Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
In message
!!AAAYAEGjmYsMtGZAuvo7rFLQ++figAAAEDf9dud5KeJHuCKyK
rUnaccBAA==@blueyonder.co.uk, dated Sat, 21 Feb 2015, John Allen
john_e_al...@blueyonder.co.uk writes:
OTOH, the EU approach is more encompassing because the prime
requirement is to comply with the essential protection requirements of
the relevant Directive(s). As such you do NOT need to comply with all
the detailed requirements of a standard, but if you claim compliance
with a Harmonized Standard but you don’t comply with some of its
specific requirements then you DO have to identify where you have
deviated and how you still hold that you comply with the essential
requirements of the Directive in question.
There is an important principle here, and it almost certainly applies to
PV products, which use relatively new technology that is still being
improved.
No-one will try to write a standard for a product that does not yet
exist, so standards development must always lag innovation. If it lags
as little as possible, it can hamper product improvement, because it's
written around a 'Mark 1' version of the new technology. If it lags a
lot, badly-designed products can appear on the market, and the lagging
standard's provisions may be influenced by them - governments and
manufacturers will not generally allow standards to drive existing
products from the market.
The EU system attempts to resolve this dilemma - swift standardisation
is encouraged. Product improvement is permitted, but controlled by the
requirement to state and justify a deviation from the applicable
standard.
A historical example. LED lamps were illegal on British bicycles for
some years after they became practicable, because the (very elderly)
regulations specified 'incandescent lamps', with the intention of
disallowing acetylene ('carbide') lamps.
--
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] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
Good point - didn't know that (:-)), but it's another example of where the EU
approach is more pragmatic.
-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 21 February 2015 22:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone
terminal equipment?
In message
!!AAAYAEGjmYsMtGZAuvo7rFLQ++figAAAEDf9dud5KeJHuCKyK
rUnaccBAA==@blueyonder.co.uk, dated Sat, 21 Feb 2015, John Allen
john_e_al...@blueyonder.co.uk writes:
OTOH, the EU approach is more encompassing because the prime
requirement is to comply with the essential protection requirements of
the relevant Directive(s). As such you do NOT need to comply with all
the detailed requirements of a standard, but if you claim compliance
with a Harmonized Standard but you don’t comply with some of its
specific requirements then you DO have to identify where you have
deviated and how you still hold that you comply with the essential
requirements of the Directive in question.
There is an important principle here, and it almost certainly applies to PV
products, which use relatively new technology that is still being improved.
No-one will try to write a standard for a product that does not yet exist, so
standards development must always lag innovation. If it lags as little as
possible, it can hamper product improvement, because it's written around a
'Mark 1' version of the new technology. If it lags a lot, badly-designed
products can appear on the market, and the lagging standard's provisions may be
influenced by them - governments and manufacturers will not generally allow
standards to drive existing products from the market.
The EU system attempts to resolve this dilemma - swift standardisation is
encouraged. Product improvement is permitted, but controlled by the requirement
to state and justify a deviation from the applicable standard.
A historical example. LED lamps were illegal on British bicycles for some years
after they became practicable, because the (very elderly) regulations specified
'incandescent lamps', with the intention of disallowing acetylene ('carbide')
lamps.
--
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
-
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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formats), large files, etc.
