RE: Comment re: RE: SV: NRTL in the U.S.
Bill, John, et al - I subscribe at work with very nice bandwidth at no direct cost to me and yet I fully support your position. Indeed a quick perusal of the official posting policy for the list, presented below, makes the point. I dislike even e-cards attached to e-mails to the list. Regards, Peter L. Tarver, PE Product Safety Manager Sanmina-SCI Homologation Services San Jose, CA peter.tar...@sanmina-sci.com Reposted without permission and with all due apologies for treading on administrator's privilege: quote From: owner-emc-p...@majordomo.ieee.org on behalf of Rich Nute [ri...@sdd.hp.com] Sent: Sunday, November 10, 2002 4:22 PM To: Product Safety Technical Committee Subject: Administrative message -- posting formats Regarding postings, here is a re-statement of our guidelines that were sent to you when you subscribed: 1. No attachments (because many of our subscribers use dial-up modems for which message size determines the download time). If an attachment is appropriate or necessary to your message, then a) offer to e-mail it separately upon request, or b) make it available on an FTP site, or c) post it to a web site and provide the URL in your message. 2. Post in ASCII plain text. Do not use RTF, HTML, or similar formats. Not all mail readers are compatible with these formats, but all mail readers are compatible with ASCII plain text. In most cases (especially Outlook), you can set your mailer to always use ASCII plain text for messages sent to emc-pstc. Also, please don't write messages without carriage returns. Some mailer readers can't handle long lines, so the line is truncated and part of the line disappears. If you use CR (ENTER) at the end of each line, then each reader will see the same format as the one you wrote. 3. Please don't re-post the entire message string when replying to a message. Instead, pick out the passages to which you want to respond, enter your response, and delete the other text. This makes your point easier to understand, and helps keep the message size down for our modem- connected colleagues. Don't forget to delete the emc-pstc footer! :-) (Each posted message gets the footer attached; multiple footers provide no useful information, and just make downloads longer.) 4. If appropriate, when responding to a message, change the subject line to agree with the major point or content of your contribution. You can append was 'original subject' to your subject if you want to reference the original subject. This will help us when the subject matter strays from the original. 5. If you want to attach a signature, please do so in ASCII (for the same reason as posting in ASCII), not the business card format that is gaining popularity. Best regards, Richard Nute Administrator, emc-pstc listserver Tel: +1-858-655-3329 FAX: +1-858-655-4374 e-mail: ri...@ieee.org end quote This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: Comment re: RE: SV: NRTL in the U.S.
No offense taken Bill I will remember this in the future and offer an attachment to those who are interested instead of wasting everyone's bandwidth and internet connection time..I apologize to those this inconvenienced... regards, John From: b...@lyons.demon.co.uk [mailto:b...@lyons.demon.co.uk] Sent: Saturday, January 18, 2003 6:19 AM To: Tyra, John; emc-p...@majordomo.ieee.org Subject: Comment re: RE: SV: NRTL in the U.S. In message 418fbd441c22d5118d860003470d43160543f...@cupid.bose.com Tyra, John writes: Attached is an article from the Conformity 2002 Annual Guide titled Know When You Need To List Your Product And When You Don't written by John Curtis of Curtis- Strauss LLC. It gives some great information. For those who, rightfully, fear attachments, I ran this through a dedicated scanner and our outgoing e-mails are virus scanned so I hope that gives you some confidence as to the integrity of the attachment..Hope this helps... [all previous snipped] Dear John, No, I don't necessarily fear attachments, but they are a terrific nuisance to those on a dial-up connection, as I am, and annoying to those who don't need them, e.g. in this instance those who are not involved in the U.S. market for example. I was horrified when my connection seemed to be hanging and when the connection at last closed found that there was a mail of no less than 839,820 bytes, and which took a helluva time, and added quite a bit to my phone bill, to download. Please may I suggest that if you had emailed your full response to those directly involved and posted a note to EMC-PSTC saying how much you valued the article and from where it could be downloaded (or that you would mail it on request), this would have been equally helpful and saved a lot of bandwidth for everyone else. Apologies both to you, as I know you meant well, and to the list administrators who may think I am infringing on their prerogative, but not everyone on this list is on a broadband connection and I thought it right to explain this. (Actually, I think the list standing guidelines deprecate the posting of binaries/attachments.) Incidentally, I'm sure Conformity will be delighted at the free publicity, but there can be copright issues in posting articles or other third party documents to mailing lists or newsgroups. Again my apologies for any unintemded offense. With best wishes Bill -- Bill Lyons - b...@lyons.demon.co.uk / w.ly...@ieee.org This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Comment re: RE: SV: NRTL in the U.S.
In message 418fbd441c22d5118d860003470d43160543f...@cupid.bose.com Tyra, John writes: Attached is an article from the Conformity 2002 Annual Guide titled Know When You Need To List Your Product And When You Don't written by John Curtis of Curtis- Strauss LLC. It gives some great information. For those who, rightfully, fear attachments, I ran this through a dedicated scanner and our outgoing e-mails are virus scanned so I hope that gives you some confidence as to the integrity of the attachment..Hope this helps... [all previous snipped] Dear John, No, I don't necessarily fear attachments, but they are a terrific nuisance to those on a dial-up connection, as I am, and annoying to those who don't need them, e.g. in this instance those who are not involved in the U.S. market for example. I was horrified when my connection seemed to be hanging and when the connection at last closed found that there was a mail of no less than 839,820 bytes, and which took a helluva time, and added quite a bit to my phone bill, to download. Please may I suggest that if you had emailed your full response to those directly involved and posted a note to EMC-PSTC saying how much you valued the article and from where it could be downloaded (or that you would mail it on request), this would have been equally helpful and saved a lot of bandwidth for everyone else. Apologies both to you, as I know you meant well, and to the list administrators who may think I am infringing on their prerogative, but not everyone on this list is on a broadband connection and I thought it right to explain this. (Actually, I think the list standing guidelines deprecate the posting of binaries/attachments.) Incidentally, I'm sure Conformity will be delighted at the free publicity, but there can be copright issues in posting articles or other third party documents to mailing lists or newsgroups. Again my apologies for any unintemded offense. With best wishes Bill -- Bill Lyons - b...@lyons.demon.co.uk / w.ly...@ieee.org This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: SV: SV: NRTL in the U.S.
I read in !emc-pstc that Amund Westin am...@westin-emission.no wrote (in lfenjlpmmjbmhpeibnilmebgckaa.am...@westin-emission.no) about 'SV: SV: NRTL in the U.S.' on Fri, 17 Jan 2003: The electrical safety legislation seems to be a bit more complicated in U.S. compared to EU. A very great deal more complicated, because the practical requirements are not centralized but delegated down though the local government chain, and in some cases jurisdictions overlap or are not clearly segregated. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: SV: NRTL in the U.S.
I read in !emc-pstc that drcuthbert drcuthb...@micron.com wrote (in cfefa50c9bcad21197470001fa7eba6b14121...@ntexchange05.micron.com) about 'SV: NRTL in the U.S.' on Fri, 17 Jan 2003: For example, UL 60950 the same as EN 60950. Are you sure? I agree that much of the content is the same, but I think there are still some differences. It's also necessary to be specific about which editions are compared. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: SV: NRTL in the U.S.
