NRTL OSHA Requirement

[Machiavelli999]

I am working on a project that is bringing in some equipment over from Europe and am being asked what code exactly requires an NRTL certification on this equipment.

I ended up calling a contact I have at an NRTL (TUV) who basically told me that ALL European equipment requires an NRTL, although it may not be uniformly addressed across the country. But this might just be sales talk.

From my research, OSHA requires NRTL listing for certain type of equipment that is listed here: https://www.osha.gov/dts/otpca/nrtl/prodcatg.html

There are about 37 different types of equipment that OSHA claims requires a listing. A lot of which is equipment that is handling some sort of volatile or hazardous compounds.

So my question is does ALL electrical equipment that is brought over from Europe required to be certified by an NRTL?

 

[texie]

I am working on a project that is bringing in some equipment over from Europe and am being asked what code exactly requires an NRTL certification on this equipment.

I ended up calling a contact I have at an NRTL (TUV) who basically told me that ALL European equipment requires an NRTL, although it may not be uniformly addressed across the country. But this might just be sales talk.

From my research, OSHA requires NRTL listing for certain type of equipment that is listed here: https://www.osha.gov/dts/otpca/nrtl/prodcatg.html

There are about 37 different types of equipment that OSHA claims requires a listing. A lot of which is equipment that is handling some sort of volatile or hazardous compounds.

So my question is does ALL electrical equipment that is brought over from Europe required to be certified by an NRTL?

A lot of variables here. Some things are required by the NEC to be listed, some not. Many states have requirements for all or some equipment to be listed. Also many customers (or their insurer) demand equipment to be listed. If you need an NRTL approval for something like this you will actually be getting a field evaluation not a listed product. If this is the route you take just make certain that all parties are OK with the chosen NRTL and the scope of the evaluation. Be aware that some things cannot be field evaluated.

 

[GoldDigger]

And that field evaluations, especially for one-off equipment, can be very expensive.

 

[don_resqcapt19]

In general OSHA requires all electrical equipment used in a work place to be "approved", but the OSHA definition of "approved" is that the product must be listed by a NRTL.
Here is part of a letter of interpretation issued by OSHA in 2013.

Listed Electrical Equipment OSHA
December 16, 2013


Dear Mr. Mason:
This letter is in response to your letter dated July 16, 2013, to the Occupational Safety and Health Administration (OSHA), as clarified in your e-mail of August 2, 2013. This letter was forwarded to OSHA's Directorate of Enforcement Programs (DEP) for response. You had questions about OSHA requirements under 29 CFR Part 1910, Subpart S.
This letter constitutes OSHA's interpretation only of the requirements discussed below and may not be applicable to any question not delineated within your original correspondence. Your paraphrased questions and our replies follow:
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)).

 

[Machiavelli999]

Thanks for your responses. I guess NRTL is required, but I am not sure why OSHA lists the "37 types of equipment" if in the end pretty much any equipment that is used in a workplace setting that takes electricity requires NRTL certification.