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Light Sources Directorate NRTL Guidelines

The following was compiled from resources obtained from the OSHA NRTL web site and BNL’s SBMS Subject Areas. The following people helped write this guidance: E. Johnson, W.R. Casey, R. Biscardi, and M. Buckley.

Prepared By: J. Aloi; October 2008

I. History

II. BNL’s NRTL Program

III. Acquiring New Equipment

IV.Existing Equipment

V.User Equipment

VI.Vendor Equipment

VII.Custom-madeIn-house Built Equipment

VIII.Definitions

 

I. History:

In accordance with OSHA Safety Standards, any electrical product used in the workplace must be approved by a Nationally Recognized Testing Laboratory (NRTL).  This standard is used to ensure that electrical products can be used and operated safely. The NRTL requirements apply to electrically powered products that are used in the workplace and are under OSHA’s jurisdiction. All work at Brookhaven National Lab falls under this jurisdiction.

NRTLs are qualified private organizations that meet the requirements of the OSHA regulations.  The NRTLs perform independent safety testing and product certification.  Each NRTL must meet the requirements as set forth by OSHA in the NRTL program.  A listing of current NRTLs may be found at the OSHA NRTL web page and their identifying marks can be found here.

Safety testing by the NRTL will ensure that a representative unit of a particular product has met all the necessary safety requirements.  The NRTL must also organize and operate a product certification program that includes listing, labeling, and follow-up programs.  The NRTL must make sure that all manufactured units of a particular product have all the required safety features as was initially tested.  It should be noted that OSHA does not perform any product approvals but relies on NRTLs to do this work.

A NRTL will work with manufacturers to test and certify products.  After successful testing of a product, the NRTL will issue a certificate that permits the manufacturer to apply the NRTLs registered certification mark or symbol on all the units manufactured.  This certification mark on the product is important in that it shows to the user of the product that a particular NRTL has tested and certified the specific product.  The OSHA web page contains certification marks generally used by each NRTL.  OSHA does not require that the “NRTL” term be used in the certification mark.  Some NRTLs have voluntarily included these initials in their certification marks.  The use of the NRTL mark does show that the product has been tested against a specific safety standard and the equipment conforms to that standard.

The European Union has the CE mark to indicate safety requirements as being met on equipment. The European Union CE mark is not related to the requirement for product safety in the United States.  In the USA, equipment that is used in the workplace is required to be safety listed and approved by a NRTL.  The NRTL safety mark from one of the NRTLs provides the recognition that the equipment has been tested and certified. OSHA does not recognize the CE mark.

See the OSHA NRTL web page for more information on the various aspects of the OSHA NRTL program.

II. BNL’s NRTL Program:

The goal of program for review and approval of electrical equipment and installations is to ensure that approved electrical equipment is free from reasonably foreseeable risk due to electrical hazards.  This program applies to all electrical equipment built, acquired, or brought onto the BNL site by workers, guests, and contractors, when the equipment will be connected to a source of electrical power greater than or equal to 50 volts (ac or dc).  See the BNL Electrical Safety Subject Area for the supporting documentation relating to the program.

Electrical equipment and installations are acceptable at BNL only if approved, that is, acceptable to the Authority Having Jurisdiction (AHJ).  The AHJ for electrical matters at BNL is the Laboratory Electrical Safety Committee (LESC), represented in the field by the Laboratory Electrical Safety Officer (LESO).  The LESC has designated a group of Electrical Equipment Inspectors (EEIs), and given them the authority to review and approve electrical equipment and installations within the Laboratory on their behalf.  The Light Sources Directorate EEIs are listed on NSLS Electrical Equipment Inspection Information web page.

NOTE: Equipment inspections are a one-time procedure, unless the equipment has been modified.  Once a piece of equipment has been modified, it is the responsibility of the equipment owner to schedule another inspection.

While electrical equipment includes any physical device connected to a source of electrical power, devices connected to electrical sources below 50 volts are exempt from detailed review.

III. Acquiring New Equipment

 

    New Equipment Requirements:

 

A Nationally Recognized Testing Laboratory (NRTL) shall approve all electrical systems delivered to BNL, for which any part of the system operates at or above 50 volts.  BNL requires that NRTL-labeled equipment be acquired whenever labeled equipment is available.  Even if the NRTL equipment costs more than the non-NRTL equipment, you must purchase the NRTL equipment, if it is available.  Click here for a listing of OSHA-recognized NRTLs marks.  Listed below are some exemptions to the rule that require additional action.

 

 

    Purchased Custom-Made Equipment:

 

Special ordered custom-made equipment or related installations which are designed, fabricated for, and intended for use by a particular use, must be determined safe for its intended use by its manufacturer on the basis of test data, this test data shall be reviewed by one of the NSLS or NSLS-II EEIs.  After the EEI reviews the test data, he/she is required to inspect the equipment.  Follow the directions on NSLS Electrical Equipment Inspection Information web page to request an inspection. The test data must be kept in a central file, located within the NSLS design room area and with the NSLS-II ESH Coordinator, and made available for inspection by the LESO.