This is a multi-part message in MIME format. Attached is an article from the Conformity 2002 Annual Guide titled Know When You Need To List Your Product And When You Don't written by John Curtis of Curtis- Strauss LLC. It gives some great information. For those who, rightfully, fear attachments, I ran this through a dedicated scanner and our outgoing e-mails are virus scanned so I hope that gives you some confidence as to the integrity of the attachment..Hope this helps... From: Amund Westin [mailto:am...@westin-emission.no] Sent: Friday, January 17, 2003 2:25 PM To: emc-p...@majordomo.ieee.org Subject: SV: SV: NRTL in the U.S. I would never dare to declare U.S. compliance without testing and certify via a NRTL. But what I am struggling with, is to gain knowledge about the basic electrical safety laws in U.S. Maybe I do not need legally to go through a NRTL, but that does not mean I would, even if I could. The electrical safety legislation seems to be a bit more complicated in U.S. compared to EU. Best regards Amund Westin, Oslo / Norway -Opprinnelig melding- Fra: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av John Woodgate Sendt: 17. januar 2003 13:25 Til: emc-p...@majordomo.ieee.org Emne: Re: SV: NRTL in the U.S. I read in !emc-pstc that Amund Westin am...@westin-emission.no wrote (in lfenjlpmmjbmhpeibnilaeapckaa.am...@westin-emission.no) about 'SV: NRTL in the U.S.' on Fri, 17 Jan 2003: Just for a few seconds forget the customers requirements, is it therefore a correct interpretation that electrical equipment (ITE, household appliances, radio transmitters, etc) must be certified in order to follow the U.S. laws I think you really already had the strictly correct answer, but it's over-complicated. The practical answer is that it's much better to have certification than not to have it, unless the cost of certification would make your product uncompetitive against other, uncertified products in competition with yours. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list Title: RE: SV: NRTL in the U.S. Attached is an article from the Conformity 2002 Annual Guide titled Know When You Need To List Your Product And When You Don't written by John Curtis of Curtis- Strauss LLC. It gives some great information. For those who, rightfully, fear attachments, I ran this through a dedicated scanner and our outgoing e-mails are virus scanned so I hope that gives you some confidence as to the integrity of the attachment..Hope this helps... -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: Friday, January 17, 2003 2:25 PM To: emc-p...@majordomo.ieee.org Subject: SV: SV: NRTL in the U.S. I would never dare to declare U.S. compliance without testing and certify via a NRTL. But what I am struggling with, is to gain knowledge about the basic electrical safety laws in U.S. Maybe I do not need legally to go through a NRTL, but that does not mean I would, even if I could. The electrical safety legislation seems to be a bit more complicated in U.S. compared to EU. Best regards Amund Westin, Oslo / Norway -Opprinnelig melding- Fra: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av John
RE: SV: NRTL in the U.S.
This is partially true in that while the there are some EU standards harmonized with UL standards, they are not completely harmonized and you still have to consider the U.S. National Deviations to be totally complaint a good example is component approvals. The UL standard will usually require a component to be compliant to a UL component standard while the IEC/EN standards reference the IEC/EN component standards. Another good example where this will kill you if you only consider the IEC/ EN requirements is for UL6500...The IEC/EN 60065 standard only requires a fire enclosure to be rated 94-HB, in most cases, while the UL standard has a U.S. deviation which requires 94-V2 plastic.so beware and check for all National Deviations.. From: drcuthbert [mailto:drcuthb...@micron.com] Sent: Friday, January 17, 2003 4:31 PM To: 'Amund Westin'; emc-p...@majordomo.ieee.org Subject: RE: SV: NRTL in the U.S. Amund, Several EU standards have been harmonized with the United States UL standards. A list can be found at http://ulstandardsinfonet.ul.com/catalog/stdscatframe.html For example, UL 60950 the same as EN 60950. So, I'm thinking that if your device meets EU safety requirements it will make it through UL as long it has been designed to a harmonized standard. Does this sound reasonable to anyone or am I off the mark? Dave Cuthbert From: Amund Westin [mailto:am...@westin-emission.no] Sent: Friday, January 17, 2003 12:25 PM To: emc-p...@majordomo.ieee.org Subject: SV: SV: NRTL in the U.S. I would never dare to declare U.S. compliance without testing and certify via a NRTL. But what I am struggling with, is to gain knowledge about the basic electrical safety laws in U.S. Maybe I do not need legally to go through a NRTL, but that does not mean I would, even if I could. The electrical safety legislation seems to be a bit more complicated in U.S. compared to EU. Best regards Amund Westin, Oslo / Norway -Opprinnelig melding- Fra: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av John Woodgate Sendt: 17. januar 2003 13:25 Til: emc-p...@majordomo.ieee.org Emne: Re: SV: NRTL in the U.S. I read in !emc-pstc that Amund Westin am...@westin-emission.no wrote (in lfenjlpmmjbmhpeibnilaeapckaa.am...@westin-emission.no) about 'SV: NRTL in the U.S.' on Fri, 17 Jan 2003: Just for a few seconds forget the customers requirements, is it therefore a correct interpretation that electrical equipment (ITE, household appliances, radio transmitters, etc) must be certified in order to follow the U.S. laws I think you really already had the strictly correct answer, but it's over-complicated. The practical answer is that it's much better to have certification than not to have it, unless the cost of certification would make your product uncompetitive against other, uncertified products in competition with yours. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave
RE: SV: NRTL in the U.S.
Amund, I think early on you mentioned that you didn't want to be restricted where you could sell. So if that's the bottom line then I think its off the NRTL you go. Even given the single condition of the City of LA which not only requires it (or a City of LA inspection where they claim to use the UL standards). I think you will also find that regardless of what the government says, many of your clients will ask for it if it is used as part of their system. We occasionally sell things to Public Utility companies that have legal exceptions these OSHA, and the NFPA, yet they still require inspection or Listing to a NRTL .I think you could make some sales without any of this, either through no requirements, or even more likely, through lack of inspection/enforcement in some areas, but that doesn't give you an unrestricted product if you will. Like any country some of laws are pretty good some of them aren't. Given that we are a pretty feisty bunch by nature (well, not me certainly) somebody always has a differing opinion and consensus isn't all that easy. Then again I don't know that its any easier to get consensus in the EU, is it? Heck we get one president who immediately undoes the laws the last president did, only to have them re-done or undone by the next guy - heavy sigh! Gary This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: SV: NRTL in the U.S.
Hi Dave, You are not correct when you stated that UL60950 is the same as EN60950. Actually, both of these standards are based on IEC60950, but they are not equal to each other. Each has specific national deviations from IEC60950 that must be addressed if a product is to be successfully evaluated to either standard. Comments? Best regards, Ron Pickard rpick...@hypercom.com drcuthb...@micron.com Sent by: To: am...@westin-emission.no, emc-p...@majordomo.ieee.org owner-emc-pstc@majordocc: mo.ieee.org Subject: RE: SV: NRTL in the U.S. 01/17/2003 02:30 PM Please respond to drcuthbert Amund, Several EU standards have been harmonized with the United States UL standards. A list can be found at http://ulstandardsinfonet.ul.com/catalog/stdscatframe.html For example, UL 60950 the same as EN 60950. So, I'm thinking that if your device meets EU safety requirements it will make it through UL as long it has been designed to a harmonized standard. Does this sound reasonable to anyone or am I off the mark? Dave Cuthbert From: Amund Westin [mailto:am...@westin-emission.no] Sent: Friday, January 17, 2003 12:25 PM To: emc-p...@majordomo.ieee.org Subject: SV: SV: NRTL in the U.S. I would never dare to declare U.S. compliance without testing and certify via a NRTL. But what I am struggling with, is to gain knowledge about the basic electrical safety laws in U.S. Maybe I do not need legally to go through a NRTL, but that does not mean I would, even if I could. The electrical safety legislation seems to be a bit more complicated in U.S. compared to EU. Best regards Amund Westin, Oslo / Norway -Opprinnelig melding- Fra: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av John Woodgate Sendt: 17. januar 2003 13:25 Til: emc-p...@majordomo.ieee.org Emne: Re: SV: NRTL in the U.S. I read in !emc-pstc that Amund Westin am...@westin-emission.no wrote (in lfenjlpmmjbmhpeibnilaeapckaa.am...@westin-emission.no) about 'SV: NRTL in the U.S.' on Fri, 17 Jan 2003: Just for a few seconds forget the customers requirements, is it therefore a correct interpretation that electrical equipment (ITE, household appliances, radio transmitters, etc) must be certified in order to follow the U.S. laws I think you really already had the strictly correct answer, but it's over-complicated. The practical answer is that it's much better to have certification than not to have it, unless the cost of certification would make your product uncompetitive against other, uncertified products in competition with yours. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac
RE: SV: NRTL in the U.S.
