the office that oversees the NRTL program.

The NRTL Program applies ONLY to end products used in the workplace.  It
does not apply to component power supplies, plastic materials used to make
enclosures, transformers, switches etc. that are used to make up end
products.  OSHA has no authority to regulate components (as they typically
can't be used in the workplace alone), and as a result, components are not
covered under the NRTL Program.  It is true that many organizations
recognized by OSHA as NRTLs do issue certifications on components, however,
they are doing so outside of their NRTL scope of recognition, and OSHA does
not oversee the activities that an organization we recognize does with
respect to components.  A common complaint that I hear is the policies of
some NRTLs as to the acceptance of component recognitions.  As the NRTL
program does not cover components, and OSHA has no authority to require one
NRTL to accept component recognition from another NRTL (that authority lies
with other Federal agencies if the policies are determined to be
anti-competitive).

With that said, OSHA and the NRTL Program do recognize the importance that
component recognitions play in product safety certifications, and we do
allow NRTLs to accept component certifications from another NRTL provided
they can demonstrate that they have reviewed the component certification
documents to ensure that the component is being properly used, and that the
organization that granted the certification had the specific standard in
their NRTL scope.

As for mutual recognition of one NRTL's certification for an end product,
again, OSHA does not have the authority to require one NRTL to accept
certifications from another NRTL.  We do allow this, and we have
established some guidelines if an NRTL does accept certifications from
another NRTL, but we can not require an NRTL to do this.  Fortunately, it
is very rare when an end product certified by NRTL #1 is then submitted to
NRTL #2.


John Tyra was sharing his experiences when working a an NRTL 20 years ago.
 I can say that times have changed.  20 years ago, the NRTL program was
only 5 years old, and the assessors were borrowed from other federal
agencies.  The only guidance that OSHA or NRTLs had was what was written in
the regulations (29 CFR 1910.7) which provides a very high level approach
to the program.  The NRTL Program within OSHA is a very small group (we
currently have a staff of 4 people), 50% of whom are ex-NRTL employees, so
we now have the expertise to dig deeper into the capabilities.  In the late
1990's, OSHA did publish additional guidance for the NRTLs, although, there
has been only minor updates since that time.  I am very happy to say that
we will soon (hopefully this week) be releasing portions of an updated
draft directive (OSHA Policies and procedures) for the NRTL program that
align our requirements with ISO 17025  17065.  On October 22, we will be
holding a stakeholder meeting to discuss which direction to take the
program in the future, and whether those changes will require rule making
which can be a lengthy process.  Some of the topics presented in this
thread will be discussed at this meeting.  While registration for the
meeting has officially closed, we so still have space available for those
who are interested in attending as an observer.  Details on the meeting are
available here: http://www.regulations.gov/#!docketDetail;D=OSHA-2013-0028.
 If you are interested in attending this meeting, please send an e-mail to
nrtlprog...@dol.gov .  Future updates to the program, including the draft
directive will be posted here: https://www.osha.gov/nrtlpi/index.html

If you have any questions, feel free to contact me.

Kevin Robinson
Electrical Engineer  Senior Assessor
OSHA NRTL Program
robinson.ke...@dol.gov
202-693-1911



On Thu, Sep 4, 2014 at 1:15 PM, jral...@productsafetyinc.com 
jral...@productsafetyinc.com wrote:

 Hi Rich,

 Yes, I would agree.  Not sure how or if we'll ever get there, but if an
 NRTL is covered by OSHA for a Standard, all NRTLs should accept their mark
 and not have to repeat any testing.  How do we get there if the Standard
 itself leaves too much room for interpretation??  If all the Standards were
 Hazard Based (I know you'll love this), do we have a chance of getting to
 harmonized interpretations??

 -Original Message-
 From: Richard Nute [mailto:ri...@ieee.org]
 Sent: Thursday, September 04, 2014 12:10 PM
 To: jral...@productsafetyinc.com; EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Battery certification issue



 Hi John:


 On 9/4/2014 8:52 AM, jral...@productsafetyinc.com wrote:
  Is it that NRTLs don't trust each other's data?  Or is the pink elephant
 in the room revenue and market share??
 The issue is revenue (profits).

 If the NRTL

Re: [PSES] Battery certification issue

[Kevin Robinson]

Hi Brian,

You stated : Do not understand the statement that components are not
covered by NRTL program, as the standards list does include component
standards: www.osha.gov/dts/otpca/nrtl/list_standards.html

In short, we know, and we are attempting to clean up that list to remove
standards that should no longer be on there (or ones that never should have
been added to the list that somehow were added).  The first of what will
likely be many Federal Register notices dealing with the list of
appropriate test standards:
http://www.regulations.gov/#!documentDetail;D=OSHA-2013-0012-0004 .  Many
standards that could be considered component only standards do apply in
some instances to end products (ex. motors, transformers etc.).
 Internally, it is a discussion that we have all the time, and we do
receive comments that recommend the addition or deletion of test standards.

Kevin Robinson
Electrical Engineer  Senior Assessor
OSHA NRTL Program
robinson.ke...@dol.gov
202-693-1911


On Thu, Sep 4, 2014 at 4:16 PM, Brian Oconnell oconne...@tamuracorp.com
wrote:

 As previously stated to Mr. Robinson, the industrial compliance
 engineering community very much appreciates his support of our concerns and
 ideas. Good people, this is our chance to provide some relevant industry
 comments. For example, for some product classes the default factory FUS
 audit interval should be no more than twice per year where the site has not
 received any variation notices, and there are no new product classes added
 to production. NRTLs should not be allowed to use the factory audit system
 as a profit center. Many other ideas, so let us write (link in below
 message).

 Do not understand the statement that components are not covered by NRTL
 program, as the standards list does include component standards:
 www.osha.gov/dts/otpca/nrtl/list_standards.html
 Perhaps there are differences in implementation. Note that a few AHJs will
 actually look up a component's 'recognition' to see if the scoped standard
 was on the NRTL list.

 Brian


 From: Kevin Robinson [mailto:kevinrobinso...@gmail.com]
 Sent: Thursday, September 04, 2014 12:15 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Battery certification issue

 I do want to chime in here on a few issues to stop any misconceptions
 about the NRTL program.  First a disclaimer, in my former life, I worked
 for an NRTL, I now work for OSHA in the office that oversees the NRTL
 program.

 The NRTL Program applies ONLY to end products used in the workplace.  It
 does not apply to component power supplies, plastic materials used to make
 enclosures, transformers, switches etc. that are used to make up end
 products.  OSHA has no authority to regulate components (as they typically
 can't be used in the workplace alone), and as a result, components are not
 covered under the NRTL Program.  It is true that many organizations
 recognized by OSHA as NRTLs do issue certifications on components, however,
 they are doing so outside of their NRTL scope of recognition, and OSHA does
 not oversee the activities that an organization we recognize does with
 respect to components.  A common complaint that I hear is the policies of
 some NRTLs as to the acceptance of component recognitions.  As the NRTL
 program does not cover components, and OSHA has no authority to require one
 NRTL to accept component recognition from another NRTL (that authority lies
 with other Federal agencies !
  if the policies are determined to be anti-competitive).

