Field Labeling

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jrannis

jrannis

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Fort Lauderdale/ Miami
Can any engineer field evaluate a piece of equipment or determine if it complies with the UL or NRTL standards or is this only done by some secret organization?
What is the procedure for such an evaluation?
I contacted someone that wanted $4,500 to come out evaluate an ATS that had an ARL (recently de-listed NRTL) sticker. Best part was that he works for ARL, and knows the ATS inside and out.
He also asked for $100 extra because the installation was 26 miles from is office.
 
Our jurisdiction would not approve a field evaluation by anyone other than a NRTL. We often have engineers and manufacturer's submit "letters of compliance" and other similar documents in order to give the impression of an "official" looking evaluation. It doesn't fly.

Most of the NRTL have local offices where agents can be made available for field evaluations. I frequently contact reps from UL, ETL and TUV here in SW Florida as they have engieers and regulatory support staff nearby in Tampa and/or Orlando.
 
I believe you will find it a jurisdictional issue.
Although I personally disagree with it, TN has provisions that the Fire Marshall may accept equipment without a NRTL label. In my area I have seen that applied once due to political pressures. IMHO it should not have been as the person "approving" had less electrical knowledge than most of the inspectors. One of the major cities here (performs it's own inspections) will accept a letter from a engineer register i this State.
 
Field evals by a registered NRTL company.

But there are times that an individual who is higher up the chain will put his/her signature on the paper. If mine does not have to be on it, I am more than happy to let someone else take the responsibility of the installation inspection and I will move on to the next job.

My parting shot usually goes something like this:
"you are sure you want your signature on this job..." (with a shrug of the shoulders for emphasis);)
 
We've recently done a great deal of research on this NRTL stuff and I can offer you the following comments based on research, conversations with, and letters to OSHA on some of the issues.

There are currently 27 States with their own OSHA body, however they're still required to enforce rules and regulations which are not less restrictive than the Fed's (29 CFR 1902.3(c)(1).

Only OSHA may define a NRTL and provides guidelines that they must follow (29 CFR 1910.7(b).

Product safety testing standards are defined in 29 CFR 1910.6. In some cases a standard does permit field certifications but that would be something written into the body of the standard.

Not all NRTL's are accredited with testing stuff. The OSHA's NRTL Web Site provides a list of those bodies that are considered by OSHA to be a NRTL and what they accredited to test to.

The AHJ (Authority Having Jurisdiction) is not the local state electrical, building, or fire inspector, it is OSHA. OSHA will issue citations for offenses regardless of what the state electrical, building, or fire inspector approved.

In terms of fire protection equipment, there are 3 exceptions to the rules requiring the equipment to be listed:
  1. There is no NRTL that lists or tests such equipment (29 CFR 1910.155(3)(ii))
  2. The equipment has been tested and found to be acceptable by another Federal Agency (29 CFR 1910.155(3)(ii)).
  3. The equipment is fabricated and intended to be used by the manufacture, and has been tested with documentation made available to OSHA for inspection (29 CFR 1910.155(3)(iii)).

Our experience is based on working with three (3) State agencies, OSHA in Washington DC, and the USCG. All of the issues centered around fire protection, however I suspect the requirements for the other subparts of OSHA are very much similar.
 
jrannis said:
Can any engineer field evaluate a piece of equipment or determine if it complies with the UL or NRTL standards or is this only done by some secret organization?
What is the procedure for such an evaluation?
I contacted someone that wanted $4,500 to come out evaluate an ATS that had an ARL (recently de-listed NRTL) sticker. Best part was that he works for ARL, and knows the ATS inside and out.
He also asked for $100 extra because the installation was 26 miles from is office.
Click to expand...

In NYC the UL lable is not needed (must be NYC approved) except for Solar (690.1). Not knowing this, I got a violation for two Solar jobs we did for NO Lables from a nationally reconized laboratory.
When I called the Enginier he came out and put UL stickers on the equipment. He said the manufactior forgot to put them on. Then I passed my inspection.
 
nyhockey said:
In NYC the UL lable is not needed (must be NYC approved) except for Solar (690.1). Not knowing this, I got a violation for two Solar jobs we did for NO Lables from a nationally reconized laboratory.
When I called the Enginier he came out and put UL stickers on the equipment. He said the manufactior forgot to put them on. Then I passed my inspection.
Click to expand...
He put his company's UL listing capability at extreme risk to do that. Only UL can come out and apply a UL label in the field, even if you could have done it in your factory. If they catch you doing this, they pull your file and suspend you from applying UL labels until they re-inspect you (and drain your bank account some more), which can take up to a year. For most people selling equipment that must be UL listed, that effectively puts them out of business.
 
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