Amund, Several EU standards have been harmonized with the United States UL standards. A list can be found at http://ulstandardsinfonet.ul.com/catalog/stdscatframe.html For example, UL 60950 the same as EN 60950. So, I'm thinking that if your device meets EU safety requirements it will make it through UL as long it has been designed to a harmonized standard. Does this sound reasonable to anyone or am I off the mark? Dave Cuthbert From: Amund Westin [mailto:am...@westin-emission.no] Sent: Friday, January 17, 2003 12:25 PM To: emc-p...@majordomo.ieee.org Subject: SV: SV: NRTL in the U.S. I would never dare to declare U.S. compliance without testing and certify via a NRTL. But what I am struggling with, is to gain knowledge about the basic electrical safety laws in U.S. Maybe I do not need legally to go through a NRTL, but that does not mean I would, even if I could. The electrical safety legislation seems to be a bit more complicated in U.S. compared to EU. Best regards Amund Westin, Oslo / Norway -Opprinnelig melding- Fra: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av John Woodgate Sendt: 17. januar 2003 13:25 Til: emc-p...@majordomo.ieee.org Emne: Re: SV: NRTL in the U.S. I read in !emc-pstc that Amund Westin am...@westin-emission.no wrote (in lfenjlpmmjbmhpeibnilaeapckaa.am...@westin-emission.no) about 'SV: NRTL in the U.S.' on Fri, 17 Jan 2003: Just for a few seconds forget the customers requirements, is it therefore a correct interpretation that electrical equipment (ITE, household appliances, radio transmitters, etc) must be certified in order to follow the U.S. laws I think you really already had the strictly correct answer, but it's over-complicated. The practical answer is that it's much better to have certification than not to have it, unless the cost of certification would make your product uncompetitive against other, uncertified products in competition with yours. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
SV: SV: NRTL in the U.S.
I would never dare to declare U.S. compliance without testing and certify via a NRTL. But what I am struggling with, is to gain knowledge about the basic electrical safety laws in U.S. Maybe I do not need legally to go through a NRTL, but that does not mean I would, even if I could. The electrical safety legislation seems to be a bit more complicated in U.S. compared to EU. Best regards Amund Westin, Oslo / Norway -Opprinnelig melding- Fra: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av John Woodgate Sendt: 17. januar 2003 13:25 Til: emc-p...@majordomo.ieee.org Emne: Re: SV: NRTL in the U.S. I read in !emc-pstc that Amund Westin am...@westin-emission.no wrote (in lfenjlpmmjbmhpeibnilaeapckaa.am...@westin-emission.no) about 'SV: NRTL in the U.S.' on Fri, 17 Jan 2003: Just for a few seconds forget the customers requirements, is it therefore a correct interpretation that electrical equipment (ITE, household appliances, radio transmitters, etc) must be certified in order to follow the U.S. laws I think you really already had the strictly correct answer, but it's over-complicated. The practical answer is that it's much better to have certification than not to have it, unless the cost of certification would make your product uncompetitive against other, uncertified products in competition with yours. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: SV: NRTL in the U.S.
I read in !emc-pstc that Amund Westin am...@westin-emission.no wrote (in lfenjlpmmjbmhpeibnilaeapckaa.am...@westin-emission.no) about 'SV: NRTL in the U.S.' on Fri, 17 Jan 2003: Just for a few seconds forget the customers requirements, is it therefore a correct interpretation that electrical equipment (ITE, household appliances, radio transmitters, etc) must be certified in order to follow the U.S. laws I think you really already had the strictly correct answer, but it's over-complicated. The practical answer is that it's much better to have certification than not to have it, unless the cost of certification would make your product uncompetitive against other, uncertified products in competition with yours. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: SV: NRTL in the U.S.
Hello Amund, Unfortunately, your question can be broadly interpreted. As a matter of law the U.S. has agencies (FCC, FDA) that require product approvals depending on their intended use and function. Also, the U.S. has environmental laws that are overseen by the Environmental Protection Agency (EPA) and usually apply to substances used in a product that have been identified by EPA as toxic or hazardous. OSHA you have already heard about. So much for the federal level, when you get down to the state level, most laws usually are those that are enacted where interstate commerce does not take place. I say this because FDA does not have jurisdiction on medical products if they are entirely made in one state for sale only in that state. In these cases a state will have their own version of FDA, like California. As you can see, the U.S. can be a complex market. However, to answer your question, you need to know what your product is and what its intended market and use are before you can determine what laws you need to comply with in the U.S., both at the federal and state level. However, the problem is that even we in the U.S. are not aware of all state and local laws as they apply to our products. We keep finding something new because in a country with 50 states there are 50 different governments enacting laws. Keeping tabs on all 50 states is not easy. Best regards, Ron Wellman At 10:55 AM 1/17/2003 +0100, Amund Westin wrote: Hi Safety folks, Many good points in this discussion. For us up here in Scandinavia, we se the U.S. market as one Market and we can not (may be we should..) go into law details for the City of LA, Santa Clara County and so on. If there are States or Cities in the U.S. which require by law that an electrical equipment must be certified by NRTL ( I guess we talk about UL, CSA, Intertek, etc), that will be the most important information for us. That means, if we will enter the U.S. market with a product and we do not know where it will be used (some place in the range Key West to Vancouver ), we have to be aware if Certification and/or listing is required by law. Just for a few seconds forget the customers requirements, is it therefore a correct interpretation that electrical equipment (ITE, household appliances, radio transmitters, etc) must be certified in order to follow the U.S. laws ? Best regards Amund Oslo / Norway -Opprinnelig melding- Fra: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]Pa vegne av gr...@test4safety.com Sendt: 15. januar 2003 21:23 Til: 'Rich Nute' Kopi: 'Product Safety Technical Committee' Emne: RE: NRTL in the U.S. Hi Rich, I argue with some of your statements. :-) Thanks - at least I know that I'm alive and not dreaming! Dave's question - Does this apply to in-house test equipment? Hi Dave - Good question (Please see attached). I'm sorry about the file size but I took it from the Department of Labor web site several years ago when this topic first came up. (It repeats about every 6 months if my memory serves) I believe Dave's question was in regard to compliance to local electrical codes, not to OSHA requirements. Yes - but that is not the full story - and it would be easy to misapply a YES-NO answer to a similar (but inappropriate) situation. Local electrical codes (e.g., NEC) require all electrical equipment that comprises an electrical installation to be approved for the purpose. This is taken to mean listed or otherwise certified for safety. Codes are enforced by local inspectors and by licensed electricians who perform the installation. Department of Labor (OSHA) regulations require that the electrical equipment used by employees be certified for safety by an NRTL. Regulations are enforced by the employer as well as by periodically by inspectors from OSHA. While these two sets of rules are independent of each other, one solution satisfies both rules: listing. As Albert Camus wrote (in The Plague) The difference was slight - and the result the same. Perhaps someone can comment about FIRE and ELECTRIC SHOCK reports on non-Listed versus LISTED products. However - the BEST and MOST RELEVANT people to ask are your Corporate Insurers. It would be little good meeting the local code to find that there is small print in your corporate liability insurance leaves you with personal liability for any failure - injury or death!!! Even if you can avoid NRTL testing then you need to protect yourself - NOT YOUR COMPANY - (people go to jail - companies don't). As a general rule, employees cannot be held personally liable if they are doing work in accordance with direction from the employer. IF THEY CAN PROVE IT! I'm sure that no 'employer' would say I employed him as a professional - I expected him
SV: NRTL in the U.S.
