OSHA Requirements and NRTL Electrical Equipment Listing

W

w_grunfeld

#1
My company develops and markets a NDT tester for Tube Inspections based on novel APR technology. It is CE marked for marketing in the EU region and as far as I am aware there is no commensurate legal requirement to market in the US. However, I am told that OSHA requires all employers to ensure all electrical equipment is NRTL listed. Is this a fact or just the common wisdom? The Tester is Type Certified under the applicable UL standard (UL 60950)
 
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Stijloor

Staff member
Super Moderator
#2
My company develops and markets a NDT tester for Tube Inspections based on novel APR technology. It is CE marked for marketing in the EU region and as far as I am aware there is no commensurate legal requirement to market in the US. However, I am told that OSHA requires all employers to ensure all electrical equipment is NRTL listed. Is this a fact or just the common wisdom? The Tester is Type Certified under the applicable UL standard (UL 60950)
Any OSHA experts who can help Willy?

Thank you!

Stijloor.
 
M

MIREGMGR

#3
...I am told that OSHA requires all employers to ensure all electrical equipment is NRTL listed.
Yes and no.

OSHA section 1910.303(b)(1)(i) requires, in general, that electrical equipment be suitable for installation and use in conformity with the provisions of that and the associated parts of OSHA. Generally, this provision is parallel to (and historically originated with) the essentially identical requirement in the National Electrical Code (NEC), an advisory consensus standard published by the National Fire Protection Association. Both OSHA and the NEC provide that suitability of equipment for an identified purpose may be evidenced by listing or labeling for that identified purpose.

As an alternative to listing or labeling, it's possible in theory to convince an OSHA enforcement authority, local electrical inspector enforcing the locally-adopted-by-reference NEC, or buying-organization purchasing agent, technician or engineer "following the rules" that directly provided documentation of testing and analysis--essentially, a Tech File--shows that an item of electrical equipment is suitable for the prospective user's intended purpose.

In practice this usually is not practical, because individual inspectors do not have the training and time to evaluate such an extensive NRTL-investigation-equivalent analysis, and those inspectors are permitted and expected by custom to reject equipment that is not prima facie acceptable.

In that regard, an NRTL listing or labeling indication is partly analogous to CE Marking, in that even though it's not legally mandatory it's nonetheless broadly expected because it efficiently communicates to individuals in the purchase-and-installation chain that an item will be safe and effective if used as directed.
 
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Doug Tropf

Quite Involved in Discussions
#4
My company develops and markets a NDT tester for Tube Inspections based on novel APR technology. It is CE marked for marketing in the EU region and as far as I am aware there is no commensurate legal requirement to market in the US. However, I am told that OSHA requires all employers to ensure all electrical equipment is NRTL listed. Is this a fact or just the common wisdom? The Tester is Type Certified under the applicable UL standard (UL 60950)
From: http://www.osha.gov/dts/otpca/nrtl/1910refs.html

With respect to 1910.303 and 1910.307, the definition of "Acceptable" under 29 CFR 1910.399 specifies, with few exceptions, that conductors and equipment must be approved only by "nationally recognized testing laboratories." Similar definitions apply to the other sections that require approval.
 
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W

w_grunfeld

#6
Thanks for the clarification. I think approved by an NRTL can mean Type Test Certification, by an NRTL and not necessarily NRTL listing.
 
M

MIREGMGR

#7
I think approved by an NRTL can mean Type Test Certification, by an NRTL and not necessarily NRTL listing.
Yes, "tested" can be equivalent to "listed", as long as the test process was passed or approved.

http://www.osha.gov/dts/otpca/nrtl/1910refs.html#1910_303-307

You might want to obtain from the NRTL with whom you are working a formal statement to that effect, in case your salespeople get pushback from particular purchase-candidates who insist on the traditional language.
 
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