 With that said, OSHA and the NRTL Program do recognize the importance that
 component recognitions play in product safety certifications, and we do
 allow NRTLs to accept component certifications from another NRTL provided
 they can demonstrate that they have reviewed the component certification
 documents to ensure that the component is being properly used, and that the
 organization that granted the certification had the specific standard in
 their NRTL scope.

 As for mutual recognition of one NRTL's certification for an end product,
 again, OSHA does not have the authority to require one NRTL to accept
 certifications from another NRTL.  We do allow this, and we have
 established some guidelines if an NRTL does accept certifications from
 another NRTL, but we can not require an NRTL to do this.  Fortunately, it
 is very rare when an end product certified by NRTL #1 is then submitted to
 NRTL #2.


 John Tyra was sharing his experiences when working a an NRTL 20 years ago.
  I can say that times have changed.  20 years ago, the NRTL program was
 only 5 years old, and the assessors were borrowed from other federal
 agencies.  The only guidance that OSHA or NRTLs had was what was written in
 the regulations (29 CFR 1910.7) which provides a very high level approach
 to the program.  The NRTL Program within OSHA is a very small group (we
 currently have a staff of 4 people), 50% of whom are ex-NRTL employees, so
 we now have the expertise to dig deeper

[PSES] Job Announcement - Electrical Engineer/Assessor

[Kevin Robinson]

Good morning,

I wanted to share a position announcement with the group.  OSHA's
Nationally Recognized Testing Laboratory (NRTL) office is looking to hire
another engineer/laboratory assessor.  Complete details of the position can
be found at this link https://www.usajobs.gov/GetJob/ViewDetails/365080100.
 The announcement closes April 11, 2014, so you have just over 2 weeks left
to apply.

The position will be located in Washington DC, and will require
approximately 25% travel to all parts of the world.  Relocation assistance
is being offered.

I can answer some specific questions about the position, but please DO NOT
send me any resumes, summary of your experience or applications as it can
disqualify you from the application process.

Kevin Robinson
Electrical Engineer/Senior Assessor
OSHA NRTL Program
robinson.ke...@dol.gov
202-693-1911

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Re: [PSES] 3rd party labs due-diligence

[Kevin Robinson]

Full disclosure, I used to work at a test lab, and I now work for a
government regulator that audits test labs.

In most cases, as Richard said, test labs, except for possibly your small
local labs have accreditations from multiple accreditation bodies, all
auditing to some variant of 17025/17065/Guide 65.  This means that the labs
are subject to audits 12 or more times a year.  Now each audit may not
cover the full scope that the laboratory has, but their core QA systems are
generally being reviewed at each audit, and individual sectors (EMC,
Safety, Performance etc.) are typically audited several times a year .
 Their systems are generally pretty tight, and staff have been trained and
audited enough to make sure that they are following their own top level
procedures for the most part.  If you do audit, you might find a deficiency
in corporate level procedures, but most will be relatively minor, and are
attributed to human error/laziness.

I tell people that ask me to visit your lab(s), talk to the engineers and
your account reps.  Ask them about the standards, perhaps pick a few
sections that are confusing to you and ask them to explain them to you.  It
will become very obvious very quickly how knowledgeable they are in the
standards, and if you are new to the world of testing, how well they are
able to take a complex standard and break it down into something that you
can understand.  Take a tour of their facilities.  Try to look past all of
the glitz and focus on the condition of their storage areas and equipment.
 If things are neat and orderly, chances are, they will put the same effort
into clearly and properly recording your test results.  Also consider their
corporate culture.  Is the lab focused on customer service, clearly
explaining things to you every step of the way, or are they extremely
efficient and would prefer to just give you a report with little
communication throughout the testing process.  Find a lab that is a good
fit for your personality and your corporate culture.  As far as conducting
an audit, when you have most labs being audited by ANSI, A2LA, IAS,
NIST/NVLAP, FCC, FDA, OSHA/NRTL, Standards Council of Canada, Industry
Canada, Verizon, ATT, EPA, IECEE/CB Scheme and many others, chances are,
you will not find any significant issues, especially if the lab has been
with the same accreditors for many years.

Kevin Robinson


On Fri, Aug 30, 2013 at 4:39 PM, John Woodgate j...@jmwa.demon.co.uk wrote:

 In message 63E38A5B081437478C77651F3D56C**64f57f4f...@orsmsx102.amr.**
 corp.intel.com63e38a5b081437478c77651f3d56c64f57f4f...@orsmsx102.amr.corp.intel.com,
 dated Fri, 30 Aug 2013, Pettit, Ghery ghery.pet...@intel.com writes:

  I've found cases where the documentation was in good shape, indicating
 that the assessor understood ISO/IEC 17025, but the test setups were wrong,
 indicating that either the assessor didn't understand the EMC standards


 Quite often, I believe. In some cases, they defy understanding!


  or the lab went back to the way they were used to doing the test after
 the assessor left.


 Also quite often. In some cases, they may be right (as well as wrong).

 But I suppose the OP has enough experience to know about those issues.
 What I meant by my apparently facetious response is: 'Unless you have full
 confidence, don't go there'.

 --
 OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
 Why is the stapler always empty just when you want it?

 John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

 -
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[PSES] Position Opening in OSHA's NRTL Program

[Kevin Robinson]

OSHA is currently seeking two experienced electrical engineers to work in
its Nationally Recognized Testing Laboratory (NRTL) program.  The incumbent
would conduct in-depth onsite assessments of national and foreign
laboratories seeking recognition as NRTLs,  conduct in-depth audits of labs
granted recognition as NRTLs to verify continued compliance to these
requirements, work with other staff in developing policies, procedures, and
sound interpretations of OSHA’s electrical safety standards based on
national and international practices for the accreditation of laboratories
or the conduct of assessments and audits to ensure the integrity and
reliability of the NRTL Program in protecting workers and other duties as
described in the position announcement.

Candidates may apply at: *
https://www.usajobs.gov/GetJob/ViewDetails/333708600*https://www.usajobs.gov/GetJob/ViewDetails/333708600or
by searching
www.usajobs.gov for position DE-13-OSHA-41.

If you have any questions about the position or what it entails, feel free
to contact me at *robinson.ke...@dol.gov* robinson.ke...@dol.gov,
however, please DO NOT send resumes or other application information to
this address.

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Mike Cantwell mcantw...@ieee.org

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Jim Bacher:  j.bac...@ieee.org
David Heald: dhe...@gmail.com

Re: [PSES] Product safety requirements

[Kevin Robinson]

If the product powered from a certified SELV, power limited supply will be used 
or installed in a workplace in the US, then it is subject to OSHA NRTL approval 
requirements and the mixer would be required to be certified by an NRTL.  OSHA 
regulations do not provide an exception to the approval requirements based on 
the voltage/current from an external power supply. 

If you have any questions, feel free to contact me directly. 

Kevin Robinson
Engineer  Senior Auditor
OSHA NRTL Program
202-693-1911
robinson.ke...@dol.gov
On Nov 16, 2012, at 7:21 PM, Chuck McDowell chu...@meyersound.com wrote:

 In America, a few years ago at Lucent, we built a DSL device that was 
 remotely powered by a separate power supply with a NEC ANSI/NFPA 70 Class 2 
 DC output. The power supply had a NRTL safety marking, and as you suggest, 
 the DSL device itself did not carry a NRTL safety mark, only EMC and Fcc 
 approval marks.
  