Hi Safety folks, Many good points in this discussion. For us up here in Scandinavia, we se the U.S. market as one Market and we can not (may be we should..) go into law details for the City of LA, Santa Clara County and so on. If there are States or Cities in the U.S. which require by law that an electrical equipment must be certified by NRTL ( I guess we talk about UL, CSA, Intertek, etc), that will be the most important information for us. That means, if we will enter the U.S. market with a product and we do not know where it will be used (some place in the range Key West to Vancouver ), we have to be aware if Certification and/or listing is required by law. Just for a few seconds forget the customers requirements, is it therefore a correct interpretation that electrical equipment (ITE, household appliances, radio transmitters, etc) must be certified in order to follow the U.S. laws ? Best regards Amund Oslo / Norway -Opprinnelig melding- Fra: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]Pa vegne av gr...@test4safety.com Sendt: 15. januar 2003 21:23 Til: 'Rich Nute' Kopi: 'Product Safety Technical Committee' Emne: RE: NRTL in the U.S. Hi Rich, I argue with some of your statements. :-) Thanks - at least I know that I'm alive and not dreaming! Dave's question - Does this apply to in-house test equipment? Hi Dave - Good question (Please see attached). I'm sorry about the file size but I took it from the Department of Labor web site several years ago when this topic first came up. (It repeats about every 6 months if my memory serves) I believe Dave's question was in regard to compliance to local electrical codes, not to OSHA requirements. Yes - but that is not the full story - and it would be easy to misapply a YES-NO answer to a similar (but inappropriate) situation. Local electrical codes (e.g., NEC) require all electrical equipment that comprises an electrical installation to be approved for the purpose. This is taken to mean listed or otherwise certified for safety. Codes are enforced by local inspectors and by licensed electricians who perform the installation. Department of Labor (OSHA) regulations require that the electrical equipment used by employees be certified for safety by an NRTL. Regulations are enforced by the employer as well as by periodically by inspectors from OSHA. While these two sets of rules are independent of each other, one solution satisfies both rules: listing. As Albert Camus wrote (in The Plague) The difference was slight - and the result the same. Perhaps someone can comment about FIRE and ELECTRIC SHOCK reports on non-Listed versus LISTED products. However - the BEST and MOST RELEVANT people to ask are your Corporate Insurers. It would be little good meeting the local code to find that there is small print in your corporate liability insurance leaves you with personal liability for any failure - injury or death!!! Even if you can avoid NRTL testing then you need to protect yourself - NOT YOUR COMPANY - (people go to jail - companies don't). As a general rule, employees cannot be held personally liable if they are doing work in accordance with direction from the employer. IF THEY CAN PROVE IT! I'm sure that no 'employer' would say I employed him as a professional - I expected him to act accordingly - Had I known the outcome I would never have instructed him to or even I did not - it is our policy to comply with ALL legislation - he obviously made a mistake - let him prove otherwise. But, today's focus on profits motivates many insurers to creatively find a way to prevent payment of claims or to recover the loss from some other source. Gee - I can't imagine that ever happening However, recovering from the likes of you and me would not come close to covering the loss. There are bigger fish and deeper pockets. OK - but suppose it did - how long would it be before legal costs bankrupted you? - Maybe that are others that do not share you optimism. What about Joint and Several actions - if I wanted to bring a successful action I would attack the designer - BECAUSE I know that his funds would be exhausted quickly AND that after disposing of him/her I would have the case proven (will minimal cost) and then go to find the deep pockets. Try to think of 'compliance' not as PASS or FAIL; but as a continuum from DEPLORABLE through ACCEPTABLE to the UNATTAINABLE. These abstractions, DEPLORABLE, ACCEPTABLE, and UNATTAINABLE, are difficult to use because they are not very measurable. PASS and FAIL at least provide a line by which to discriminate between acceptable and unacceptable. Correct - the word I used to describe them was CONTINUUM that is not measurable either. I was trying to set sights higher than Our product PASSED - where PASSED equals look
RE: NRTL in the U.S.
Hi Rich, I argue with some of your statements. :-) Thanks - at least I know that I'm alive and not dreaming! Dave's question - Does this apply to in-house test equipment? Hi Dave - Good question (Please see attached). I'm sorry about the file size but I took it from the Department of Labor web site several years ago when this topic first came up. (It repeats about every 6 months if my memory serves) I believe Dave's question was in regard to compliance to local electrical codes, not to OSHA requirements. Yes - but that is not the full story - and it would be easy to misapply a YES-NO answer to a similar (but inappropriate) situation. Local electrical codes (e.g., NEC) require all electrical equipment that comprises an electrical installation to be approved for the purpose. This is taken to mean listed or otherwise certified for safety. Codes are enforced by local inspectors and by licensed electricians who perform the installation. Department of Labor (OSHA) regulations require that the electrical equipment used by employees be certified for safety by an NRTL. Regulations are enforced by the employer as well as by periodically by inspectors from OSHA. While these two sets of rules are independent of each other, one solution satisfies both rules: listing. As Albert Camus wrote (in The Plague) The difference was slight - and the result the same. Perhaps someone can comment about FIRE and ELECTRIC SHOCK reports on non-Listed versus LISTED products. However - the BEST and MOST RELEVANT people to ask are your Corporate Insurers. It would be little good meeting the local code to find that there is small print in your corporate liability insurance leaves you with personal liability for any failure - injury or death!!! Even if you can avoid NRTL testing then you need to protect yourself - NOT YOUR COMPANY - (people go to jail - companies don't). As a general rule, employees cannot be held personally liable if they are doing work in accordance with direction from the employer. IF THEY CAN PROVE IT! I'm sure that no 'employer' would say I employed him as a professional - I expected him to act accordingly - Had I known the outcome I would never have instructed him to or even I did not - it is our policy to comply with ALL legislation - he obviously made a mistake - let him prove otherwise. But, today's focus on profits motivates many insurers to creatively find a way to prevent payment of claims or to recover the loss from some other source. Gee - I can't imagine that ever happening However, recovering from the likes of you and me would not come close to covering the loss. There are bigger fish and deeper pockets. OK - but suppose it did - how long would it be before legal costs bankrupted you? - Maybe that are others that do not share you optimism. What about Joint and Several actions - if I wanted to bring a successful action I would attack the designer - BECAUSE I know that his funds would be exhausted quickly AND that after disposing of him/her I would have the case proven (will minimal cost) and then go to find the deep pockets. Try to think of 'compliance' not as PASS or FAIL; but as a continuum from DEPLORABLE through ACCEPTABLE to the UNATTAINABLE. These abstractions, DEPLORABLE, ACCEPTABLE, and UNATTAINABLE, are difficult to use because they are not very measurable. PASS and FAIL at least provide a line by which to discriminate between acceptable and unacceptable. Correct - the word I used to describe them was CONTINUUM that is not measurable either. I was trying to set sights higher than Our product PASSED - where PASSED equals look-at-that it passed! - pheeeweee We, at HP and Agilent, use a three-block model to evaluate safety: +-++-++-+ |hazardous|| || | |energy |---|safeguard|---| body | |source || || | +-++-++-+ We say that, for every hazardous energy source, there must be one or more safeguards interposed between the source and the body. The safeguard has a number of parameters that must be controlled such that the safeguard remains effective for the equipment lifetime. If we do a thorough job, then we have a safe product -- unless the safeguard is subjected to influences greater than the design level. This is a practical, powerful, and measurable model for safety. I agree - I use a similar model and do a forward and backward pass. The problem with all these models and reviews is that if we cannot prove safety. The best we can hope for is that our assessments fail to prove a hazard. So if we are good at finding hazards we are better safety engineers than someone that cannot find any. Best regards Gregg This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at:
Re: NRTL in the U.S.
