Hello All,

Just had a short emailversation with Dick Pittenger regarding his response
(enclosed below).  We both agreed that while his response may be true in
the Consumer Product world, it is not correct with respect to the
Workplace (under OSHA's control);  And that happens to be where Mr. 
Harlowe's equipment is headed for (as determined in an emailversation with
Mr.  Harlowe earlier today). 

OSHA requires all electrical equipment to be Listed, Labelled, etc, per
the earlier and very comprehensive response on this topic submitted by Ron
Pickard.

Regards, Art Michael

Int'l Product Safety News
A.E. Michael, Editor
P.O. Box 1561 PSTC
Middletown CT 06457-8061 U.S.A.

Phone  :  (860) 344-1651
Fax    :  (860) 346-9066
Email  :  i...@connix.com
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ISSN   :  1040-7529


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---------- Forwarded message ----------
List-Post: emc-pstc@listserv.ieee.org
Date: Tue, 16 Mar 1999 13:44:06 -0500
From: pitt...@pmifeg.com
To: emc-p...@ieee.org

Hello Brian:

Concerning your questions about the requirement for UL Listing/CSA
Certification for electrical equipment used in the USA and Canada, here's
my two cent's worth (this is based on 20+ years of handling submittals to
both agencies):

For the USA, NFPA 70 (the National Electrical Code) makes reference to use
of Listed equipment, meaning that electrical construction equipment,
conduit, outlets, boxes, circuit breakers AND utilization equipment such as
appliances which are permanently connected to the branch circuit, must be
evaluated and covered by an NRTL such as UL. Thus, any installation that
will be subjected to an electrical inspection needs to be made-up of Listed
equipment. If not, the inspector performing the inspection must make the
judgment himself concerning suitability of the components. Some states and
cities are not willing to take on that responsibility and make it very
difficult to use non-Listed equipment. Field inspections by UL are possible
but cost-prohibitive.

For cord-connected portable equipment, it is entirely possible to avoid any
Listing at all since the user simply takes the product home and plugs it in
with no electrical inspection taking place. Case in point is holiday
lighting strands, many of which are on store shelves with no Listing Marks
in evidence.

In reality, most reputable manufacturers want, and in-the-know consumers
demand, a third-party Listing of some sort. Personally, I wouldn't want any
electrical product in my home that didn't meet at least such minimum levels
of safety standards such as UL's (indeed some of the products that do have
the Mark are marhinal at best).. Additionally, with the product liability
climate in the USA, manufacturers want the extra assurance that an outside
organization has agreed that a minimum safety standard has been met. This
can be very beneficial during litigation.

For Canada, Certifications or field inspections of electrical equipment are
mandated by law. Therefore, in most instances, a Certification is the most
economical procedure. For low-volume equipment, field inspections are
possible but again expensive. Note that it's very common now for
manufacturers to submit to UL or CSA for coverage in both the USA and
Canada-one project for a small additional expense covers requirements for
both and allows for markings acceptable to both countries to be placed on
each unit.

Hope this information helps some.

R. Pittenger
PMI Food Equipment Group
Troy, Ohio



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