 Chuck McDowell
 Meyer Sound Laboratories Inc.
  
 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Aldous, Scott
 Sent: Friday, November 16, 2012 8:36 AM
 To: Mcburney, Ian; emc-p...@ieee.org
 Subject: RE: Product safety requirements
  
 You would need to make sure that the output of the power supply is a Limited 
 Power Source in order to deal with fire hazards. The nameplate output ratings 
 are necessary but insufficient information to determine if a fire hazard may 
 be present. Also, it is possible that your regulators (maybe just the boost) 
 could produce voltages internally that would be considered a shock hazard, 
 which would require evaluation of the output circuits as SELV. There are a 
 wide variety of DC/DC converters commercially available that have SELV inputs 
 and SELV outputs which nonetheless still have 3rd party safety 
 certifications. You should be able to find a certified one OTS (or multiple 
 converters) that will work for you if you don’t want to deal with the 
 certification piece yourself. Maybe that defeats the purpose of what you are 
 trying to do since you could just as easily find OTS certified AC/DC power 
 supplies.
  
 Technical considerations aside, you could always run into trouble with any 
 given local authority or customs official wanting to see certification on 
 your mixer, not just on the power supply that connects to it or that it ships 
 with.
  
 Also, you should be aware that most notebook power supplies nowadays have 
 more than just the power output pins – they have feedback signals that are 
 intended to keep the supplies in a low power consumption mode when the 
 computer is in the off state in order to comply with various efficiency 
 regulations. If you don’t provide the right signal, you won’t get power out 
 of them.
  
 Scott Aldous
 Compliance Engineer
 AE Solar Energy
  
   +1.970.492.2065 Direct
   +1.970.407.5872 Fax
   +1.541.312.3832 Main
 scott.ald...@aei.com
  
  
 1625 Sharp Point Drive
 Fort Collins, CO 80525
  
 www.advanced-energy.com/solarenergy
  
  
 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Mcburney, Ian
 Sent: Friday, November 16, 2012 8:24 AM
 To: emc-p...@ieee.org
 Subject: Product safety requirements
  
 Dear Colleagues
  
 We are a manufacturer of audio mixing consoles with a range that varies from 
 A4 size up to large 2m long 2 man lift consoles.
 Most have internal ac/dc power supplies.
 We are researching changing the way we power are future products to 
 rationalise the psu range as worldwide approval costs increase.
 One of the options is to purchase 60-80W PC laptop power supplies and power 
 the smaller mixers from the DC output of the external laptop supply.
 The DC output voltage from a laptop PSU is typically 19V. However; most 
 mixers require typically +/-15V, +10V  +48V internal voltage rails.
 We propose to buck regulate the +/-15V and +10V rails  boost the +48V rail 
 from the 19V DC input.
 If the total power consumption of the mixer was no more than 80W and the +48V 
 was current limited to no more than 1 Amp, would the mixer require approval 
 testing for north America or any other country as the input voltage would 
 only be 19V DC.
 Obviously the external ac to dc laptop power supply would have all the 
 necessary approvals; probably to IEC60950 and be class 1 construction.
  
 Your opinions would be appreciated.
  
 Thank you in advance;
  
 Ian McBurney
 Design Engineer
  
 Allen  Heath Ltd
 Kernick Industrial Estate
 Penryn, Cornwall
 TR10 9LU
 United Kingdom
  
 +44 (0)1326 370121
 
 ian.mcbur...@dmh-global.com
 www.allen-heath.com
 A DMH Pro Company.
  
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Re: [PSES] CE Marking Provoqium

[Kevin Robinson]

29CFR1910 applies only to the EMPLOYER and there is no requirement for OSHA 
purposes for a manufacturer to have their product certified by an NRTL before 
marketing it or selling it. The employee using the product however has the 
burden of demonstrating that the product meets the definition of acceptable, 
and for mass produced products, the easiest way for an employer to meet this 
requirement is to purchase NRTL certified equipment. 

CPSC has no requirements for certification of electrical products (unless they 
are considered a toy), however a few years ago CPSC staff recommended that 
electrical products be certified by an NRTL. Most major retailers also want 
NRTL approval on products they sell. While these are not law, if you want to 
sell your product to consumers through major retail outlets, you are almost 
required to have your product certified by an NRTL. 

Kevin Robinson

On Aug 18, 2012, at 2:42 AM, Bill Owsley wdows...@yahoo.com wrote:

 Indeed, when they 47 CFR, provide the schedule for penalties and payments, 
 and collect on these.  it is law.
 But does 29 CFR provide the same for anybody outside of 1910?
 It seems a manufacture falls into the CSPA? where failure to report yourself 
 of getting caught costs a lot... but it is after the fact.
 There is still no before the fact, as in registering radios, and DoC for ITE 
 and verifying other equipment that the FCC has.
 Where does the CFR require an NRTL cert outside of 1910 commercial locations? 
 or even by convoluted path to make a requirement for safety certs by 3rd 
 party labs?  ps. your business will suffer greatly if you don't, but that is 
 a business issue.
 
 
 
 From: Peter Tarver ptar...@ieee.org
 To: eMC-PSTC@LISTSERV.IEEE.ORG 
 Sent: Saturday, August 18, 2012 1:39 AM
 Subject: Re: [PSES] CE Marking Provoqium
 
 Date sent:  Fri, 17 Aug 2012 20:40:49
 From:  Dward dw...@pctestlab.com
  Let's not confuse a CFR with law. While a Code of Federal Regulations may be
  backed up by a law, they are in themselves not law.
 
 While not law in a technical sense, Congress, upon 
 creation the bureaucracies of the Executive Branch,  
 bestowed upon them the authority that any 
 regulations they pass shall have the power of law.
 
 Essentially Congress ceded their power to the 
 Executive agencies they created so Congress could 
 spend their time on more worthy pursuits, such as 
 pointing fingers at one another in front of 
 fawning/deriding press and enriching themselves and 
 their campaign donors.
 
 Peter Tarver
 
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Re: [PSES] OSHA - NRTL audit question

[Kevin Robinson]

OSHA only uses OSHA employees to conduct NRTLaudits and assessments.
The NRTL program does not operate on a peer assessment type of
system.

Kevin Robinson
Lead Auditor - OSHA NRTL Program

On Tue, Jul 3, 2012 at 1:58 PM, Doug Powell doug...@gmail.com wrote:
 Brian,

 NRTLs are under to oversight of OSHA, although I was not aware they would do
 field surveys like this.

 See: http://www.osha.gov/dts/otpca/nrtl/


 --
 Thanks, -doug

 Douglas E Powell
 doug...@gmail.com
 http://www.linkedin.com/in/dougp01



 On Tue, Jul 3, 2012 at 10:55 AM, Brian Oconnell oconne...@tamuracorp.com
 wrote:

 Was at an NRTL/CAB site yesterday. Noted a small group lurking -
 assessment
 engineer said they were part of an OSHA audit team. I recognized one
 member
 of the audit team from another NRTL down the road.

 Does the U.S. OSHA use NRTLs to audit each other?