Hi Gregg: I argue with some of your statements. :-) Dave's question - Does this apply to in-house test equipment? Hi Dave - Good question (Please see attached). I'm sorry about the file size but I took it from the Department of Labor web site several years ago when this topic first came up. (It repeats about every 6 months if my memory serves) I believe Dave's question was in regard to compliance to local electrical codes, not to OSHA requirements. Local electrical codes (e.g., NEC) require all electrical equipment that comprises an electrical installation to be approved for the purpose. This is taken to mean listed or otherwise certified for safety. Codes are enforced by local inspectors and by licensed electricians who perform the installation. Department of Labor (OSHA) regulations require that the electrical equipment used by employees be certified for safety by an NRTL. Regulations are enforced by the employer as well as by periodically by inspectors from OSHA. While these two sets of rules are independent of each other, one solution satisfies both rules: listing. However - the BEST and MOST RELEVANT people to ask are your Corporate Insurers. It would be little good meeting the local code to find that there is small print in your corporate liability insurance leaves you with personal liability for any failure - injury or death!!! Even if you can avoid NRTL testing then you need to protect yourself - NOT YOUR COMPANY - (people go to jail - companies don't). As a general rule, employees cannot be held personally liable if they are doing work in accordance with direction from the employer. But, today's focus on profits motivates many insurers to creatively find a way to prevent payment of claims or to recover the loss from some other source. However, recovering from the likes of you and me would not come close to covering the loss. There are bigger fish and deeper pockets. Try to think of 'compliance' not as PASS or FAIL; but as a continuum from DEPLORABLE through ACCEPTABLE to the UNATTAINABLE. These abstractions, DEPLORABLE, ACCEPTABLE, and UNATTAINABLE, are difficult to use because they are not very measurable. PASS and FAIL at least provide a line by which to discriminate between acceptable and unacceptable. We, at HP and Agilent, use a three-block model to evaluate safety: +-++-++-+ |hazardous|| || | |energy |---|safeguard|---| body | |source || || | +-++-++-+ We say that, for every hazardous energy source, there must be one or more safeguards interposed between the source and the body. The safeguard has a number of parameters that must be controlled such that the safeguard remains effective for the equipment lifetime. If we do a thorough job, then we have a safe product -- unless the safeguard is subjected to influences greater than the design level. This is a practical, powerful, and measurable model for safety. Best regards, Rich This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: NRTL in the U.S.
Hi Gary: Rich Nute (I think) wrote and excellent article or e-mail on this not too long ago and should be in the archives. Its pretty concise and clear but goes into some pretty good specifics and the state laws and how they very and you will find it very helpful. Unfortunately, the archives are not available at this time due to our web site transition from Akiva to Community Zero. We hope to have the archives available in another month or so. Best regards, Rich This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: NRTL in the U.S.
Hello Sam, Chances are if you are ever involved in a product liability law suit in the United States that the jury will look at you very unfavorably if your product is not NRTL Listed. Also, expect that the NRTL will not help defend you in a law suit even if your product is Listed with them. A Catch 22. BTW, enforcement of law should never be a condition of compliance. Market surveillance does happen. Just because you have not been caught does not mean that the law is not being enforced. However, this really depends on the integrity of your company and its management, and whether they are willing to except risk of liability. Makes you wonder why we have whistle blowers. Best regards, Ron Wellman At 05:48 PM 1/14/2003 -0600, Sam Davis wrote: Another interpretation of the question may be Where is the NRTL requirement strictly enforced? (which is a much larger list than where it is required.) Where can you get away without a NRTL mark? That depends in part on the product, the market, and the distribution scheme. Which brings this to mind- Is a law a law if it is not enforced? (Many politically controversial issues come to mind here.) I have had many clients who actually want to waive tests based on the argument We've been selling these for years, and have had no complaints yet. It is not uncommon to be able to sell laboratory equipment, with a CE mark only, all over the US. Even some medical equipment (which truly surprised me). Basically, if the client (or reseller) doesn't care, and the electrical inspector doesn't see it, it can be sold and used without a NRTL mark. The same logic can be used in illicit drug trafficking as well. (If I don't get caught, I'm not breaking the law). I am not suggesting that any product to be sold in the US not be NRTL'ed, but just expressing another viewpoint. Besides the fact that my employer makes money when we sell a NRTL job, my risk vs reward mindset tells me the cash saved now (a few $k - not much reward) ain't worth the potential injuries, deaths, and lawsuits (where the risk amount depends on your company's assets). NRTL it, and the question is moot. Sam This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: NRTL in the U.S.
Good point Sam, There is one other point on the whole to NRTL, or not scenario. The more visibility a company attains in the marketplace, the more their competition looks for a weakness in the competing product's armor. Best case scenario: Your product is compliant, but is not listed, your competitor will use ours has been independently tested and listed by a Nationally Recognized Testing Laboratory for safety, theirs hasn't against you every time while in front of the customer. (some of you will say that this doesn't guarantee safety, and you are 100% correct. But it makes no difference once the customer hears this, especially for the well trained sales rep who uses this to their full advantage.) Worst case scenario: Your product is not compliant, competitor reports the non compliant product, so to level the playing field because they have spent the additional funds on compliance, which puts the non compliant competitor at an unfair advantage. There are other side disasters for a non compliant company that's found out through competitor whistle blowing. I won't go into them, but they all cost money, large. Garry Hojan Strategic Compliance Services www.regulatory-compliance.com From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Sam Davis Sent: Tuesday, January 14, 2003 3:49 PM To: emc-p...@majordomo.ieee.org Subject: RE: NRTL in the U.S. Another interpretation of the question may be Where is the NRTL requirement strictly enforced? (which is a much larger list than where it is required.) Where can you get away without a NRTL mark? That depends in part on the product, the market, and the distribution scheme. Which brings this to mind- Is a law a law if it is not enforced? (Many politically controversial issues come to mind here.) I have had many clients who actually want to waive tests based on the argument We've been selling these for years, and have had no complaints yet. It is not uncommon to be able to sell laboratory equipment, with a CE mark only, all over the US. Even some medical equipment (which truly surprised me). Basically, if the client (or reseller) doesn't care, and the electrical inspector doesn't see it, it can be sold and used without a NRTL mark. The same logic can be used in illicit drug trafficking as well. (If I don't get caught, I'm not breaking the law). I am not suggesting that any product to be sold in the US not be NRTL'ed, but just expressing another viewpoint. Besides the fact that my employer makes money when we sell a NRTL job, my risk vs reward mindset tells me the cash saved now (a few $k - not much reward) ain't worth the potential injuries, deaths, and lawsuits (where the risk amount depends on your company's assets). NRTL it, and the question is moot. Sam This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: NRTL in the U.S.
Another interpretation of the question may be Where is the NRTL requirement strictly enforced? (which is a much larger list than where it is required.) Where can you get away without a NRTL mark? That depends in part on the product, the market, and the distribution scheme. Which brings this to mind- Is a law a law if it is not enforced? (Many politically controversial issues come to mind here.) I have had many clients who actually want to waive tests based on the argument We've been selling these for years, and have had no complaints yet. It is not uncommon to be able to sell laboratory equipment, with a CE mark only, all over the US. Even some medical equipment (which truly surprised me). Basically, if the client (or reseller) doesn't care, and the electrical inspector doesn't see it, it can be sold and used without a NRTL mark. The same logic can be used in illicit drug trafficking as well. (If I don't get caught, I'm not breaking the law). I am not suggesting that any product to be sold in the US not be NRTL'ed, but just expressing another viewpoint. Besides the fact that my employer makes money when we sell a NRTL job, my risk vs reward mindset tells me the cash saved now (a few $k - not much reward) ain't worth the potential injuries, deaths, and lawsuits (where the risk amount depends on your company's assets). NRTL it, and the question is moot. Sam This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: NRTL in the U.S.
