Jack Black
D.L.S. Electronic Systems, Inc.
Wheeling, IL
Manufacturers and distributors of electronic and electrical devices are required to meet various product safety and EMC standards established by the United States and Canada. They may be asked to show proof of compliance for these products by residential and workplace end-users. Today, there are multiple options for testing to the various North American standards through NRTLs, where in the past safety testing options were limited to UL.
The United States government, through the United States Department of Labor, has established the Occupational Health and Safety Administration, known as OSHA. It sets and establishes guidelines for the safe operation of products and devices that are used in the workplace. The workplace can be defined as any place where work is completed or performed. OSHA’s mission is to assure the safety and health of America’s workers by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace safety and health.
Based on this mission, and to assure the use of safe products in the workplace, OSHA established the Nationally Recognized Testing Laboratory (NRTL) program. This is a comprehensive accreditation process that allows the entry of new testing laboratories, accredited to perform many tests previously carried out only by safety organizations like UL and FM. The elimination of this virtual monopoly has opened up a competitive market for the U.S. safety compliance testing.
An NRTL is an organization that OSHA has “recognized” as meeting the legal requirements in 29 CFR 1910.7. In brief, the NRTLs are required to be completely independent, to have the capability to control programs, and to have reporting and complaint procedures in place, enabling them to test and certify specific products for workplace safety. To receive OSHA recognition as an NRTL, an NRTL must have the necessary capabilities both as a product safety-testing laboratory and as a product certification body.
The NRTL requirements differ from the OSHA Safety Standards in that they define the requirements for “approval” (i.e., testing and certification) of certain products. The Safety Standards are found in Title 29 of the Code of Federal Regulations (29 CFR), and the provisions for NRTL certification are generally in Part 1910 (29 CFR Part 1910). The OSHA requirements help protect workers by ensuring that products are designed for safe use in the workplace. An NRTL generally certifies products for a manufacturer.
OSHA Safety Standards contain general requirements for workplace safety. Many of these requirements pertain to equipment for which OSHA does not require an NRTL certification. The only products covered under the NRTL Program are those for which OSHA regulations require certification by an NRTL. Whether or not OSHA requires NRTL certification, an employer is subject to OSHA’s requirements and must assure that the workplace complies with the provisions of the Safety Standards applicable to its operations.
OSHA’s recognition is not a government license, a position, a delegation or a grant of government authority. Instead, the recognition is an acknowledgment that an organization has the necessary qualifications to perform safety testing and certification for the specific products covered within its scope of recognition. As a result, OSHA will accept products “properly certified” by many NRTLs. “Properly certified” generally means:
• The product is labeled or marked with the registered certification mark of the NRTL.
• The NRTL has reviewed the product to insure it complies with the test standard.
• The NRTL issues the certification from one of its locations which OSHA has recognized.
OSHA enforces the requirements for NRTL approval by:
• Recognizing NRTLs to assure itself that qualified organizations test and certify the safety of products used in the workplace
• Auditing each NRTL annually to verify that it maintains the quality of its operation and continues to meet the requirements for its recognition
• Performing workplace inspections during which OSHA compliance officers (CSHOs) review specific products to check whether they contain the certification mark of an NRTL.
OSHA may cite an employer and may impose penalties if the officer finds improperly certified products for which OSHA requires certification.
A quick look on the OSHA web site at www.osha.org/nrtl/csa shows that there are many companies such as CSA (Canadian Standards Association) offering accredited testing services for a number of UL, FM, IEC, and ANSI standards. CSA, for example, is an organization that has the unique ability to offer both U.S. and Canadian compliance testing and certification. Other approved NRTLs include Met Laboratories, SGS, U.S. Testing, and NSF International. A complete list of NRTLs can be found at www.osha.org/nrtl.
Since each NRTL has met the same requirements for recognition, OSHA considers any NRTL recognized for a given product safety test standard to be equivalent to all others that have been accredited for that standard. For example, any NRTL recognized for 950, a test standard for ITE, can certify such units for a manufacturer. However, even if recognized for the same test standards, each organization has different abilities depending on its experience, personnel, facilities, equipment, testing methods, and other aspects of its operations for testing and certifying products. OSHA merely recognizes organizations as NRTLs and, under its regulations, cannot dictate how an NRTL must operate. Each organization determines the details of its own NRTL operations, although OSHA has some general policies with which NRTLs must comply.