 Brian

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[PSES] Interview Questions

[Kevin Robinson]

Hello All,

I have recently been tasked with writing a set of questions that job
candidates would need to answer at the same time they apply for a
position requiring  knowledge of product safety evaluation, testing
and practices.  These questions would serve as an automated pre
screening mechanism.  Questions like What does the term creepage
distance mean? would be perfect , however the challenge that I am
facing is finding questions that the answers are not easily found
using Google.  If anyone has any product safety related questions that
they would not mind sharing, I would greatly appreciate it.

Kevin Robinson

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Re: [PSES] Compliance costs too much.

[Kevin Robinson]

Contrasting your story. I used to work at a safety testing laboratory
and one of my clients came in with his product that incorporated a
custom designed power supply. I told him that the custom supply would
add considerable cost and time to the certification project and asked
him why he did not use an off the shelf recognized supply that would
eliminate the need for the expensive evaluation and testing. He said
that they were trying to keep the total product cost below $200 and
the off the shelf supply pushed them over by $0.20. I then told him
that the additional testing would cost him several thousand dollars,
and asked him how many units they intended to manufacture to which he
replied that they were making less than 500 units. When I pointed out
that the certified supply would add only $100 to the production run vs
several thousand for the additional testing he said that he did not
care as compliance costs came from a different budget and were not
considered in the total product cost.


Kevin Robinson


On Mar 30, 2012, at 4:26 PM, Barron, Manny (IS) manny.bar...@ngc.com wrote:

 I used to manage an outside EMI test lab.  About 15 years ago I remember one 
 well known client who needed to pass FCC Class B but his product utilized a 
 plastic case (not metalized nor conductive finish, but fully plastic).  When 
 his product failed he started adding [many] ferrite beads to the culprit 
 internal I/O cable until his product was 10 dB below the limit.  Then he 
 started taking them off one by one until the product was about 2 dB below the 
 limit.  When I inquired why remove the beads and reduce margin his response 
 was cost and that his management would not be pleased with him because he had 
 added cost to the product.

 Just an interesting story.

 Manny Barron
 EMC/EMI Engineer
 Northrop Grumman Corp.
 San Jose, California



 -Original Message-
 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Thomas 
 Cokenias
 Sent: Friday, March 30, 2012 12:24 PM
 To: ri...@ieee.org
 Cc: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: Compliance costs too much.

 I used to work at FCC Lab and they have  ways of getting your attention.  One 
 story as I remember it:

 Back in the mid 80's there was an IBM clone computer company named (I 
 believe)  Columbia Data Products, at the time located in Columbia MD,  They 
 were heavily advertising  their latest computer soon to come on the market, 
 had a warehouse full of product just waiting for the FCC certification 
 process to be completed at the FCC Lab (also in Columbia MD).

 Alas, they failed sample testing several times, and the application was 
 denied.  And they could not come up with a way to retrofit the design, much 
 less the products in the warehouse,  so that they would meet the Part 15 
 limits.

 The FCC issued a non-compliance letter.  The local paper had an article 
 showing the destruction of the warehouse samples, with photo of bulldozers 
 crushing and otherwise rendering useless all the would- be merchandise.  
 Pretty impressive.  I was working in private sector lab when this happened - 
 the article was a great sales tool with customers who  balked at the expense 
 of doing all that testing...

 Tom Cokenias

 T.N. Cokenias Consulting
 P.O. Box 1086
 El Granada CA 94018


 On Mar 29, 2012, at 8:23 PM, Richard Nute wrote:

 I once worked with an EMC engineer who measured the performance of
 himself and his time by the cost of the components that were used in
 the equipment solely for the purpose of EMC control.

 His objective was to reduce the cost of compliance by advising
 designers of careful layout so as to minimize the need for EMC
 components.

 Safety is a bit different because many safety components are also
 functional components.
 Nevertheless, a ground wire can be eliminated if double-insulation is
 employed.  In this example, a cost trade-off between the power cord
 and the extra insulation.  But, these days, most primary circuit
 designs are indeed double-insulated as transformers simply don't use
 internal shields.

 Enclosures... only needed for primary circuits and secondary circuits
 exceeding 30 V.  (Yes, you still want an enclosure, but not for
 safety!)

 Etc.  So, compliance should not cost too much.

 I look forward to your comments on compliance costing too much.


 Rich


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[PSES] Job Opening - Electrical Engineer/NRTL Auditor

[Kevin Robinson]

Hello everyone,

I apologize if this is a repeat message, but I wanted to share a job
posting for an Electrical Engineer with the US Department of Labor's
Occupational Safety and Health Administration (OSHA) working for the
office that administer's the NRTL (Nationally Recognized Testing
Laboratory) Program.

The position is in Washington, DC.

The position announcement can be found at
http://www.usajobs.gov/GetJob/ViewDetails/311868000

Please share this notice with anyone who you believe would be
interested and qualified.

While I can not directly accept resumes or applications, if you do
have any questions about the position, please feel free to contact me
at robinson.ke...@dol.gov

Kevin Robinson
NRTL Program Engineer  Lead Auditor
202-693-1911

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[PSES] Job Opening - Electrical Engineer - OSHA NRTL Program

[Kevin Robinson]

Hello everyone,

I wanted to share a job posting for an Electrical Engineer with the US
Department of Labor's Occupational Safety and Health Administration
(OSHA) working for the office that administer's the NRTL (Nationally
Recognized Testing Laboratory) Program.

The position is in Washington, DC.

The position announcement can be found at
http://www.usajobs.gov/GetJob/ViewDetails/311868000

While I can not directly accept resumes or applications, if you do
have any questions about the position, please feel free to contact me
at robinson.ke...@dol.gov

Kevin Robinson

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Re: [PSES] Is this common knowledge - Electrical Ratings

[Kevin Robinson]

For consumer grade equipment, one might argue that you could do away with
ratings and assume that if you purchase something from you local retailer
it will work in your home, however, for permanently connected equipment and
for more industrial/commercial equipment, I think the need for electrical
ratings is more important, especially in the global society that we now
live in.  Personally, I feel that electrical ratings on the product are
still important.  Do I look at them when I purchase some consumer
electronics from my local retailer, not always, but I do consider the
current/power ratings when deciding where to plug in certain appliances, or
if I do trip a circuit when my daughter is using the curling iron, my wife
is using the hair dryer, and I am ironing a shirt all at the same time.

I also think that electrical ratings on the product get people to ask the
question Can I use this when I travel to a foreign country?  I can't
count the times that I have been asked by coworkers or family members who
were planning a trip from the US to Europe if they could use their personal
grooming appliance or laptop computer or cell phone charger while traveling
if the electrical ratings on the product were ___.   Most consumers
don't know a Volt from an Amp or how they relate, but they do know they are
important and will seek out the answer when it is important.

Kevin Robinson

On Sat, Jan 28, 2012 at 4:23 PM, Richard Nute ri...@ieee.org wrote:

  The ratings could just as well be in the accompanying documents.
 
  ... which are thrown away, no, sorry, *recycled*, with the packaging.

 Of course.  But, as I said before, why do I
 need to know the ratings?  Especially after
 the equipment is installed?

 Most manufacturers now provide e-copies on the
 web.  So, I can get most any accompanying
 documents at any time.