Hello Peter, This is probably true when an electrician is involved in a product installation. However, the majority of products that we are dealing with do not require an electrician to install. They are either installed by the Customer or a representative of the product manufacturer. The acceptance of liability in using a Non-Listed product is no different in accepting the liability of using a Listed one because being NRTL Listed doesn't always mean your product is safe. Just take a look at all the products that are being recalled by the Consumer Product Safety Commission (CPSC) that are NRTL Listed. Best regards, Ron Wellman At 03:06 PM 1/14/2003 -0500, peter.a.manfredo...@us.ul.com wrote: The truth is that an independent licensed electrician will not connect a product that is not Listed. In commercial or industrial environments, there may be a Licensed Professional Engineer on staff, who can approve a product but he takes the personal liability for Non-Listed products. Manfredonia -- For more information about UL, its Marks, and its services for EMC, quality registrations and product certifications for global markets, please access our web sites at http://www.ul.com and http://www.ulc.ca, or contact your local sales representative. -- * Internet E-mail Confidentiality Disclaimer ** This e-mail message may contain privileged or confidential information. If you are not the intended recipient, you may not disclose, use, disseminate, distribute, copy or rely upon this message or attachment in any way. If you received this e-mail message in error, please return by forwarding the message and its attachments to the sender. Underwriters Laboratories Inc. and its affiliates do not accept liability for any errors, omissions, corruption or virus in the contents of this message or any attachments that arise as a result of e-mail transmission. * This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: NRTL in the U.S.
Hi Dave: Does this apply to in-house test equipment? That is, equipment that is built in-house and remains on site? In the past I have designed in-house equipment to meet the safety standards but did not send the equipment out for testing and certification. Yes. If you check with your local electrical code inspectors (or, if you have one, your in-house electrician ), you will find that custom-built equipment used in your factory or site must meet the electrical code, which means it must be certified for safety. Many of the certification houses offer on-site investigations of such equipment. UL has a standard (I don't recall the number) for such equipment. Upon successful completion of the investigation, the cert house will put a sticker on the equipment, and the electrical code inspector will accept the equipment. (Such certification also protects your employer against violation of OSHA rules.) Best regards, Rich This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: NRTL in the U.S.
This is a multi-part message in MIME format. Dave's question - Does this apply to in-house test equipment? Hi Dave - Good question (Please see attached). I'm sorry about the file size but I took it from the Department of Labor web site several years ago when this topic first came up. (It repeats about every 6 months if my memory serves) Beware of defining the situation incorrectly. Between RD - Prototyping - Manufacturing - customer site. As you change location the to NRTL or not to NRTL conditions may change - so . FIRST - THINK IT THROUGH VERY CAREFULLY - short term - long term. Document your CONDITIONS of acceptable USE However - the BEST and MOST RELEVANT people to ask are your Corporate Insurers. It would be little good meeting the local code to find that there is small print in your corporate liability insurance leaves you with personal liability for any failure - injury or death!!! NEXT - is it legal? - If 'yes' then. - ASK WHY AM I DOING THIS? If you answer legal requirements then think again. If you answer to reduce liability then think again If the answer is to prevent injury, etc then consider what if things go wrong - what protection do you would have in law. I thought it was OK is not good. I was only doing my job or I'm not paid to do that are worst Will there be any evidence (maybe even years after you have left the company) you made any assessment? Will there be any record of any changes to 'your' design? Even if you can avoid NRTL testing then you need to protect yourself - NOT YOUR COMPANY - (people go to jail - companies don't). You would be most wise to create a UL-Style Product Description AND UL style test Report so that you have some sort of evidence of due diligence AND A CONFIGURATION RECORD OF WHAT YOU TESTED. It have seen too many modifications that have made products d-a-n-g-e-r-o-u-s. Whereas I believe that there is may be no single one right answer to your question there will be, I am sure, plenty of wrong ones. Hopefully those will not be posted here!!! STEP OUTSIDE THE BOX Try to think of 'compliance' not as PASS or FAIL; but as a continuum from DEPLORABLE through ACCEPTABLE to the UNATTAINABLE. Whereas there is a basic legal need to reach ACCEPTABLE there is a commercial need (6-sigma - zero-defect - fault-free : call it what you will) that strives for better things. (Which is just as well because the standards have become stricter and will continue to do so.) My company has clients at all points along that continuum and work with them to progress their knowledge and to show them how they can reduce their personal and corporate risks. Before someone shoots COSTS at me - please let me add - we find that the cost (of training and implementation) is more than offset by cost saving that result from the compliance improvement exercise. There are free downloads under the eLearning section of our web site - please help yourself. Best regards Gregg Gregg Kervill DipIM, MIMgt, MIEEE VP Engineering Test4Safety.com Inc PO Box 310, Reedville, VA 22539. USA Phone ( 804) 453-3141 Fax(804) 453-9039 http://www.test4safety.com/ From: drcuthbert [mailto:drcuthb...@micron.com] Sent: Tuesday, January 14, 2003 12:53 PM To: 'Gregg Kervill'; 'Joe P Martin'; emc-p...@majordomo.ieee.org Subject: RE: NRTL in the U.S. Does this apply to in-house test equipment? That is, equipment that is built in-house and remains on site? In the past I have designed in-house equipment to meet the safety standards but did not send the equipment out for testing and certification. Dave From: Gregg Kervill [mailto:gr...@test4safety.com] Sent: Tuesday, January 14, 2003 7:50 AM To: 'Joe P Martin'; emc-p...@majordomo.ieee.org Subject: RE: NRTL in the U.S. Importance: High Joe, You are correct that NRTL LISTING is a specified requirement by some cities and states. You are incorrect in that all products used where OSHA applies are required to be NRTL LISTED. NEC Code makes that same requirement Furthermore most (I have yet to find an exception) cities and states base their code upon NEC There may be local exception but I believe that to make a 'blanket statement that .. NRTL is not required in the US... is I believe at best confusing and at that the worst very dangerous. The following is a statement from the US NOL: All electrical equipment, except those kinds which no NRTL accepts, certifies, lists, labels, or otherwise determines to be safe, must be approved, as that term is defined at 29 CFR 1910.399. Except as indicated in the following this means that a NRTL must accept, certify, label, list, or otherwise determine that equipment is safe for it to be considered approved. The requirement mandating that electrical equipment be approved is set forth at 29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that approved equipment be used in conformance with its approval. Electrical equipment
RE: NRTL in the U.S.
Rich Nute (I think) wrote and excellent article or e-mail on this not too long ago and should be in the archives. Its pretty concise and clear but goes into some pretty good specifics and the state laws and how they very and you will find it very helpful. Rich if it wasn't you sorry but you better get writing! Gary From: Ronald R. Wellman [mailto:rwell...@wellman.com] Sent: Tuesday, January 14, 2003 8:53 AM To: peter.a.manfredo...@us.ul.com; Joe P Martin Cc: emc-p...@majordomo.ieee.org; owner-emc-p...@majordomo.ieee.org Subject: Re: NRTL in the U.S. Hello Peter, Those of us who have had to list products in the United States already know this. What is required by law versus what is a customer requirement are two different things. NRTL listing is a Customer requirement as viewed from a product manufacturer. However, there are some cities, states, and counties, that require NRTL listing by law. To answer Martin's question, I believe it is Cook County, Illinois and just the City (not county) of Los Angeles that require NRTL listing. I also remember that the State of Oregon requires NRTL listing as well as some counties in Florida. Best regards, Ron Wellman At 08:37 AM 1/14/2003 -0500, peter.a.manfredo...@us.ul.com wrote: Local municipalities throughout the U.S. adopt the National Electrical code NFPA 70 as a way to assure consistent administration and enforcement of a standardized electrical code. The Code provides that wiring and installed electrical equipment ...Need not be inspected at the time of installation of the equipment, except to detect alterations or damage, if the equipment has been LISTED by a qualified electrical testing laboratory Manfredonia Joe P Martin MartinJP@appliedbiosys To: emc-p...@majordomo.ieee.org tems.com cc: Sent by: Subject: NRTL in the U.S. owner-emc-pstc@majordom o.ieee.org 01/13/2003 11:22 PM Please respond to Joe P Martin Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list -- For more information about UL, its Marks, and its services for EMC, quality registrations and product certifications for global markets, please access our web sites at http://www.ul.com and http://www.ulc.ca, or contact your local sales representative. -- * Internet E-mail Confidentiality Disclaimer ** This e-mail message may contain privileged or confidential information. If you are not the intended recipient, you may not disclose, use, disseminate, distribute, copy or rely upon this message or attachment in any way. If you received this e-mail message in error, please return by forwarding the message and its attachments to the sender. Underwriters Laboratories Inc. and its affiliates do not accept liability for any errors, omissions, corruption or virus in the contents of this message or any attachments that arise as a result of e-mail transmission. * --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail
RE: NRTL in the U.S.