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David Heald: dhe...@gmail.com
-
This message is from the IEEE Product Safety Engineering Society emc-pstc
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All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
In message cadyqxldy7tejcbl-vv+_m2zgdippqtn2nfamxol-7nogmi0...@mail.gmail.com, dated Fri, 20 Feb 2015, Kevin Robinson kevinrobinso...@gmail.com writes: 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 You can't expect a turkey to vote for Thanksgiving. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
Good morning (London time!) W.r.t. the OSHA survey – things have changed a bit in the EU since 2008 – for both good and bad! I think there is more general awareness of the hazards of electrical and other goods – and certainly there are more product recalls than there ever were in earlier days, and the supply chain is more aware of its responsibilities to ensure that only “safe” items are supplied. You only have to look at the number of high-profile product recalls that now routinely occur! OTOH, the ranges of goods on offer, and the variety of sources from which they come, have expanded enormously – and that, unfortunately, has lead to more “holes in the systems” for trying to ensure that only “safe” items are put on the market. However, I think that there are several common factors which are tending to reinforce the overall trend towards safer products across the World, and thus in both N.America and Europe, such as: 1) More and more products are being developed for worldwide, as opposed to national, markets, and that means that the designers and manufacturers have to take all the market requirements into account – and, with the welcome rise in the importance of truly international safety standards, that means that those suppliers do more closely try to meet them (or then either fail to get their products into the big markets, or else get widely taken to account for supplying unsafe products) The NTRL approach in N. America and the EU CE marking requirements over here have both substantially contributed to that both directly in their own marketplaces and more globally as the less economically-developed countries (even the big ones like China!) pragmatically adopt the similar standards and regulatory controls on the basis that “if it works in the big countries then it should work for us as well” (and as well as encouraging and helping their own manufacturers to meet those same standards in order to have much wider export markets – or at least not to lose them!). 2) Intelligence gathering and dissemination of information on unsafe products is now much more worldwide – and so knowledge of those products quickly gets to both the regulators and the general public, and the latter are in a much better position to put pressure on the former to get the suppliers to get the problems fixed! Gone are the days when a supplier in one country could be reasonably sure that faults in products on one side of the World would not become public knowledge elsewhere – or that a local supplier could claim that a product was OK and a particular safety problem had never been known about in his marketplace, even though it was well known to the suppliers and regulators in another. National product-alert/recall regimes are much more established in both of the big markets – the legally-enforced systems such CPSC/OHSA in the US and RAPEX in the EU have more clout than they did before. Even if many of the individual regulators are short of funds to enforce the rules, the combined effects of all of them help collectively So where do I think that leaves us? Well, collectively a lot better than we were in 2008, and with a general way forward to better, safer products. Is the NTRL system in the US still necessary? Yes, because that is how the State regulators and the public expect/require it to be at present – but in another 10-20 years, maybe it will become a fond memory from the past! J John Allen W.London, UK From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] Sent: 21 February 2015 03:21 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? 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
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
In message OFE8B273B2.B20F6D17-ON88257DF2.007B9EF8-88257DF2.007C2C17@US.Schneider-E lectric.com, dated Fri, 20 Feb 2015, McDiarmid, Ralph ralph.mcdiar...@schneider-electric.com writes: 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. The European model would work better in those countries. We have had issues with the EU border 'leaking' non-compliant products through some countries whose enforcement is lacking in zeal. I think the risk is much lower in the countries you cite. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
Brian Not arguing at all with your comments - generally I think I generally agree with them in the specific issue of strict compliance with the standards. But why do I think that that the standards are not the whole answer? Why? Because the burden on small (and even on bigger) companies of complying with the complex requirements of many standards can be (generally IS) very heavy - just think how much time/money it takes to comply with the ones you know well - and then think how much more is required for a company that does not? And, in that respect, the NRTL approach is very prescriptive - deviations from the standards is hard, if not impossible, for them to permit. OTOH, the EU approach is more encompassing because the prime requirement is to comply with the essential protection requirements of the relevant Directive(s). As such you do NOT need to comply with all the detailed requirements of a standard, but if you claim compliance with a Harmonized Standard but you don’t comply with some