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[PSES] Is this common knowledge - Electrical Ratings

[Kevin Robinson]

Happy Friday everyone

I am asking a question that I already know the answer to, but I am
trying to determine if it is common knowledge or if it was something
that I picked up along the way and have always accepted as being true.

If you were to see a product with a marked electrical rating of
120/240 V and another product with a marked rating of 120-240V, what
would be the difference between these two products?  Would a user or
operator need to do anything special with one or both of these
products to use it at 120V or 240V?

Thanks,

Kevin Robinson
OSHA

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Re: [PSES] Is this common knowledge - Electrical Ratings

[Kevin Robinson]

Thanks everyone for your response.  Everyone who responded to me on
the forum and privately was correct that 120-240V indicates a range,
and the product can operate at any voltage over that range.  120/240V
indicates that the product can only operate at those specific voltages
(plus tolerances).

As for the general public, I was actually quite surprised.  I asked
several people that I know, many of whom freely admit they don't know
how electricity works.  Every person I asked knew that 120-240 was
different from 120/240 and they were able to guess a range vs
either/or.

The general public was pretty clear on 120-240V saying they would
just plug it in and it would work, however they were confused when
faced with 120/240, some said they should look for a voltage selector
switch, others indicated they would need some sort of adapter, and a
few people said just plug it in and it will work.


Thanks again for your responses,

Kevin

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Re: [PSES] Mandatory NRTL certification

[Kevin Robinson]

Hi Peter,

While the NRTL program and NRTL approval is used by a variety of local
AHJs, employers and retailers, the program was developed by OSHA for
OSHA's purposes.

OSHA requires certain types of equipment
(http://www.osha.gov/dts/otpca/nrtl/prodcatg.html) to be approved by
an NRTL.  Electrical equipment must be Acceptable to the Assistant
Secretary of Labor as defined in 29 CFR 1910.399
(http://www.gpo.gov/fdsys/pkg/CFR-2011-title29-vol5/pdf/CFR-2011-title29-vol5-sec1910-399.pdf).
1910.399 provides three options to comply 1) Approval by an NRTL, 2)
Approval by another regulatory body if it is of a type of equipment
that no NRTL will approve or 3) Approval my the manufacturer if the
product is custom made.  Most equipment manufactured would not meet
the requirements of options 2 or 3, so it would need to be approved by
an NRTL.

OSHA's authority in this area is limited to the employer, as such, the
burden of complying with NRTL Approval requirements falls on US
employers, not the product manufacturer.  Product manufacturers have
no LEGAL requirement (at least per OSHA regulations) to have their
products tested or certified by an NRTL, however, due to the
potentially destructive nature of the tests, the time and cost
involved, as well as the amount of potentially confidental or
priveleged information that must be provided to the NRTLs, most
manufacturers opt to take on the burden of having the product
certified by an NRTL.  The NRTL Certification mark that is applied to
the product can then be used by an employer to demonstrate to OSHA
that they meet the applicable approval requirements.

If your product could also be used in and around a home or school, or
is classified as a medical device, it may also be subject to CPSC
and/or FDA requirements in addition to OSHA requirements.

If you have any additional questions, please feel free to contact me directly.

Kevin Robinson
Department of Labor – OSHA
NRTL Program Engineer  Lead Auditor
Office of Technical Programs  Coordination Activities
200 Constitution Ave, NW,  Room N-3655
Washington DC 20210
Phone: 202 -693-1911
Fax: 202-693-1644
E-mail: robinson.ke...@dol.gov




 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of
 peterh...@aol.com
 Sent: Thursday, January 05, 2012 5:41 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Mandatory NRTL certification



 Hello All,



 Today a colleague asked me a question as to why do we need NRTL
 certification such as UL or CSA on any product in the US. I thought this was
 a good and logical question and the way I answered it was that to the best
 of my knowledge, OSHA requires that any products that is used in work place
 to be safe and to have been certified by one of the NRTL labs. Would you say
 that is a correct answer?



 Thank you

 Peter

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Re: CCC processes

[Kevin Robinson]

I think that www.standardsportal.org may offer some assistance (The site is
run by ANSI).  Simply select Peoples Republic of China from the drop down
menu on the left and it will provide you with a fairly good overview of the
different agencies in China and how they interact with each other.  I did not
immediately see information on the CCC process, but I think that the
background information will help fill in some of the gaps when people reply
specifically to the CCC process issue.
 
Kevin Robinson

 
On 7/1/08, Rich Nute rn...@san.rr.com wrote: 

Is there a good document (in English) on
CCC processes?  How to do it?

Are there any agents in England who can
assist or get CCC?


Thanks for your help,
Richard Nute
San Diego

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RE: Haz Loc Testing

[Kevin Robinson]

Richard,

It really depends on the type of protection that is being employed in a
particular product.  If you want more details, contact me directly. There
are several methods that are typically used, two of the most common being:

Intrinsically Safe (Division 1) /Non-Incendive (Division 2)
Explosion Proof 

I assume that you are inquiring about Intrinsically safe/Non-Incendive as
this is probably the most test intensive

To summarize 100 pages of a standard into 1 paragraph:
Intrinsically Safe/Non-Incendive: This method relies on the circuitry
internal to the product as well as the wiring to and from the product (if it
is a permanent installation).  This method of protection requires a large
amount of circuit analysis to determine the theoretical energy available
at points of potential spark release (switches, relays, motors etc).  Once
the theoretical value of energy has been determined, you can compare this
with published ignition curves to determine what spark ignition testing you
need to conduct. Spark ignition testing is where the make/break portion of
the circuit is placed in an explosive atmosphere and cycled a minimum of
1600 times. (Note:  The actual circuit is placed outside the explosive
atmosphere, and the circuit is switched using a specialized test setup with
a cadmium disk and tungsten electrodes.)  If ignition occurs in this
atmosphere, the circuit is deemed to have too much energy use in that
particular atmosphere and you will either need to drop the investigation
back to a lower gas group and retest, or redesign the circuit to limit the
amount of available energy.  

With this method, you want to minimize the amount of capacitance and
inductance that you have in your circuit, and to increase the amount of
resistance as much as possible.

Also conducted are drop tests from 1m on to concrete (for portable
apparatus) and temperature tests to determine the maximum temperature in the
product.

If you are looking for more detail than that, please contact me off line and
I will be happy to discuss further.


Kevin Robinson 
Senior Project Engineer/QA
Safety Laboratory
MET Laboratories-Baltimore
Phone: 410-354-3300 x 361
Fax: 410-354-3313


 -Original Message-
 From: richwo...@tycoint.com [SMTP:richwo...@tycoint.com]
 Sent: Monday, February 04, 2002 11:00 AM
 To:   emc-p...@majordomo.ieee.org
 Subject:  Haz Loc Testing
 
 
 It would be appreciated if someone would provide me with a brief overview
 of
 the testing that is performed in order to classify electronic equipment
 for
 use in a hazardous location where fuel vapors are located.
 