 

    Equipment Built to BNL Specifications “and” Equipment that no NRTL will Certify:

 

There are cases where the above pathway cannot be followed. These include cases where BNL causes the equipment to be manufactured in accordance with a specification, or non-listed or foreign equipment is acquired to perform a unique experimental function in support of the Laboratory’s scientific mission.  This equipment must be inspected and approved by one of the NSLS or NSLS-II EEIs.  Follow the directions on NSLS Electrical Equipment Inspection Information web page to request an inspection.

 

    Responsibility:

 

It is the responsibility of the person purchasing the equipment to ensure that it is NRTL approved, or receives the proper inspection and approval by one of the NSLS or NSLS-II EEIs.  When purchasing equipment through the web requisitioning system, the purchaser must select BNL QA 4.40 in the QA drop down section of the web requisition; this will ensure that the proper NRTL requirements are flowed down to the supplier.

When purchasing equipment with a credit card, it is the responsibility of the purchaser to buy only NRTL approved equipment.  Non-NRTL approved equipment is on the restricted items list for credit card purchases and must be obtained by a web requisition.

For NRTL purchased equipment, the purchaser is required to inspect the equipment upon receipt to assure that it is labeled with a NRTL mark.  If the equipment is not labeled, contact  your Quality Assurance Manager for guidance. Click here for a listing of OSHA-recognized NRTL marks.

For non-NRTL labeled equipment, follow the appropriate directions listed in the above paragraphs.

 

    Tracking:

 

All new equipment (both labeled and unlabeled) must be entered into the Electrical Equipment database.  In addition, unlabeled equipment requires an inspection. Follow the directions on NSLS Electrical Equipment Inspection Information web page to request an EEI to log in your equipment, and if necessary, inspect your equipment.

 

    CE mark:

Please remember the generic CE mark is a European self-certification applied to a product by a manufacturer or vendor who declares that their product complies with European standards.  The CE mark does not represent a third-party product evaluation and does not meet the requirements of the NRTL listing or an EEI’s approval.

 

For a good overall summary on the OSHA requirement for NRTL approval, see: http://www.osha.gov/dts/otpca/nrtl/NRTLarticle.html

 

 

IV. Existing Equipment:

 

Equipment that is already in use is NOT exempt from NRTL requirements.  A program has been established at the NSLS and NSLS-II to review and approve this equipment.  Use the NSLS Electrical Equipment Inspection Information web page to request a review of your equipment.  This web page contains a program overview and the directions to request an inspection of your equipment. Inspection results shall be logged in the NSLS Electrical Equipment Inspection Database. 

 

V. User Equipment:

 

Experimental equipment brought to the NSLS and NSLS-II also falls under these requirements.  When equipment is brought to the NSLS and NSLS-II that is not NRTL approved the responsible person must select “yes” on the NRTL question on the Safety Approval Form (SAF) and follow the directions in that section (NSLS-II R&D projects are managed through the Project Safety Review Forms; these are based on the ESR format in the SBMS Work Planning subject area).  The equipment must meet the basic requirements listed on the Electrical Equipment Inspection Sheet.  Once at the NSLS or NSLS-II, your equipment will be inspected, and if acceptable, approved.  If not acceptable, you must make the proper modification to the equipment prior to it receiving approval for use.  It behooves you to meet the basic requirements in the inspection sheet prior to arriving at the NSLS (or NSLS-II) for your beam time. This will speed up the inspection process and allow you to start your experiment on time. Inspection results shall be logged in the NSLS Electrical Equipment Inspection database.  Follow the directions on NSLS Electrical Equipment Inspection Information web page to request an inspection.

 

VI. Vendor Equipment:

 

            If the equipment being brought to demonstrate meets the BNL NRTL requirements, a simple verification needs to be made on-site by one of the NSLS or NSLS-II EEIs.  If the equipment does not presently carry an NRTL label, an alternative method to meet BNL’s electrical safety requirement is through a more thorough on-site inspection.  

It is useful to keep in mind that for new procurements from BNL, NRTL listing has become a requirement where it is available. If the equipment does not bear an NRTL mark, you can help speed the process of onsite inspection by sending the model number(s) and specifications to your point of contact at the NSLS or NSLS-II. Then you should inspect the equipment for the following before your visit to the lab;

1.     Equipment sufficiently enclosed to prevent accidental contact with energized parts.

2.    Exposed metal parts bonded and grounded.

3.    Over current protection appropriate for intended use.

 

Your electrical equipment will be inspected by Electrical Equipment Inspectors upon arrival at the NSLS or NSLS-II.  Please note that any electrical equipment set up before inspection must remain unplugged. Your point contact will know how to arrange for an inspection.