Hello Gregg, Martin is correct that NRTL Listing is not a requirement to sell electronic products in the U.S. Product usage is something entirely different and may require compliance under OSHA regulations. Best regards, Ron Wellman At 09:50 AM 1/14/2003 -0500, Gregg Kervill wrote: Joe, You are correct that NRTL LISTING is a specified requirement by some cities and states. You are incorrect in that all products used where OSHA applies are required to be NRTL LISTED. NEC Code makes that same requirement Furthermore most (I have yet to find an exception) cities and states base their code upon NEC There may be local exception but I believe that to make a 'blanket statement that .. NRTL is not required in the US... is I believe at best confusing and at that the worst very dangerous. The following is a statement from the US NOL: All electrical equipment, except those kinds which no NRTL accepts, certifies, lists, labels, or otherwise determines to be safe, must be approved, as that term is defined at 29 CFR 1910.399. Except as indicated in the following this means that a NRTL must accept, certify, label, list, or otherwise determine that equipment is safe for it to be considered approved. The requirement mandating that electrical equipment be approved is set forth at 29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that approved equipment be used in conformance with its approval. Electrical equipment which no NRTL accepts, certifies, lists, labels, or determines to be safe is acceptable to OSHA under the following if the equipment is inspected or tested by another Federal Agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the NEC and found in compliance with the provisions of the NEC as applied to Subpart S of 29 CFR 1910 standards. Custom made equipment which is designed, fabricated for, and intended for use by a particular customer does not have to be approved if it is determined to be safe for its intended use by its manufacturer. The determination must be made on the basis of test data that the employer keeps and makes available to the Assistant Secretary of Labor for OSHA. In summary then if there are ten different models of a particular kind of equipment, but only one of them is accepted, certified, listed, labeled or otherwise determined to be safe by a NRTL only that one would be considered to be approved; unless of course it is custom made equipment. Only those entities that have applied and been approved pursuant to the requirements of 29 CFR 1910.7 are considered to be a NRTL. Recently the Canadian Standards Association was the first foreign laboratory approved as an NRTL. Enclosed find a copy of a directive that discusses NRTLs. Best regards Gregg Kervill Gregg Kervill DipIM, MIMgt, MIEEE VP Engineering Test4Safety.com Inc PO Box 310, Reedville, VA 22539. USA Phone ( 804) 453-3141 Fax(804) 453-9039 http://www.test4safety.com/ -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Joe P Martin Sent: Monday, January 13, 2003 11:22 PM To: emc-p...@majordomo.ieee.org Subject: NRTL in the U.S. Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions
RE: NRTL in the U.S.
Add Orange County California, City of San Francisco, states of Maryland (consumer products only as I recall), North Carolina and Washington. Richard Woods Sensormatic Electronics Tyco International From: Brian Epstein [mailto:brian.epst...@veeco.com] Sent: Tuesday, January 14, 2003 2:36 PM To: 'Ronald R. Wellman'; peter.a.manfredo...@us.ul.com; Joe P Martin Cc: emc-p...@majordomo.ieee.org; owner-emc-p...@majordomo.ieee.org Subject: RE: NRTL in the U.S. Add Santa Clara County and the Commonwealth of Virginia to that list. Brian Epstein Sr Regulatory Compliance Engineer Veeco Instruments From: Ronald R. Wellman [mailto:rwell...@wellman.com] Sent: Tuesday, January 14, 2003 8:53 AM To: peter.a.manfredo...@us.ul.com; Joe P Martin Cc: emc-p...@majordomo.ieee.org; owner-emc-p...@majordomo.ieee.org Subject: Re: NRTL in the U.S. Hello Peter, Those of us who have had to list products in the United States already know this. What is required by law versus what is a customer requirement are two different things. NRTL listing is a Customer requirement as viewed from a product manufacturer. However, there are some cities, states, and counties, that require NRTL listing by law. To answer Martin's question, I believe it is Cook County, Illinois and just the City (not county) of Los Angeles that require NRTL listing. I also remember that the State of Oregon requires NRTL listing as well as some counties in Florida. Best regards, Ron Wellman At 08:37 AM 1/14/2003 -0500, peter.a.manfredo...@us.ul.com wrote: Local municipalities throughout the U.S. adopt the National Electrical code NFPA 70 as a way to assure consistent administration and enforcement of a standardized electrical code. The Code provides that wiring and installed electrical equipment ...Need not be inspected at the time of installation of the equipment, except to detect alterations or damage, if the equipment has been LISTED by a qualified electrical testing laboratory Manfredonia Joe P Martin MartinJP@appliedbiosys To: emc-p...@majordomo.ieee.org tems.com cc: Sent by: Subject: NRTL in the U.S. owner-emc-pstc@majordom o.ieee.org 01/13/2003 11:22 PM Please respond to Joe P Martin Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list -- For more information about UL, its Marks, and its services for EMC, quality registrations and product certifications for global markets, please access our web sites at http://www.ul.com and http://www.ulc.ca, or contact your local sales representative. -- * Internet E-mail Confidentiality Disclaimer ** This e-mail message may contain privileged or confidential information. If you are not the intended recipient, you may not disclose, use, disseminate, distribute, copy or rely upon this message or attachment in any way. If you received this e-mail message in error, please return by forwarding the message and its attachments to the sender. Underwriters Laboratories Inc. and its affiliates do not accept liability for any errors, omissions, corruption or virus in the contents of this message or any attachments that arise as a result of e-mail transmission. * --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord
RE: NRTL in the U.S.
The truth is that an independent licensed electrician will not connect a product that is not Listed. In commercial or industrial environments, there may be a Licensed Professional Engineer on staff, who can approve a product but he takes the personal liability for Non-Listed products. Manfredonia -- For more information about UL, its Marks, and its services for EMC, quality registrations and product certifications for global markets, please access our web sites at http://www.ul.com and http://www.ulc.ca, or contact your local sales representative. -- * Internet E-mail Confidentiality Disclaimer ** This e-mail message may contain privileged or confidential information. If you are not the intended recipient, you may not disclose, use, disseminate, distribute, copy or rely upon this message or attachment in any way. If you received this e-mail message in error, please return by forwarding the message and its attachments to the sender. Underwriters Laboratories Inc. and its affiliates do not accept liability for any errors, omissions, corruption or virus in the contents of this message or any attachments that arise as a result of e-mail transmission. * This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: NRTL in the U.S.
Hi Joe: As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. The list would be very much shorter if the list contained those cities or counties that do NOT require safety certification. (I would venture to say there are none.) You could probably get such a list from UL or CSA or MET or ETL other safety certification house that has applied for and been accepted in those jurisdictions. Just ask for a list of states, counties, and cities where their mark is accepted. Personally, I know of no city, county, or state that does not require safety certification (listing) of electrical products. Your mention of cities, counties, and states implies the local electrical code requirements (usually the NEC). NRTL is a concept of the Occupational Safety and Health Adminstration (OSHA). OSHA is a federal government entity that addresses workplace safety, not local electrical codes. NRTL certification of an electrical product used in the workplace satisfies an employer's requirement (under OSHA) to supply a safe electrical device for use by employees. There is no connection between local electrical codes and NRTL. But, we know what you mean! :-) Best regards, Rich This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: NRTL in the U.S.