 Richard Woods
 Sensormatic Electronics
 Tyco International
 
 
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RE: CFR requirements for the workplace

[Kevin Robinson]

29 CFR 1910 is the section that requires products be listed by an NRTL.

Kevin Robinson
Senior Project Engineer/QA
Safety Laboratory
MET Laboratories
Phone: (410) 354-3300 x 361
Fax: (410) 354-3313


 -Original Message-
 From: Patricia Knudsen (EWU) [SMTP:ewup...@am1.ericsson.se]
 Sent: Friday, September 14, 2001 11:38 AM
 To:   emc-p...@majordomo.ieee.org
 Subject:  CFR requirements for the workplace
 
 Does anyone know the specific section of the CFR that refers to equipment
 at the workplace (specifically computer or test equipment) being Listed by
 a NRTL?
 
 Patty Knudsen 
 Sr. Regulatory Engineer 
 Ericsson Wireless Communications 
 (858) 332-5014 
 patricia.knud...@ericsson.com 
 

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RE: Class I Division 1 versus Class I Division 2

[Kevin Robinson]

Robert,

Check out the National Electric Code (NFPA 70) Article 500-7(a) and 500-7(b)
for your answer, but simply stated, In a Division 1 location, the hazardous
atmosphere is assumed to be present under normal conditions, and a Division
2 location, the hazardous atmosphere is present under abnormal conditions (a
chemical spill, leak, etc.)

What is needed to bring a Division 2 product into compliance with Division 1
requirements?  It ultimately depends on what the product is, and what method
of protection was employed.  I will assume that the Division 2 product was
evaluated as a Non-Incendive product, if this is the case, then that product
was only investigated under normal operating conditions.  To upgrade the
certification to a Division 1 location, one would have to look at the
product operating under normal operating conditions, a single fault
condition, and also a double fault condition (whichever is worst
case...NOTE: a double fault is not always worst case).  

If you are NOT using Non-Incendive/Intrinsic Safety type protection then I
would have to have a little more information about the product as well as
the method of protection being used.

Contact the lab who did the original certification, they should have some
intimate knowledge of the product and be able to tell you after reviewing
the original investigation data if upgrading to a Division 1 classification
would even be possible for the product, but be forewarned, it is usually not
a simple process and may require some rather severe product modifications.

Kevin Robinson
Senior Project Engineer/QA
Safety Laboratory
MET Laboratories
The Nation's FIRST NRTL
Phone: (410) 354-3300 x 361
Fax: (410) 354-3313


 -Original Message-
 From: Loop, Robert [SMTP:rl...@hnt.wylelabs.com]
 Sent: Thursday, March 15, 2001 11:13 AM
 To:   emc-p...@majordomo.ieee.org
 Subject:  Class I Division 1 versus Class I Division 2
 
 
 Hello Group,
 
 I need some education on Classified/Hazardous locations.
 
 What is the difference between a product that is certified to Class I
 Division 1 versus Class I Division 2?
 
 If I had a product that was certified to Division 2, what would be needed
 to
 make it pass Division 1 requirements?
 
 I apologize for my ignorance, there are simply too many standards out
 there
 and this is out of my league.
 
 Sincerely,
 Robert Loop
 Engineering Supervisor
 Wyle Laboratories 
 Product Safety
 ph - (256) 837-4411 x313
 fax- (256) 721-0144
 e-mail: rl...@hnt.wylelabs.com
 
 
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RE: Conversion program

[Kevin Robinson]

Here is the original E-mail from November 1999:

For those of you interested, there is a free conversion
program located at the following address:
http://www.joshmadison.com/software
http://www.joshmadison.com/software  http://www.joshmadison.com/software
http://www.joshmadison.com/software  
After opening this site, go to CONVERT for a description. I
have found this program to be quite useful for conversion tasks between
different units, e.g. temperature, power, etc. Hopefully  you will find this
useful as well.
-Original Message-
From:   Hjálmar Árnason
[SMTP:hjal...@tnet.is]
Sent:   Friday, June 16, 2000 4:54 AM
To: emc-p...@majordomo.ieee.org
Subject:Conversion program



Hi everyone,

some months back there was an email going around
that 
had attached a conversion software i.e. converting
dB-that 
to dB-this and so on.
Is there anyone out there that can resend me this
program.

Thanks in advance..

Hjalmar.

STIKLA ehf
Hjalmar Arnason
Manager Technical Operations
Hlidarsmara 11
200 Kopavogi
Iceland.

hjal...@tetra.is

STIKLA ehf is a TETRA operator in Iceland and you
can
find us at www.tetra.is 

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RE: Network Card Certification

[Kevin Robinson]

The release of the final version of UL60950 Third Edition
was delayed until some time this summer (from the UL Bulletin).  It was
originally scheduled to be released by April 1, 2000.

It will be a Bi-National standard with CSA 60950 Third
Edition and will be harmonized with IEC60950 3rd edition

Kevin Robinson
Project Engineer/QA
MET Laboratories
Phone: (410) 354-3300x361
Fax: (410) 354-3313
E-Mail: krobin...@metlabs.com mailto:krobin...@metlabs.com



-Original Message-
From:   Bandele Adepoju
[SMTP:badep...@jetstream.com]
Sent:   Thursday, May 11, 2000 3:12 PM
To: 'geor...@lexmark.com';
george.sparac...@bostonacoustics.com
Cc: emc-p...@ieee.org
Subject:RE: Network Card
Certification


Unfortunately, there is a UL60950. I had the draft
copy, which was sent to me direct from UL, but not
the final copy.  My draft was misplaced in a change
of companies. I have spoken to UL about getting
another copy.

I also understand that this standard went into
effect 
on April 1st, 2000.

http://www.wll.com/teupdate0100.pdf

Bandele 
Jetstream Communications, Inc.
badep...@jetstream.com

 


-Original Message-
From: geor...@lexmark.com
[mailto:geor...@lexmark.com]
Sent: Thursday, May 11, 2000 9:10 AM
To: george.sparac...@bostonacoustics.com
Cc: emc-p...@ieee.org
Subject: RE: Network Card Certification


George,

There is no UL60950.  Try UL1950, Third Edition.

George





george.sparacino%bostonacoustics@interlock.lexmark.com on 05/11/2000
11:50:58 AM

Please respond to
george.sparacino%bostonacoustics@interlock.lexmark.com

To:   emc-pstc%ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  RE: Network Card Certification



Has anyone seen a copy of UL60950 ?  I am unable to
find copy (or draft) for
review.

Thanks,
George

-Original Message-
From: Bandele Adepoju
[mailto:badep...@jetstream.com]
Sent: Wednesday, May 10, 2000 8:38 PM
To: emc-p...@ieee.org; dan_mitch...@condordc.com
Subject: RE: Network Card Certification



You should self declare conformity (DoC) of the card
to FCC Class B. The FCC logo mentioned by David
must be supported on your card with the product
model
or identification number.

Test configuration, in addition to that listed by
David below, should include a remote PC hookup for
data exchange (or a loopback transceiver) to
exercise
the LAN port.

For US safety, the RJ jacks may, as alternate to
what
is listed below, be marked with the word Ethernet
or similar.

Clause 6 of the EN60950 or UL1950 standard does not
apply to your card. Make sure that the card is
listed
to the 3rd Edition of UL1950 or UL60950.  Preferably
that you list the card to UL60950 which went into
effect on April 1st of this year. UL1950 expires on
April 1st of 2003.