In addition to OSHA requirements, many users and sellers of electronic devices used in the residential or commercial environment may require an NRTL mark to insure that safety standards have been met. U.S. companies such as Best Buy, an electronics retailer, require a certified NRTL safety mark on the products it sells. Cities such as Los Angeles require the NRTL safety mark on products installed in the city.
Many NRTLs have established an APD (Agent Program – Data Acceptance) Testing Laboratory or similar partner laboratory programs. These programs established a series of accredited localized testing labs under the umbrella of the NRTL testing organization. This type of program was established with the manufacture in mind. Regionally based accredited testing labs performing testing and compliance assessments can greatly speed up the process from months to a few weeks.
The accredited partner labs are designed for fast turnaround, with state-of-the-art equipment and experienced technical laboratory engineers and staff. An example would be a centrally located laboratory that performs the identical testing procedures as mandated in the OSHA recognized UL, CSA, ANSI, FM and other U.S. standards.
Some partner labs specialize in key market segments, utilizing their technical expertise to eliminate many of the roadblocks usually found at other safety agencies. These segments can include; medical devices, laboratory and measurement equipment, ITE equipment, industrial, machinery, and household appliances. By taking advantage of labs’ specialized expertise in key technical areas, clients can enjoy competent testing, economically.
Partner labs can offer an additional service, such as problem-solving. Some safety agencies do not provide this kind of service, because of conflict of interest, liability issues, or lack of expertise. An engineering staff that is technically trained to trouble-shoot non-compliant test results can greatly reduce the time needed for compliance, and can also reduce costs relating to solving non-compliant situations. This engineering assistance can eliminate delays found at many safety agencies and allows the compliance program to proceed at the fastest possible rate. In many cases, there is no additional charge.
For overall compliance, including requirements for safety and EMC compliance, the best option would be for a manufacturer to have available a complete “one-stop shop” for its testing needs, including requirements of the Federal Communications Commission (FCC) and those of the Food and Drug Administration (FDA) for specific medical devices. A combined testing program can provide a faster compliance path with respect to total compliance. When compared to other safety agencies, a cost savings may also be enjoyed. Less time wasted means less money spent.
The FCC, under the Code of Federal Regulation, or CFR, title 47, is authorized to set and maintain standards for various devices to assure they do not interfere with the broadcast frequencies established for radio, television, and other licensed communications. Under FCC guidelines, a digital device that operates above 9 kHz, and is marketed for use in residential, commercial, industrial, or business environments must meet the requirements for radiated and conducted emissions found in FCC Part 15.
Devices commonly considered in this category include industrial equipment, machinery, and factory industrial controls, as well as devices usually found in or near residential, home and business environments.
A digital device which is marketed for use in a residential or home-type environment must meet the more stringent radiated and conducted emissions requirements, found in FCC Part 15, B level. Products that are included in this category are computers, calculators, printers, and microwaves. Certification is required of any device that intentionally transmits or broadcasts energy as a function of its operation.
Many partner labs offer these additional services, such as EMC testing for FCC and other related requirements, formal filing with the FCC for transmitting devices, and FDA approval assistance, for products within the medical device catgory. Many labs offer additional service for global compliance standards such as the CE compliance testing for Europe.
The CE mark is unrelated to the requirements for product safety in the U.S. It is a mark used in the European Union (EU) to indicate that a manufacturer has declared that the product meets “all” requirements in the EU for product safety, EMC, and any other requirements covered by Directives for a given product category. The CE mark has no legal status in the U.S.; however, some standards will allow data from certified CE testing to be used for U.S. approvals. In the U.S., under OSHA’s NRTL requirements, the product must carry the specific mark from a recognized NRTL.
Conclusion
OSHA’s program granting recognition to NRTLs across the country has been a boon to manufacturers whose products must meet stringent safety and interference standards, whether domestic or international. Today, it is possible to find needed expertise in the immediate geographical area, to find a facility with in-depth knowledge of a particular industrial sector, and to take advantage of on-the-spot experience when testing indicates the need for a design change or retrofit. Of course, such efficiency streamlines compliance testing and time-to-market and cuts costs. More importantly, it assures compliance, efficient product operation, and safer homes and workplaces.