Does this apply to in-house test equipment? That is, equipment that is built in-house and remains on site? In the past I have designed in-house equipment to meet the safety standards but did not send the equipment out for testing and certification. Dave From: Gregg Kervill [mailto:gr...@test4safety.com] Sent: Tuesday, January 14, 2003 7:50 AM To: 'Joe P Martin'; emc-p...@majordomo.ieee.org Subject: RE: NRTL in the U.S. Importance: High Joe, You are correct that NRTL LISTING is a specified requirement by some cities and states. You are incorrect in that all products used where OSHA applies are required to be NRTL LISTED. NEC Code makes that same requirement Furthermore most (I have yet to find an exception) cities and states base their code upon NEC There may be local exception but I believe that to make a 'blanket statement that .. NRTL is not required in the US... is I believe at best confusing and at that the worst very dangerous. The following is a statement from the US NOL: All electrical equipment, except those kinds which no NRTL accepts, certifies, lists, labels, or otherwise determines to be safe, must be approved, as that term is defined at 29 CFR 1910.399. Except as indicated in the following this means that a NRTL must accept, certify, label, list, or otherwise determine that equipment is safe for it to be considered approved. The requirement mandating that electrical equipment be approved is set forth at 29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that approved equipment be used in conformance with its approval. Electrical equipment which no NRTL accepts, certifies, lists, labels, or determines to be safe is acceptable to OSHA under the following if the equipment is inspected or tested by another Federal Agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the NEC and found in compliance with the provisions of the NEC as applied to Subpart S of 29 CFR 1910 standards. Custom made equipment which is designed, fabricated for, and intended for use by a particular customer does not have to be approved if it is determined to be safe for its intended use by its manufacturer. The determination must be made on the basis of test data that the employer keeps and makes available to the Assistant Secretary of Labor for OSHA. In summary then if there are ten different models of a particular kind of equipment, but only one of them is accepted, certified, listed, labeled or otherwise determined to be safe by a NRTL only that one would be considered to be approved; unless of course it is custom made equipment. Only those entities that have applied and been approved pursuant to the requirements of 29 CFR 1910.7 are considered to be a NRTL. Recently the Canadian Standards Association was the first foreign laboratory approved as an NRTL. Enclosed find a copy of a directive that discusses NRTLs. Best regards Gregg Kervill Gregg Kervill DipIM, MIMgt, MIEEE VP Engineering Test4Safety.com Inc PO Box 310, Reedville, VA 22539. USA Phone ( 804) 453-3141 Fax(804) 453-9039 http://www.test4safety.com/ From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Joe P Martin Sent: Monday, January 13, 2003 11:22 PM To: emc-p...@majordomo.ieee.org Subject: NRTL in the U.S. Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald
Re: NRTL in the U.S.
Hello Peter, Those of us who have had to list products in the United States already know this. What is required by law versus what is a customer requirement are two different things. NRTL listing is a Customer requirement as viewed from a product manufacturer. However, there are some cities, states, and counties, that require NRTL listing by law. To answer Martin's question, I believe it is Cook County, Illinois and just the City (not county) of Los Angeles that require NRTL listing. I also remember that the State of Oregon requires NRTL listing as well as some counties in Florida. Best regards, Ron Wellman At 08:37 AM 1/14/2003 -0500, peter.a.manfredo...@us.ul.com wrote: Local municipalities throughout the U.S. adopt the National Electrical code NFPA 70 as a way to assure consistent administration and enforcement of a standardized electrical code. The Code provides that wiring and installed electrical equipment ...Need not be inspected at the time of installation of the equipment, except to detect alterations or damage, if the equipment has been LISTED by a qualified electrical testing laboratory Manfredonia Joe P Martin MartinJP@appliedbiosys To: emc-p...@majordomo.ieee.org tems.com cc: Sent by: Subject: NRTL in the U.S. owner-emc-pstc@majordom o.ieee.org 01/13/2003 11:22 PM Please respond to Joe P Martin Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list -- For more information about UL, its Marks, and its services for EMC, quality registrations and product certifications for global markets, please access our web sites at http://www.ul.com and http://www.ulc.ca, or contact your local sales representative. -- * Internet E-mail Confidentiality Disclaimer ** This e-mail message may contain privileged or confidential information. If you are not the intended recipient, you may not disclose, use, disseminate, distribute, copy or rely upon this message or attachment in any way. If you received this e-mail message in error, please return by forwarding the message and its attachments to the sender. Underwriters Laboratories Inc. and its affiliates do not accept liability for any errors, omissions, corruption or virus in the contents of this message or any attachments that arise as a result of e-mail transmission. * --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron
RE: NRTL in the U.S.
Joe, You are correct that NRTL LISTING is a specified requirement by some cities and states. You are incorrect in that all products used where OSHA applies are required to be NRTL LISTED. NEC Code makes that same requirement Furthermore most (I have yet to find an exception) cities and states base their code upon NEC There may be local exception but I believe that to make a 'blanket statement that .. NRTL is not required in the US... is I believe at best confusing and at that the worst very dangerous. The following is a statement from the US NOL: All electrical equipment, except those kinds which no NRTL accepts, certifies, lists, labels, or otherwise determines to be safe, must be approved, as that term is defined at 29 CFR 1910.399. Except as indicated in the following this means that a NRTL must accept, certify, label, list, or otherwise determine that equipment is safe for it to be considered approved. The requirement mandating that electrical equipment be approved is set forth at 29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that approved equipment be used in conformance with its approval. Electrical equipment which no NRTL accepts, certifies, lists, labels, or determines to be safe is acceptable to OSHA under the following if the equipment is inspected or tested by another Federal Agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the NEC and found in compliance with the provisions of the NEC as applied to Subpart S of 29 CFR 1910 standards. Custom made equipment which is designed, fabricated for, and intended for use by a particular customer does not have to be approved if it is determined to be safe for its intended use by its manufacturer. The determination must be made on the basis of test data that the employer keeps and makes available to the Assistant Secretary of Labor for OSHA. In summary then if there are ten different models of a particular kind of equipment, but only one of them is accepted, certified, listed, labeled or otherwise determined to be safe by a NRTL only that one would be considered to be approved; unless of course it is custom made equipment. Only those entities that have applied and been approved pursuant to the requirements of 29 CFR 1910.7 are considered to be a NRTL. Recently the Canadian Standards Association was the first foreign laboratory approved as an NRTL. Enclosed find a copy of a directive that discusses NRTLs. Best regards Gregg Kervill Gregg Kervill DipIM, MIMgt, MIEEE VP Engineering Test4Safety.com Inc PO Box 310, Reedville, VA 22539. USA Phone ( 804) 453-3141 Fax(804) 453-9039 http://www.test4safety.com/ From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Joe P Martin Sent: Monday, January 13, 2003 11:22 PM To: emc-p...@majordomo.ieee.org Subject: NRTL in the U.S. Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: NRTL in the U.S.
Local municipalities throughout the U.S. adopt the National Electrical code NFPA 70 as a way to assure consistent administration and enforcement of a standardized electrical code. The Code provides that wiring and installed electrical equipment ...Need not be inspected at the time of installation of the equipment, except to detect alterations or damage, if the equipment has been LISTED by a qualified electrical testing laboratory Manfredonia Joe P Martin MartinJP@appliedbiosys To: emc-p...@majordomo.ieee.org tems.com cc: Sent by: Subject: NRTL in the U.S. owner-emc-pstc@majordom o.ieee.org 01/13/2003 11:22 PM Please respond to Joe P Martin Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list -- For more information about UL, its Marks, and its services for EMC, quality registrations and product certifications for global markets, please access our web sites at http://www.ul.com and http://www.ulc.ca, or contact your local sales representative. -- * Internet E-mail Confidentiality Disclaimer ** This e-mail message may contain privileged or confidential information. If you are not the intended recipient, you may not disclose, use, disseminate, distribute, copy or rely upon this message or attachment in any way. If you received this e-mail message in error, please return by forwarding the message and its attachments to the sender. Underwriters Laboratories Inc. and its affiliates do not accept liability for any errors, omissions, corruption or virus in the contents of this message or any attachments that arise as a result of e-mail transmission. * This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings
NRTL in the U.S.
Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