of its specific requirements then you DO have to identify where you have deviated and how you still hold that you comply with the essential requirements of the Directive in question. That's not to excuse companies that ignore the above statement of the requirements, but to explain why it is perfectly possible for the situations you describe could arise in the EU and yet still be compliant with the legal (and hopefully ethical) requirements in this area of the world. OTOH, in the US the situation is more black and white and with less room for flexibility - which also means a rather blinkered approach IMHO! John Allen West London, UK -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: 21 February 2015 20:21 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Non sequitur? The survey indicated injury rates, not recalled products (actually preferable to injuries). A small example from my edge of the desert. With exception of the U.K. and Germany, all of the PV stuff that has been reviewed by self that was built in the EU required some significant fixes - did not conform to EN62109-1 much less UL1741/1703. Methinks the industry attitude of many southern EU states needs some adjustment. The only thing that OSHA and SCC should fix is the mess that is the (lack of) mutual recognition among accredited labs. If one NRTL thinks another NRTL's work cannot be accepted, then make a regulatory framework where they are required to be doing the same thing or the offending NRTL's VP of engineering goes to jail. Brian From: John Allen [mailto:john_e_al...@blueyonder.co.uk] Sent: Saturday, February 21, 2015 1:46 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Good morning (London time!) W.r.t. the OSHA survey – things have changed a bit in the EU since 2008 – for both good and bad! I think there is more general awareness of the hazards of electrical and other goods – and certainly there are more product recalls than there ever were in earlier days, and the supply chain is more aware of its responsibilities to ensure that only “safe” items are supplied. You only have to look at the number of high-profile product recalls that now routinely occur! OTOH, the ranges of goods on offer, and the variety of sources from which they come, have expanded enormously – and that, unfortunately, has lead to more “holes in the systems” for trying to ensure that only “safe” items are put on the market. However, I think that there are several common factors which are tending to reinforce the overall trend towards safer products across the World, and thus in both N.America and Europe, such as: 1) More and more products are being developed for worldwide, as opposed to national, markets, and that means that the designers and manufacturers have to take all the market requirements into account – and, with the welcome rise in the importance of truly international safety standards, that means that those suppliers do more closely try to meet them (or then either fail to get their products into the big markets, or else get widely taken to account for supplying unsafe products) The NTRL approach in N. America and the EU CE marking requirements over here have both substantially contributed to that both directly in their own marketplaces and more globally as the less economically-developed countries (even the big ones like China!) pragmatically adopt the similar standards and regulatory controls on the basis that “if it works in the big countries then it should work for us as well” (and as well as encouraging and helping their own manufacturers to meet those same standards in order to have much wider export markets – or at least not to lose them!). 2) Intelligence gathering and dissemination of information
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
Non sequitur? The survey indicated injury rates, not recalled products (actually preferable to injuries). A small example from my edge of the desert. With exception of the U.K. and Germany, all of the PV stuff that has been reviewed by self that was built in the EU required some significant fixes - did not conform to EN62109-1 much less UL1741/1703. Methinks the industry attitude of many southern EU states needs some adjustment. The only thing that OSHA and SCC should fix is the mess that is the (lack of) mutual recognition among accredited labs. If one NRTL thinks another NRTL's work cannot be accepted, then make a regulatory framework where they are required to be doing the same thing or the offending NRTL's VP of engineering goes to jail. Brian From: John Allen [mailto:john_e_al...@blueyonder.co.uk] Sent: Saturday, February 21, 2015 1:46 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Good morning (London time!) W.r.t. the OSHA survey – things have changed a bit in the EU since 2008 – for both good and bad! I think there is more general awareness of the hazards of electrical and other goods – and certainly there are more product recalls than there ever were in earlier days, and the supply chain is more aware of its responsibilities to ensure that only “safe” items are supplied. You only have to look at the number of high-profile product recalls that now routinely occur! OTOH, the ranges of goods on offer, and the variety of sources from which they come, have expanded enormously – and that, unfortunately, has lead to more “holes in the systems” for trying to ensure that only “safe” items are put on the market. However, I think that there are several common factors which are tending to reinforce the overall trend towards safer products across the World, and thus in both N.America and Europe, such as: 1) More and more products are being developed for worldwide, as opposed to national, markets, and that means that the designers and manufacturers have to take all the market requirements