If there are any questions, please contact one of the people listed below:

 

NSLS:

Wayne Rasmussen  (631) 344-7839 rasmusse@bnl.gov

John Aloi (631) 344-7018 aloi@bnl.gov

 

NSLS-II:

Paul Ribaudo (631) 344-4572 ribaudo@bnl.gov

 

BNL:

Richard Biscardi (631) 344-7760 biscardi@bnl.gov

Jim Durnan (631) 344-5993 durnan@bnl.gov

 

 

VII. Custom-made In-House Built Equipment:

 

Custom-made in-house equipment can be approved for use by one of the NSLS or NSLS-II EEIs if built according to specific standards (e.g., Underwriters Laboratories [UL] 508 ).  Appropriate documentation for such equipment shall be maintained on file (prints, schematics, etc.).  Inspection results shall be logged in the NSLS Electrical Equipment Inspection Database.  Follow the directions on NSLS Electrical Equipment Inspection Information web page to request an inspection.

 

 

NOTE: Equipment inspections are a one-time procedure, unless the equipment has been modified.  Once a piece of equipment has been modified, it is the responsibility of the equipment owner to schedule another inspection.


 

VIII. Definitions:

29 CFR 1910.7 - Section 1910.7 of Title 29, Code Of Federal Regulations (CFR) -- The regulatory authority that defines the requirements for a nationally recognized testing laboratory (NRTL), and the criteria and requirements to evaluate and recognize an NRTL.

ACCREDITATION -- A formal acknowledgment that a testing organization is competent to carry out a specific test or specific types of tests.

APPROVED -- Acceptable to the Assistant Secretary. See the definition of "acceptable" in 29 CFR 1910.399. Products certified by an NRTL are acceptable to the Assistant Secretary, and therefore are approved for purposes of meeting the requirements in the specific paragraphs of 29 CFR Part 1910.

CERTIFICATION -- The procedure by which written assurance is given that a supplier provides a product, process, or service which conforms to a standard or specification. Within the context of the NRTL Program, the NRTL provides such assurance showing that it has determined a product conforms to one or more specific consensus-based U.S. safety standard(s). The certification must be evidenced by the NRTL's certification mark on the product.

CERTIFICATION BODY -- Within the context of the NRTL Program, the part of the NRTL's organization that conducts the product certification, as opposed to testing laboratory, activities, i.e., listing and labeling and inspection of manufacturer's facilities.

CERTIFICATION MARK -- Protected mark, applied or issued under the rules of a certification, indicating that adequate confidence is provided that the relevant product, process, or service is in compliance with a specific standard or other normative document.

CERTIFY -- Tangible assurance by a recognized third party that a product is in conformity with the safety requirements in specified test standards. Within the context of the NRTL Program, the recognized third party is the NRTL and the term "certified", includes but is not limited to the following expressions and any combination of them found in any OSHA rule, regulation, or standard: "listed"; "accepted"; "approved"; "meet the requirements of"; "tested and approved"; "tested and listed"; "certified"; and "otherwise determined to be safe."

LISTED -- Equipment is "listed" if it is of a kind mentioned in a list that is published by a nationally recognized testing laboratory (NRTL), which makes periodic inspection of the production of such equipment, and/or such equipment meets nationally recognized standards or has been tested and found safe for use in a specified manner.

LABELED -- Equipment is "labeled" if there is an attached label, symbol, or other identifying mark of a NRTL which makes periodic inspections of the production of such equipment, and whose labeling indicates compliance with nationally recognized standards or tests to determine safe use in a specified manner.

NRTL -- (Nationally Recognized Testing Laboratory) The legal entity recognized by OSHA as meeting the requirements defined in 29 CFR 1910.7.

RECOGNITION (AS AN NRTL) -- The acknowledgment by OSHA that an organization meets the requirements for an NRTL specified in 29 CFR 1910.7(b). In granting recognition, OSHA has determined that the organization has the capability, control programs, independence, and effective procedures to perform safety testing and certification of the types of products covered under the test standards included in its scope of recognition.

STANDARD -- Document, established by consensus and approved by a recognized body, that provides, for common and repeat use, rules, guidelines, or characteristics for activities or their results, aimed at achievement of the optimum degree of order in a given context. Within the context of calibrations, an artifact, instrument, or other reference material that provides a basis for setting a parameter of a test instrument to a specific value.

TESTING LABORATORY -- Laboratory or portion of an organization that measures, examines, tests, calibrates, or otherwise determines the characteristics or performance of materials or products.

TEST PROCEDURE -- A sufficiently detailed instruction to follow in examining and testing a type of product, or in performing a specific type of test. For purposes of the NRTL Program, a test procedure must be consistent with and, where necessary, elaborate upon the product safety test standard(s) applicable to the products under test. A test standard may be used, partly or completely, as a test procedure if it contains sufficiently detailed instructions that will yield repeatable results.

THIRD PARTY -- Person or body that is recognized to be independent of the parties involved, as concerns the issue(s) in question.

THIRD PARTY CERTIFICATION -- A form of certification in which the supplier's claim of conformity is validated by a technically and otherwise competent body other than one controlled by a producer or buyer. Within the context of the NRTL Program, the "third party" is the NRTL and the "supplier" is generally a product manufacturer.