A clear understanding of OSHA safety requirements and the objectives of the NRTL program can render the testing and approval process easier for electronics manufacturers.
Regan Arndt, TÜV SÜD America, San Diego, California, USA
INTRODUCTION
The Occupational Safety and Health Administration (OSHA), an arm of the U.S. Department of Labor, is the primary federal agency regulating workplace safety. OSHA mandates that certain products must be approved by a Nationally Recognized Testing Laboratory, or NRTL, before they are put to use in the workplace. At one time Underwriters Laboratories (UL) was the only entity approved to certify the safety of products. Since many safety standards were written by UL and still carry the UL prefix, many people believe erroneously that UL is the only source for needed product approvals. At present, there are 17 NRTLs that can test products and can grant approval under the OSHA program. These include Underwriters Laboratories and TÜV SÜD America.
MANDATES FOR NTRLs
Specifically, OSHA safety standards require that products used in the workplace undergo an approval process of testing and certification as stipulated by the applicable standards. OSHA policy recognizes the importance of giving manufacturers multiple sources for approval, a stance that encourages competition and expedites the approval process. As noted above, several test facilities are part of the OSHA Nationally Recognized Testing Laboratory Program, a part of the OSHA Directorate of Science, Technology, and Medicine.
NTRLs are qualified private safety testing laboratories that meet the requirements of OSHA regulations under 29 CFR (Code of Federal Regulations) Part 1907.1 to perform independent safety testing and product certification. Under the recognition process spelled out in Part 1910.7, NTRLs may be based in the United States or in other countries. Currently, there are 15 NTRLs in the U.S. and two that are based abroad. A current listing of NTRLs can be found on the OSHA website.1
Key parts of the approval process involves identifying the appropriate standards that apply to the product and performing an engineering review of the product construction with particular attention to product parts that might impact any aspect of safety. A test plan is developed, and testing is carried out to ensure that the product operates in a safe manner. Is some parts of the product are found to be non-compliant, those problems are reported to the manufacturer for corrective measures. Once non-compliance issues are resolved, a technical report is issued and reviewed prior to the issuance of a safety mark for that product. The certification marks generally used by each NRTL can be found on the OSHA website.2
Once a product has been approved, OSHA further mandates that the factories in which that product is manufactured be inspected on a regular basis to assure that the manufacturer has effective quality measures in place. Steps in the manufacturing process that assure the safety of the end product must remain unchanged throughout the entire “lifecycle” of the product in question.
Also, the NTRL Program specifies the types of products an independent laboratory may test and the “appropriate test standards” to be used in testing products for approval. The scope of recognition for any given NTRL facility can be found by clicking on its listing on the OSHA website. As required by Part 1910.7, an appropriate test standard must be a U.S. consensus-based test that has been developed and maintained by a standards development organization (SDO). International test standards applicable in Europe and elsewhere may be applied if they have been harmonized to U.S. requirements by a U.S.-based SDO. They then fall into the “appropriate” category.
Most the standards imposed by OSHA can be found in the General Requirements of 29 CFR Part 1910. Specifically, Part 1910.303 (a), read together with Part 1910. 399, mandates that electrical products be tested and approved by an NTRL. The language of the regulations usually uses the term approval although the reader will also encounter terms with similar meanings including certified, listed, and labeled. A comprehensive listing of NTRL approval requirements can be found on the OSHA website.3
CHOOSING AN NTRL TO TEST A SPECIFIC PRODUCT
When choosing an NTRL to test and approve an NTRL for a particular electronic product, the manufacturer should look at several key issues. Clearly, the facility must be accredited to test and to certify to the standards applying to the product. Then, there are several factors that impact turnaround time. A lab with extensive experience in doing a specific testing procedure will be able to guide a product through the certification process with fewer delays. Also, some labs are busier than others especially for testing to certain standards. Some facilities can provide multiple testing services for the same product—e.g. providing testing to EMC or quality standards necessary before the product can go to the end user.
Another key factor is whether the manufacturer’s personnel will have direct access to project engineers and will not be forced to handle all communications through administrators or sales staff. Direct access to the engineers can establish good communications and can minimize frustration when trying to resolve any non-compliance issues.
Other key issues revolve around documentation. Does the lab have experienced staff to help with any required submittals to the Federal Communications Commission or Industry Canada? If the product is to be shipped to Europe or other countries beside the U.S. or Canada, can the laboratory provide the test reports or certifications to European Norm (EN) or other international standards?
CONCLUSION
A clear understanding of OSHA safety requirements and the objectives of the NTRL Program can render the testing and approval process easier for electronics manufacturers. Also, manufacturers should be aware of key issues involving accreditation, experience, access to personnel, and documentation when making the final choice of an NTRL.
REFERENCES
1. http://www.osha.gov/dts/otpca/nrtl/nrtllist.html
2. http://www.osha.gov/dts/otpca/nrtl/nrtlmrk.html
3. http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=STANDARDS&p_toc_level=0&p_keyvalue=&p_status=CURRENT
Regan Arndt graduated as an Electronics Engineering Technologist from the Southern Alberta Institute of Technology (SAIT) in Calgary, Alberta, Canada in 1994. Regan has been with TÜV SÜD America since 2004 and is based in the San Diego office, where he is responsible for business development and account sales for the Southwestern United States. Regan is a member for the IEEE Product Safety Society.
