NRTL approval

mortimer46

Member
Location
Minnesota
Occupation
Master Electrician
I am the electrician for a company in Minnesota. The AHJ is making me get an NRTL for all 45 cnc machines we have in our commercial tool building location. How many states require this? I get that all 50 states have adopted the NEC and that it is required to be listed but this seems excessive to me. All of our CNC's come from Europe and have the CE marking on them.
 
Where the installations permitted and inspected?
In WA, UL/NRTL listing is required. Our state electrical rules have a clear explanation of what an industrial control panel is. There is an exception for manufacturing facilities that make their own panels but are still in inspected.
 
we bought an existing building. Moved all of our CNC's into it with all new electrical. Now all the CNC's need NRTL in order to pass the final electrical inspection. Yes all permits were pulled. Just wondering of it was a Minnesota thing or if other states require this?
 
Are they asking that the whole machine be listed or just the control panel?

Potentially you could get the control panels field inspected if that is what is being required. Expect to pay $5000-$10,000 per machine.
 
Are they asking that the whole machine be listed or just the control panel?

Potentially you could get the control panels field inspected if that is what is being required. Expect to pay $5000-$10,000 per machine.
they want the whole machine listed. that is what I'm trying to avoid. I've got 45 machines. cha ching
 
There are field evaluations that might be cheaper than trying to get the machine listed. You could ask the inspector if he would allow a field evaluation based on the manufacturer's installation instructions and nameplate ratings.

From the last time I spoke to UL about it, the listing of equipment is more expensive because you are going to need to send them one of the pieces of equipment to their lab and have it "destroyed" for testing. It then ends up on their product iQ page under a category.

Field evaluations is where they come to your site and evaluate the torquing, circuit protections, wiring, name plate rating and install instructions and tell you whether or not it is suitable for what your use is.


The industry tends to use the two terms interchangeably but they are different.
 
We had a customer with some gas fire equipment in there plant and they hired us to relocate the equipment as they were putting on an addition. We had to run a new gas line so that triggered an inspection.

Ma require any gas equipment to be approved and listed on there web site. This equipment was not listed as it was over 30 years old and had been used in the plant for years and was installed when Ma did not have there own listing.

The customer had to hire there own PE to inspect the equipment and file for special permission from the plumbing board to have it installed
 
As mentioned in Eddie's post above, I have found that some jurisdictions will allow a "certification' by a PE on aged existing equipment. It would be worth asking if there was any alternative accepted method,
 
In WA there is a process for a PE to get approved as a testing lab, a much less expensive option than UL. More useful for you is UL is the most expensive for field evaluations. There are many NTRL agencies that can list products to UL 508a, such as ETL
 
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When we were dealing with this in WA, we were told that most states have this NRTL/Listed requirement. Many don't enforce it, but it seems to be getting more common. Check your state codes to see if they have an approved list of Field Evaluation Bodies. WA does, and you can only use those if it isn't listed by one of the approved OSHA NRTL companies like ETL, UL, etc. Some companies lose their accreditation over time, which makes it worse if you had something OK at one time and now it isn't.

Here's the OSHA NRTL list. If you're lucky, you may find one of these symbols on your machines: https://www.osha.gov/nationally-recognized-testing-laboratory-program/current-list-of-nrtls
 
An electrical inspector can only address the electrical aspect of a machine, i.e. the control panel. Article 409 of the NEC indirectly requires it, because it requires aspects of an "industrial control panel" that can only be effectively achieved through the process of listing it. Specifically, 409.110, which calls for an SCCR (Short Circuit Current Rating) that must be provided by an "approved method", which basically is either an NRTL listing process, or a PE signing off on the suitability of the components in the panel to handle whatever the available fault current is at the facility. This has come up in here many many times, I do not know of any PEs who will stake their livelihood to sign off on that...

In addition, most states interpret 110.3(C) to mean NRTL listing, as it specifically mentions that in the Informational Note.
The Occupational Safety and Health
Administration (OSHA) recognizes qualified electrical testing
laboratories that perform evaluations, testing, and certification
of certain products to ensure that they meet the requirements of
both the construction and general industry OSHA electrical
standards. If the listing (product certification) is done under a
qualified electrical testing laboratory program, this listing mark
signifies that the tested and certified product complies with the
requirements of one or more appropriate product safety test
standards.

CE is not a "listing" that is acceptable in North America, it is a symbol of conformance to environmental, safety and health standards in Europe, and is SELF CERTIFIED, meaning there is no "3rd party" testing agency involved, the manufacturer is just making the claim based on their own internal testing (or not, who knows...). It's kind of like the foxes union stating that the henhouses are safe and secure... which is why it is not acceptable here.

But possibly MORE important, the company's INSURANCE CARRIER may also require NRTL listing. That should be checked.
 
Move your business to place that is more appreciative of the taxes you will pay producing products.
 
From an OSHA letter of interpretation:
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)).
Note that the OSHA definition of approved equals listed.
 
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