into account – and, with the welcome rise in the importance of truly international safety standards, that means that those suppliers do more closely try to meet them (or then either fail to get their products into the big markets, or else get widely taken to account for supplying unsafe products) The NTRL approach in N. America and the EU CE marking requirements over here have both substantially contributed to that both directly in their own marketplaces and more globally as the less economically-developed countries (even the big ones like China!) pragmatically adopt the similar standards and regulatory controls on the basis that “if it works in the big countries then it should work for us as well” (and as well as encouraging and helping their own manufacturers to meet those same standards in order to have much wider export markets – or at least not to lose them!). 2) Intelligence gathering and dissemination of information on unsafe products is now much more worldwide – and so knowledge of those products quickly gets to both the regulators and the general public, and the latter are in a much better position to put pressure on the former to get the suppliers to get the problems fixed! Gone are the days when a supplier in one country could be reasonably sure that faults in products on one side of the World would not become public knowledge elsewhere – or that a local supplier could claim that a product was OK and a particular safety problem had never been known about in his marketplace, even though it was well known to the suppliers and regulators in another. National product-alert/recall regimes are much more established in both of the big markets – the legally-enforced systems such CPSC/OHSA in the US and RAPEX in the EU have more clout than they did before. Even if many of the individual regulators are short of funds to enforce the rules, the combined effects of all of them help collectively So where do I think that leaves us? Well, collectively a lot better than we were in 2008, and with a general way forward to better, safer products. Is the NTRL system in the US still necessary? Yes, because that is how the State regulators and the public expect/require it to be at present – but in another 10-20 years, maybe it will become a fond memory from the past! ☺ John Allen W.London, UK From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] Sent: 21 February 2015 03:21 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? 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
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
Doug, Dave, Don, Rich: Thanks for your input on this confusing topic. Based on your input, my tentative conclusions can be summarized as follows: 1) The NEC requires an NRTL listing on all products that connect to the public telecommunications network (including ordinary telephones). 2) Technically, the NEC is just a guide, and individual jurisdictions could revise this particular requirement if they chose to do so. 3) It seems likely that most jurisdictions have retained this requirement in their local versions of the code, but answering the question for a specific jurisdiction would require some investigation. 4) So, while an NRTL listing might seem to be mandatory, the main weakness with the current system is one of enforcement. The only way to get cited for non-compliance is for the local AHJ to see a non-listed product and “tag” it. Most AHJs are inspecting new construction and commercial properties, rather than established residential households. I suppose that in theory, an AHJ could go into a Wal-Mart or other retail store and tag consumer telephone products that lack an NRTL listing, but my impression is that few AHJ’s are that zealous. So, the requirement exists, but for consumer products used in the home, enforcement of the requirement may be relatively weak. The important thing I learned from this discussion is that when it comes to products that connect to the public telecommunications network, it’s not just a few jurisdictions like Los Angeles that require an NRTL listing. In effect, this requirement exists in any jurisdiction that has adopted the relevant clause from the NEC (which probably accounts for 99% of the USA). Joe Randolph Telecom Design Consultant Randolph Telecom, Inc. 781-721-2848 (USA) mailto:j...@randolph-telecom.com j...@randolph-telecom.com http://www.randolph-telecom.com http://www.randolph-telecom.com From: Doug Powell [mailto:doug...@gmail.com] Sent: Thursday, February 19, 2015 11:30 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? I agree with Dave and I would add that the statement in the NEC probably should have said public telecommunications network. There is a lot of variability with AHJs around the country. Just because a code is national. It doesn't mean it has been equally adopted at all local jurisdictions. For example City County of Los Angeles is on a three year cycle for reviewing and updating local requirements to the NEC but they schedule is such that they are never up to date with the very latest version. That said, if a clause has stood unmodified for several revision cycles you can have pretty good confidence it will continue for the time being. Also, I have to keep reminding myself that national codes are not product standards, they are in effect installation standards and the location such as household or commercial does matter. Since we must defer to the local AHJ, it's not always easy to figure this out. Thanks, - doug Douglas Powell http://www.linkedin.com/in/dougp01 From: Nyffenegger, Dave Sent: Wednesday, February 18, 2015 9:57 PM To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Nyffenegger, Dave Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? While the “N” standards for National, enforcement of the NEC for