Regards,

Bandele
Jetstream Communications, Inc.
badep...@jetstream.com




-Original Message-
From: david_ster...@ademco.com
[mailto:david_ster...@ademco.com]
Sent: Wednesday, May 10, 2000 12:26 PM
To: emc-p...@ieee.org; dan_mitch...@condordc.com
Subject: RE: Network Card Certification



 Safety:
 UL1950US
 EN/IEC60950

RE: Network Card Certification

[Kevin Robinson]

The final version is not yet out, but you can apparently
purchase a proposed copy of UL60950 from Global


http://global.ihs.com/cgi-bin/detdoc.cgi?FRITTER=130536DOCID=7335720
http://global.ihs.com/cgi-bin/detdoc.cgi?FRITTER=130536DOCID=7335720 


Kevin Robinson
Project Engineer/QA
MET Laboratories
Phone: (410) 354-3300x361
Fax: (410) 354-3313
E-Mail: krobin...@metlabs.com mailto:krobin...@metlabs.com



-Original Message-
From:   geor...@lexmark.com
[SMTP:geor...@lexmark.com]
Sent:   Thursday, May 11, 2000 12:10 PM
To: george.sparac...@bostonacoustics.com
Cc: emc-p...@ieee.org
Subject:RE: Network Card
Certification

George,

There is no UL60950.  Try UL1950, Third Edition.

George





george.sparacino%bostonacoustics@interlock.lexmark.com on 05/11/2000
11:50:58 AM

Please respond to
george.sparacino%bostonacoustics@interlock.lexmark.com

To:   emc-pstc%ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  RE: Network Card Certification



Has anyone seen a copy of UL60950 ?  I am unable to
find copy (or draft) for
review.

Thanks,
George

-Original Message-
From: Bandele Adepoju
[mailto:badep...@jetstream.com]
Sent: Wednesday, May 10, 2000 8:38 PM
To: emc-p...@ieee.org; dan_mitch...@condordc.com
Subject: RE: Network Card Certification



You should self declare conformity (DoC) of the card
to FCC Class B. The FCC logo mentioned by David
must be supported on your card with the product
model
or identification number.

Test configuration, in addition to that listed by
David below, should include a remote PC hookup for
data exchange (or a loopback transceiver) to
exercise
the LAN port.

For US safety, the RJ jacks may, as alternate to
what
is listed below, be marked with the word Ethernet
or similar.

Clause 6 of the EN60950 or UL1950 standard does not
apply to your card. Make sure that the card is
listed
to the 3rd Edition of UL1950 or UL60950.  Preferably
that you list the card to UL60950 which went into
effect on April 1st of this year. UL1950 expires on
April 1st of 2003.

Regards,

Bandele
Jetstream Communications, Inc.
badep...@jetstream.com




-Original Message-
From: david_ster...@ademco.com
[mailto:david_ster...@ademco.com]
Sent: Wednesday, May 10, 2000 12:26 PM
To: emc-p...@ieee.org; dan_mitch...@condordc.com
Subject: RE: Network Card Certification



 Safety:
 UL1950US
 EN/IEC60950   International

 FCC
 CFR 47 Part 15: Class B residential or Class A
(industrial)

 Re: FCC
 FCC logo for Class B is self-certified but
you must test in the PC
 configuration specified in Part 15;  EUT
includes monitor, keyboard,
 mouse, serial device and printer.  Be sure all
items are Class B
 before you test your card.

 Class B requires careful circuit layout and
component choice for most
 network technologies.

 Re: safety
 If RJ jack, mark the port with the
telephone-banned logo or print a
 lengthy message (for data only) near the port.
'For data only' does
 not translate well into French.

 david



__ Reply Separator

RE: NRTL acceptance

[Kevin Robinson]

Thanks for that link George.  That was a quick/concise list
that I was looking for. To get the information you mentioned (what the scope
of each CO is), you go to the link that I mentioned
http://www.scc.ca/search-front/index.html
http://www.scc.ca/search-front/index.html  , click on accreditations and
then certification orgs, and type in the name of the Lab you are interested
in, for the sake of argument, if you type MET, a list of all related links
for MET Laboratories will show up.  You should have a link to a MS Word
document, which if you click on, will show you the scope of our laboratory,
which includes all electrical equipment, (which includes CSA C22.2 No 950).
Similar results would be obtained if you typed in the name for all the other
COs.   

SCC is a bit more broad as they typically accredit labs for
types of equipment (i.e. all electrical products etc.) vs. OSHA/NRTL which
accredits based by standard.   If you combine the NRTL list with the SCC
list, by my count (correct me if I am wrong) you come up with about 5 labs
(MET, CSA, Intertek, Entela, and UL) that can provide you with US  Canadian
certifications (including UL1950/CSA C22.2 No 950, among others) that from
the legal aspect are equal.  Hope this helps to answer your question.

Kevin Robinson
Project Engineer/QA
MET Laboratories
Phone: (410) 354-3300x361
Fax: (410) 354-3313
E-Mail: krobin...@metlabs.com mailto:krobin...@metlabs.com



-Original Message-
From:   geor...@lexmark.com
[SMTP:geor...@lexmark.com]
Sent:   Tuesday, November 23, 1999 10:01 AM
To: emc-p...@majordomo.ieee.org
Subject:RE: NRTL acceptance


Kevin,

Thanks for the website pointer.  I found the site
nearly impossible
to use via the search function.  I got no hits for
COs no matter
what I tried, including UL and Underwriters
Laboratories.  Somehow
I stumbled on to the following site which DOES list
all COs.

http://www.scc.ca/certific/colist.html

There are 20 SCC accredited COs listed, including
CSA, UL, ITS, and
MET.  Now, back to the original question.  Who knows
which of the
20 listed COs can authorize the use of a mark
indicating compliance
with CAN/CSA 22.2 950-95 for the safety of ITE, i.e.
legally
equivalent to the CSA mark?

George
-- Forwarded by George
Alspaugh/Lex/Lexmark on 11/23/99
09:34 AM ---

krobinson%metlabs@interlock.lexmark.com on
11/23/99 08:54:51 AM

Please respond to
krobinson%metlabs@interlock.lexmark.com

To:
emc-pstc%majordomo.ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  RE: NRTL acceptance

  You can check out the SCC website at
www.scc.ca
http://www.scc.ca  , click on accreditations and
then certification
orgs and type in the name of your favorite test lab
(or your least favorite
as the case may be :-) )to see if they are a CO.
You can try a general
search for laboratories but it did not tun up all
of the laboratories that
I knew were CO's, I had better luck searching for
specific laboratories.

  Kevin Robinson
  Project Engineer/QA
  MET Laboratories
  Phone: (410) 354-3300x361
  Fax: (410) 354-3313
  E-Mail: krobin...@metlabs.com
mailto:krobin...@metlabs.com

-Original Message-
From: geor...@lexmark.com
[SMTP:geor...@lexmark.com]
Sent: Tuesday, November 23, 1999 8:02 AM
To:  emc-p...@majordomo.ieee.org
Subject:  RE: NRTL acceptance


S. William,

Thanks for the words on COs and TOs and SCCs.
Apparantly UL
is one or more of these, as the c-UL mark is legally
acceptable
in Canada.  Now, what other COs has the SCC
accredited to issue
an approved Canadian mark?  Not CSA, but
alternatives to CSA

RE: NRTL acceptance

[Kevin Robinson]

You can check out the SCC website at www.scc.ca
http://www.scc.ca  , click on accreditations and then certification
orgs and type in the name of your favorite test lab (or your least favorite
as the case may be :-) )to see if they are a CO.  You can try a general
search for laboratories but it did not tun up all of the laboratories that
I knew were CO's, I had better luck searching for specific laboratories.

