No kitchen equipment NRTL Approval - Is this a showstopper?

AM59

Member
Location
Boston, MA
Occupation
Electrical Engineer
I'm an electrical engineer working with a prospective client to help them decide whether they can move forward with a restaurant fit-out job. The restaurant owner wants to use a bunch of foreign kitchen equipment that hasn't been tested by a NRTL. I'm just part of a team working on the MEP systems for this project, is the lack of approval for the equipment my problem?

My drawings wouldn't actually say to connect anything, it would be all receptacles and switches for "equipment connection". Am I completely divorced from the acceptability of the equipment, or is there a requirement that I abstain from work where I know the code will not ultimately be followed to the letter? Or do I just kick it down to the road and have some CYA language on the drawings like "acceptability of all kitchen equipment to be coordinated with AHJ."?
 
Most equipment is outside of NEC rules. You are only responsible for the electrical design criteria, what the owner or kitchen equipment supplier connects is on them and the AHJ
 
OSHA requires all electrical equipment used in a workplace to be listed by a NRTL.
From an OSHA letter ruling.
Question 1: Does 29 CFR Part 1910 Subpart S apply to the design of industrial machinery, including the requirement under §1910.303(a) that the conductors and equipment required or permitted by Subpart S are acceptable only if approved, as defined in §1910.399?

Response: Yes, §1910.301(a) provides that the design safety standards for electric utilization systems are contained in §1910.302 through §1910.308. And §1910.302(a) states that §1910.302 through §1910.308 "cover electrical installations and utilization equipment installed or used within or on buildings, structures, and other premises." For purposes of Subpart S, "utilization equipment" means "equipment that utilizes electric energy for electronic, electromechanical, chemical, heating, lighting, or similar purposes." 29 CFR 1910.399. And "equipment" is defined to include "material, fittings, devices, appliances, fixtures, apparatus, and the like, used as a part of, or in connection with, an electrical installation." 29 CFR 1910.399. Thus, industrial machinery that uses electric energy is "utilization equipment" covered by Subpart S (including §1910.303(a)).
 
I would certainly include the wording you suggested in your post on your drawings. Historically of equal concern is the specifics of the equipment in terms of voltages & frequency of the equipment compared to what is available
 
Their insurance carrier will likely have something to say about it as well.

But from a system engineering design standpoint, if you are just setting up outlets for things to be plugged in, I don’t think that what they plug in is something that you control.
 
I would put the language in. I would also terminate all of the branch circuits at a receptacle. I wouldn't mark anything that could be construed as terminating at the equipment or at the load. I would also do the math like the receptacles are continuously loaded. Like 16A * voltage for a 20A circuit with #12.

A lot of cooking equipment that isn't listed can be field evaluated. That might be a a good way to make the AHJ happy if they notice it.
 
I don't know about restaurant equipment in particular but UL is not the only game in town, there are other NRTL's on that list, A manufacturer targeting more than the US can go to a one stop shop like TÜV Rheinland they are both a US NRTL in Canada and the U.S and they offer other global certifications such as CB Scheme, GS mark, and so on, the cTÜVus label means equipment can be operated without any additional testing in Canada and the U.S as well as Europe. Also Intertek/ ETL has similar options along with their IECEx Equipment Certification Scheme.
 
I don't know about restaurant equipment in particular but UL is not the only game in town, there are other NRTL's on that list, A manufacturer targeting more than the US can go to a one stop shop like TÜV Rheinland they are both a US NRTL in Canada and the U.S and they offer other global certifications such as CB Scheme, GS mark, and so on, the cTÜVus label means equipment can be operated without any additional testing in Canada and the U.S as well as Europe. Also Intertek/ ETL has similar options along with their IECEx Equipment Certification Scheme.
No matter who does the listing or evaluation, it must be to a standard that is acceptable in the US. The "us" symbol next to the listing mark indicates it was evaluated to a standard acceptable in the US. The global marks without a "us" are not acceptable in the US.
 
No matter who does the listing or evaluation, it must be to a standard that is acceptable in the US. The "us" symbol next to the listing mark indicates it was evaluated to a standard acceptable in the US. The global marks without a "us" are not acceptable in the US.
Again the US & Canada have options, for example an alternative to UL 508 is UL 60947-4-1A
which aligns with IEC 60947.
For HVAC equipment we have UL 60335-2-40 which aligns with IEC 60335-2-40 standard, no need to make a run of stuff just for the US market. No more UL 1995.
UL has done some fantastic harmonization work over the last decade creating new compatible standards that, while being
based upon and adopting IEC requirements, incorporate sufficient national differences. Manufacturers can streamline and stock fewer sku's and pass the savings on.
 
Again the US & Canada have options, for example an alternative to UL 508 is UL 60947-4-1A
which aligns with IEC 60947.
For HVAC equipment we have UL 60335-2-40 which aligns with IEC 60335-2-40 standard, no need to make a run of stuff just for the US market. No more UL 1995.
UL has done some fantastic harmonization work over the last decade creating new compatible standards that, while being
based upon and adopting IEC requirements, incorporate sufficient national differences. Manufacturers can streamline and stock fewer sku's and pass the savings on.
But the listing marks must be marked "c" for use in Canada or "us" for use in the USA. The fact that there is harmonization between various world standards does not change the marking requirement.
 
My drawings wouldn't actually say to connect anything, it would be all receptacles
would also terminate all of the branch circuits at a receptacle.
Not when monkey business is your client.

If equipment designed for 30mA RCD trips 6mA GFCI, required w/ kitchen receptacles: client may demand inspection pass with J-boxes, rather than buy 2-Pole GFCI’s, just to be ripped out, after unlisted appliances arrive.
 
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