non-workplaces is with the AHJs which generally aren’t looking at consumer products unless they are integrated into new construction and part of permit inspection. I’ve not found any national enforcement of the NEC apart from OSHA. Perhaps there are some local codes covering consumer telcom products but if so enforcement is probably weak unless they are enforced at the retailer. I have seen some products (not necessarily telcom) that aren’t allowed to be shipped into certain states. Insurance companies could also enforce NEC requirements in homes by denying coverage if an inspection shows non-listed products (or requiring unlisted products to be removed). The TELCO can enforce product compliance or removal on any product causing problems with the network listed or otherwise. The local TELCO may also have a listing requirement for anything a consumer connects to their network. -Dave From: Joe Randolph [mailto:j...@randolph-telecom.com] Sent: Wednesday, February 18, 2015 11:15 PM To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Hello All: I know this topic has been discussed before, so I apologize in advance. For several years I have told my clients that *IN PRINCIPLE*, an NRTL listing for consumer-grade wireline telecom equipment (telephones, fax machines, answering machines, etc
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
Hi Joe: I suppose that in theory, an AHJ could go into a Wal-Mart or other retail store and tag consumer telephone products that lack an NRTL listing, but my impression is that few AHJ’s are that zealous. When I first came to Oregon (1960s), Oregon had two full-time inspectors who did just that. Laws or rules in many jurisdictions (e.g., Los Angeles) say that non-certified products cannot be sold or even offered for sale. One of my former employers was cited in Los Angeles for showing a non-certified product – an engineering sample – at an electronics show. So, the retailer is held responsible to sell only certified products. Most retailers abide by the laws that apply to them. Best regards, 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/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
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* - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
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 From: Richard Nute ri...@ieee.org To: EMC-PSTC@LISTSERV.IEEE.ORG, Date: 02/20/2015 02:21 PM Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Hi Joe: I suppose that in theory, an AHJ could go into a Wal-Mart or other retail store and tag consumer telephone products that lack an NRTL listing, but my impression is that few AHJ’s are that zealous. When I first came to Oregon (1960s), Oregon had two full-time inspectors who did just that. Laws or rules in many jurisdictions (e.g., Los Angeles) say that non-certified products cannot be sold or even offered for sale. One of my former employers was cited in Los Angeles for showing a non-certified product – an engineering sample – at an electronics show. So, the retailer is held responsible to sell only certified products. Most retailers abide by the laws that apply to them. Best regards, Rich __ This email has been scanned by the Symantec Email Security.cloud service. __ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
Joe, With regard to this line, The NEC code 800-4 additionally requires all equipment connected to a telecommunications network to be listed I am still at my temporary job 25 ½ years later, for which I was hired to help get the legacy ATT/Western Electric telephones that were still going to be manufactured Listed under the enforcement of the 1990 National Electrical Code. The Listing requirement is still in the 2014 NEC, but it is now 800.17, and reads as follows: VI. Listing Requirements 800.170 Equipment. Communications equipment shall be listed as being suitable for electrical connection to a communications network. Informational Note: One way to determine applicable requirements is to refer to UL 60950-1-2007, Standard for Safety of Information Technology Equipment; UL 1459-1999, Standard for Safety Telephone Equipment; or UL 1863-2004, Standard for Safety Communications Circuit Accessories. For information on listing requirements for cable routing assemblies and communications raceways, see UL 2024-2011, Standard for Signaling, Optical Fiber and Communications Cable Raceways and Cable Routing Assemblies. With regard to consumer phones, a non-Listed phone would be the exception at this point, but I have suspected that stores would not sell them if they are not Listed for insurance/liability reasons. Best regards, DON GIES ALCATEL-LUCENT SENIOR PRODUCT COMPLIANCE ENGINEER GLOBAL PRODUCT COMPLIANCE LABORATORY 600-700 Mountain Avenue Room 5B-104 Murray Hill, NJ 07974-0636 USA Phone: +1 908 582 5978 Fax: +1 908 582 0582 mailto:don.g...@alcatel-lucent.com don.g...@alcatel-lucent.com From: Joe Randolph [mailto:j...