Kevin Robinson
Project Engineer/QA
MET Laboratories
Phone: (410) 354-3300x361
Fax: (410) 354-3313
E-Mail: krobin...@metlabs.com mailto:krobin...@metlabs.com



-Original Message-
From:   geor...@lexmark.com
[SMTP:geor...@lexmark.com]
Sent:   Tuesday, November 23, 1999 8:02 AM
To: emc-p...@majordomo.ieee.org
Subject:RE: NRTL acceptance


S. William,

Thanks for the words on COs and TOs and SCCs.
Apparantly UL is one or
more of these, as the c-UL mark is legally
acceptable in Canada.

Now, what other COs has the SCC accredited to issue
an approved Canadian
mark?  Not CSA, but alternatives to CSA?

George

-- Forwarded by George
Alspaugh/Lex/Lexmark on 11/23/99
07:57 AM ---

swilliam%apcc@interlock.lexmark.com on 11/22/99
05:02:15 PM

To:   George_Alspaugh/Lex/Lexmark@LEXMARK
cc:
emc-pstc%majordomo.ieee@interlock.lexmark.com (bcc: George
  Alspaugh/Lex/Lexmark)
Subject:  RE: NRTL acceptance



George, Canada is not as straight forward as that.
There is not a mutual
agreement. In order for a lab to issue a Canadian
Approval Mark, the lab
must be accredited as a CO(Certifying Organization)
by the SCC(Standards
Council of Canada). The CO must use data that has
come from a TO(Testing
Organization) that is also accredited by the SCC.
Most labs that issue
their Canada Mark are both a CO and TO so it is very
easy for them. The
critical item is that the product has to have been
tested against the
relevant Canadian National Standard(very easy for
ITE as 1950 is a joint
standard).
If you want to do everything by the book, your US
Mark should be from an
NRTL certified by OSHA to the standards that apply
to your product and the
Canadian Mark must be from a CO accredited by the
SCC.


Please respond to geor...@lexmark.com

To:   emc-p...@majordomo.ieee.org
cc:(bcc: Steve Williams/SDD/NAM/APCC)
From: geor...@lexmark.com on 11/22/99 03:42 PM
Subject:  RE: NRTL acceptance


I tried to recall NRTLs that were approved for
asessments of ITE to
UL1950.  I did not overlook MET (listed in my note),
but may have
missed NTS which may fit this description.  I'm not
sure the others
are sanctioned for listing of ITE under UL1950.

There are many NTRLs, including UL.  There is no
NRTL mark, as all
NRTLs are legally equal.  The mark of some NRTLs has
included the
letters NRTL as part of their mark, apparantly by
choice.  The
CSA/NRTL mark is an example.  To my knowledge, the
use of NRTL in
an agency's mark is not mandatory.  CSA has recently
changed their
mark to drop the NRTL and simply show the CSA mark
with US
subscript for assessment to the U.S. stadnard.

However, Canada does not recognize the U.S. NRTLs to
assess an ITE
product to the Canadian standard.  There is a mutual
agreement between
Canada and the U.S. that allows a UL assessment to
the Canadian ITE
safety standard.  This results in the UL mark with a
subscript C,
often called the c-UL mark.  It is my
understanding that when the
Canadian government bids out ITE for its own use,
they tend to prefer
the CSA mark over the c-UL mark.  This seems to
violate the spirit

RE: Argentina Approval/Certification

[Kevin Robinson]

The best person to contact on this subject at MET
Laboratories is:

Leonard Frier
MET Laboratories
914 W. Patapsco Ave.
Baltimore MD, 21230
Phone: (410) 354-3300
Fax: (410) 354-3313
E-mail: lfr...@metlabs.com mailto:lfr...@metlabs.com 
Web: www.metlabs.com http://www.metlabs.com 

He should be able to give you all the information that you
need.  Hope this helps.

Kevin Robinson
Project Engineer/QA
MET Laboratories
Phone: (410) 354-3300x361
Fax: (410) 354-3313
E-Mail: krobin...@metlabs.com mailto:krobin...@metlabs.com



-Original Message-
From:   John Juhasz
[SMTP:jjuh...@fiberoptions.com]
Sent:   Friday, July 23, 1999 1:41 PM
To: 'Nezam Najafi';
emc-p...@majordomo.ieee.org
Subject:RE: Argentina
Approval/Certification

Anyone can correct me if I'm wrong, but my
understanding is that for the time being, Argentina is accepting CE approval
until Jan 1, 2000. 

MET laboratories in Patapsco, MD is rather well
versed in the Mercosur countries (Argentina, Brazil, Uruguay,  Chile). It
may be worth contacting them. They are a good resource. 

John A. Juhasz 
Product Qualification  
Compliance Engr. 

Fiber Options, Inc. 
80 Orville Dr. Suite 102 
Bohemia, NY 11716 USA 

Tel: 516-567-8320 ext. 324 
Fax: 516-567-8322 




-Original Message- 
From: Nezam Najafi [ mailto:nezam.naj...@madge.com
mailto:nezam.naj...@madge.com ] 
Sent: Friday, July 23, 1999 11:15 AM 
To: emc-p...@majordomo.ieee.org 
Subject: Argentina Approval/Certification 



To all: 

Dose anyone have any experience with certification
of networking equipment 
for Argentina. I understand there is an IRAM
marking. If my equipment has a 
CE marking what is the lead time to get the
appropriate Argentina 
certification. Can you sell the products to
Argentina that already has a CE 
marking. Would ther be any problem with Argentian
custom to take a CE mark 
equipment there. I thank you for anyone that will
enlighten me on this 
matter. 


Regards, 
Nezam Najafi 
Sr. Compliance Engineer 
Madge Networks, 
Voice: 732-460-6825 

  

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RE: Enclosure ratings IP vs NEMA

[Kevin Robinson]

NEMA 250 , appendix A has a chart that makes the
comparison between NEMA and IP ratings, although it can only be used to
convert NEMA type numbers to IEC Classifications.

Hope this helps. 
Kevin Robinson
MET Laboratories
Product Safety Department
Project Engineer/QA Manager
Ph: (410) 354-3300 x361
Fx: (410) 354-3313
E-Mail: krobin...@metlabs.com


-Original Message-
From:   Russell, Ray
[SMTP:ray_russ...@gastmfg.com]
Sent:   Thursday, April 08, 1999 9:39 AM
To: 'IEEE PSTC'
Subject:Enclosure ratings IP vs
NEMA

Greetings,

I hope everyone had a happy holiday. 

I am looking for a comparison of IEC 60529 IP
ratings for enclosures to the
NEMA equivalents. 

Thank you for your assistance,
 

Ray Russell
Regulatory Compliance Engineer


ray_russ...@gastmfg.com

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