@randolph-telecom.com] Sent: Wednesday, February 18, 2015 11:15 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Hello All: I know this topic has been discussed before, so I apologize in advance. For several years I have told my clients that *IN PRINCIPLE*, an NRTL listing for consumer-grade wireline telecom equipment (telephones, fax machines, answering machines, etc.) is not mandatory in the USA. In theory, it is a voluntary choice on the part of the manufacturer. Then I go on to explain that there are exceptions. OSHA requires an NRTL listing on such products when used in the workplace. And, certain local jurisdictions such as the city of Los Angeles require it on all telephone equipment, including consumer products. This is my current understanding. Recently I was looking on the web for a list of local jurisdictions that, like Los Angeles, require an NRTL listing on pretty much every electronic product. I ran across this statement that I would like to better understand, The NEC code 800-4 additionally requires all equipment connected to a telecommunications network to be listed. Is this statement incorrect or have things changed? I dont have a current copy of the NEC, and even if I did, I do not have sufficient experience with the NEC to be confident that I am interpreting it correctly. I have attended many presentations where NEC experts explained that certain statements in the NEC do not mean what they first appear to mean, especially with respect to telecommunications equipment, where telecom network facilities are generally outside the scope of the NEC. My question here is not about network equipment, though. Im asking specifically about common consumer-grade wireline telephone terminal equipment (telephones, fax machines, answering machines, etc.) that consumers use in their own homes. For these types of devices, is an NRTL listing now required throughout the USA by the NEC? Joe Randolph Telecom Design Consultant Randolph Telecom, Inc. 781-721-2848 (USA) j...@randolph-telecom.com http://www.randolph-telecom.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
Hi Joe: The NEC is a model electrical code. The NFPA intends the code to be adopted by local jurisdictions. Some jurisdictions, like the City of Los Angeles, write their own codes. Other jurisdictions adopt the NEC with changes, some of which affect the certification of products and equipment mentioned in the code. Without studying the code in each jurisdiction, one cannot make a statement that certification is required for all electrical equipment in all jurisdictions. However, NRTL certification is acceptable, but not necessarily required, in all jurisdictions. Best regards, 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/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
I agree with Dave and I would add that the statement in the NEC probably should have said public telecommunications network. There is a lot of variability with AHJs around the country. Just because a code is national. It doesn't mean it has been equally adopted at all local jurisdictions. For example City County of Los Angeles is on a three year cycle for reviewing and updating local requirements to the NEC but they schedule is such that they are never up to date with the very latest version. That said, if a clause has stood unmodified for several revision cycles you can have pretty good confidence it will continue for the time being.Also, I have to keep reminding myself that national codes are not product standards, âthey are in effect installation standards and the location such as household or commercial does matter. Since we must defer to the local AHJ, it's not always easy to figure this out. Thanks, - dougDouglas Powellhttp://www.linkedin.com/in/dougp01 From: Nyffenegger, DaveSent: Wednesday, February 18, 2015 9:57 PMTo: EMC-PSTC@LISTSERV.IEEE.ORGReply To: Nyffenegger, DaveSubject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? While the âNâ standards for National, enforcement of the NEC for non-workplaces is with the AHJs which generally arenât looking at consumer products unless they are integrated into new construction and part of permit inspection. Iâve not found any national enforcement of the NEC apart from OSHA. Perhaps there are some local codes covering consumer telcom products but if so enforcement is probably weak unless they are enforced at the retailer. I have seen some products (not necessarily telcom) that arenât allowed to be shipped into certain states. Insurance companies could also enforce NEC requirements in homes by denying coverage if an inspection shows non-listed products (or requiring unlisted products to be removed). The TELCO can enforce product compliance or removal on any product causing problems with the network listed or otherwise. The local TELCO may also have a listing requirement for anything a consumer connects to their network. -Dave From: Joe Randolph [mailto:j...@randolph-telecom.com] Sent: Wednesday, February 18, 2015 11:15 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Hello All: I know this topic has been discussed before, so I apologize in advance. For several years I have told my clients that *IN PRINCIPLE*, an NRTL listing for consumer-grade wireline telecom equipment (telephones, fax machines, answering machines, etc.) is not mandatory in the USA. In theory, it is a voluntary choice on the part of the manufacturer. Then I go on to explain that there are exceptions. OSHA requires an NRTL listing on such products when used in the workplace. And, certain local jurisdictions such as the city of Los Angeles require it on all telephone equipment, including consumer products. This is my current understanding. Recently I was looking on the web for a list of local jurisdictions that, like Los Angeles, require an NRTL listing on pretty much every electronic product. I ran across this statement that I would like to better understand, âThe NEC code 800-4 additionally requires all equipment connected to a telecommunications network to be listed.â Is this statement incorrect or have things changed? I donât have a current copy of the NEC, and even if I did, I do not have sufficient experience with the NEC to be confident that I am interpreting it correctly. I have attended many presentations where NEC experts explained that certain statements in the NEC do not mean what they first appear to mean, especially with respect to telecommunications equipment, where telecom network facilities are generally âoutside the scopeâ of the NEC. My question here is not about network equipment, though. Iâm asking specifically about common consumer-grade wireline telephone terminal equipment (telephones, fax machines, answering machines, etc.) that consumers use in their own homes. For these types of devices, is an NRTL listing now required throughout the USA by the NEC? Joe Randolph Telecom Design Consultant Randolph Telecom, Inc. 781-721-2848 (USA) j...@randolph-telecom.com http://www.randolph-telecom.com - This message is from the IEEE Product Safety
Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
While the N standards for National, enforcement of the NEC for non-workplaces is with the AHJs which generally aren't looking at consumer products unless they are integrated into new construction and part of permit inspection. I've not found any national enforcement of the NEC apart from OSHA. Perhaps there are some local codes covering consumer telcom products but if so enforcement is probably weak unless they are enforced at the retailer. I have seen some products (not necessarily telcom) that aren't allowed to be shipped into certain states. Insurance companies could also enforce NEC requirements in homes by denying coverage if an inspection shows non-listed products (or requiring unlisted products to be removed). The TELCO can enforce product compliance or removal on any product causing problems with the network listed or otherwise. The local TELCO may also have a listing requirement for anything a consumer connects to their network. -Dave From: Joe Randolph [mailto:j...@randolph-telecom.com] Sent: Wednesday, February 18, 2015 11:15 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Hello All: I know this topic has been discussed before, so I apologize in advance. For several years I have told my clients that *IN PRINCIPLE*, an NRTL listing for consumer-grade wireline telecom equipment (telephones, fax machines, answering machines, etc.) is not mandatory in the USA. In theory, it is a voluntary choice on the part of the manufacturer. Then I go on to explain that there are exceptions. OSHA requires an NRTL listing on such products when used in the workplace. And, certain local jurisdictions such as the city of Los Angeles require it on all telephone equipment, including consumer products. This is my current understanding. Recently I was looking on the web for a list of local jurisdictions that, like Los Angeles, require an NRTL listing on pretty much every electronic product. I ran across this statement that I would like to better understand, The NEC code 800-4 additionally requires all equipment connected to a telecommunications network to be listed. Is this statement incorrect or have things changed? I don't have a current copy of the NEC, and even if I did, I do not have sufficient experience with the NEC to be confident that I am interpreting it correctly. I have attended many presentations where NEC experts explained that certain statements in the NEC do not mean what they first appear to mean, especially with respect to telecommunications equipment, where telecom network facilities are generally outside the scope of the NEC. My question here is not about network equipment, though. I'm asking specifically about common consumer-grade wireline telephone terminal equipment (telephones, fax machines, answering machines, etc.) that consumers use in their own homes. For these types of devices, is an NRTL listing now required throughout the USA by the NEC? Joe Randolph Telecom Design Consultant Randolph Telecom, Inc. 781-721-2848 (USA) j...@randolph-telecom.commailto:j...@randolph-telecom.com http://www.randolph-telecom.com - 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.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.orgmailto:sdoug...@ieee.org Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list
[PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment?
Hello All: I know this topic has been discussed before, so I apologize in advance. For several years I have told my clients that *IN PRINCIPLE*, an NRTL listing for consumer-grade wireline telecom equipment (telephones, fax machines, answering machines, etc.) is not mandatory in the USA. In theory, it is a voluntary choice on the part of the manufacturer. Then I go on to explain that there are exceptions. OSHA requires an NRTL listing on such products when used in the workplace. And, certain local jurisdictions such as the city of Los Angeles require it on all telephone equipment, including consumer products. This is my current understanding. Recently I was looking on the web for a list of local jurisdictions that, like Los Angeles, require an NRTL listing on pretty much every electronic product. I ran across this statement that I would like to better understand, The NEC code 800-4 additionally requires all equipment connected to a telecommunications network to be listed. Is this statement incorrect or have things changed? I don't have a current copy of the NEC, and even if I did, I do not have sufficient experience with the NEC to be confident that I am interpreting it correctly. I have attended many presentations where NEC experts explained that certain statements in the NEC do not mean what they first appear to mean, especially with respect to telecommunications equipment, where telecom network facilities are generally outside the scope of the NEC. My question here is not about network equipment, though. I'm asking specifically about common consumer-grade wireline telephone terminal equipment (telephones, fax machines, answering machines, etc.) that consumers use in their own homes. For these types of devices, is an NRTL listing now required throughout the USA by the NEC? Joe Randolph Telecom Design Consultant Randolph Telecom, Inc. 781-721-2848 (USA) j...@randolph-telecom.com mailto:j...@randolph-telecom.com http://www.randolph-telecom.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
