nrtl’s and the nec - on your side vs feb and the nec.pdf · nrtl’s approval for that product,...

NRTLs, FEBs and the NEC

What every electrical inspector needs to know about NRTLs, FEBs, listing, labeling

and the NEC.

Presented by ACES - 2011

What we will cover today

» What is a NRTL? What is an FEB?

» Why are they important?

» NEC requirements for listing/labeling.

» What listing and labeling marks look like?

» What do NRTLs and FEBs do?

» How do AHJs relate to NRTLs and FEBs?

» Common issues for inspectors!

What is a NRTL? What is an FEB?

» An NRTL is a Nationally Recognized

Testing Laboratory.

» An FEB is a Field Evaluation Body.

(An NRTL may offer FEB services. But an FEB is not

required to be an NRTL via the OSHA recognition

process to offer FEB services).

What is a NRTL?

» NRTLs are third-party organizations

recognized by OSHA as having the

capability to provide product safety testing

and certification (“listing”) services, at the

point of manufacture, for a wide range of

products used in the American workplace.

What Is Listing?

» The listing process involves rigorous testing of

representative samples of a product and then

periodic (usually 2-4 times per year) factory

follow-up verification and inspection by the

NRTL to ensure new production exactly mirrors

the tested samples.

What is an FEB?

» FEBs are third-party testing organizations.

» FEBs have the capability to provide

product safety testing and labeling

primarily in the field for a wide range of

products found in the American workplace.

What is an FEB?

» NFPA recently published two important

national standards:

▪ NFPA 790, Standard for Competency

of Third Party Evaluation Bodies

(FEBs).

▪ NFPA 791, Recommended Practice

and Procedures for Unlabeled

Equipment Evaluation.

What is an FEB?

» Since these standards provide national

requirements for FEB competency and

methods, they are a big help for AHJs.

» AHJs can now use these standards to

determine FEB acceptability.

What is an FEB?

» Field evaluation involves the non-

destructive testing of EACH product to

verify compliance with applicable

standards before applying a label.

What is a NRTL? What is an FEB?

» The listings performed by NRTLs and

evaluations performed by FEBs are based

on product safety standards developed by

US based standards-developing

organizations and often issued under the

accreditation of the American National

Standards Institute (ANSI).

CFR 1910.399

» Acceptable. An installation of equipment is

acceptable to the Assistant Secretary of Labor,

and approved within the meaning of this Subpart

S:

(1) If it is accepted, or certified, or listed, or

labeled, or otherwise determined to be safe by a

nationally recognized testing laboratory

recognized pursuant to § 1910.7;

(NRTLs can perform this service)

CFR 1910.399

(3) With respect to custom-made equipment or related installations that are designed, fabricated for, and intended for use by a particular customer, if it is determined to be safe for its intended use by its manufacturer on the basis of test data which the employer keeps and makes available for inspection to the Assistant Secretary and his authorized representatives.

(FEBs can provide such test data)

CFR 1910.7(b)

» NRTL requirements. The term nationally

recognized testing laboratory (NRTL)

means an organization which is

recognized by OSHA and which tests for

safety, and lists or labels or accepts,

equipment or materials and which meets

all of the following criteria:

CFR 1910.7(b) (continued)

» For each specified item of equipment or material

to be listed, labeled or accepted, the NRTL has

the capability (including proper testing

equipment and facilities, trained staff, written

testing procedures, and calibration and quality

control programs) to perform: Testing and

examining of equipment and materials for

workplace safety purposes to determine

conformance with appropriate test standards.

What are NRTLs and FEBs?

» NRTLs can issue listings that are accepted by OSHA. NRTLs and FEBs are usually accepted by local jurisdictions for showing that equipment is suitable for use in the workplace.

» NRTLs and FEBs are also usually accepted by local jurisdictions, retailers and others for testing and evaluating products used in construction and the home.

Why are FEBs and NRTLs Important?

» The purpose of NRTLs and FEBs is to

evaluate and test electrical equipment to

insure that the products comply with the

applicable standards.

» Without NRTLs or FEBs there would be no

way of knowing that a particular product met

the required safety requirements (without

taking it apart and checking in the field).

Importance of NRTLs and FEBs

» By looking for the NRTL mark or FEB

label, an inspector will have information

about the standards to which the product

has been listed or labeled. In addition the

inspector can call on the NRTL or FEB for

help regarding safety or acceptance

questions regarding equipment suitability

when something does not look correct!

Importance of NRTLs and FEBs

» NRTLs and FEBs are part of the US

Electrical Safety System that helps insure

safe installations of electrical products and

systems.

The NEC, NRTLs and FEBs

» How does this apply to AHJs and Electrical

Inspectors?

The NEC, NRTLs and FEBs

» The NEC is the driver that causes local

Electrical Inspectors and AHJs to look for

labels and listing marks!

» 110.2 Approval.

▪ The conductors and equipment required or

permitted by this Code shall be acceptable

only if approved.

(See also NEC 90.7)

The NEC, NRTLs and FEBs

» NEC 110.3 provides a list of considerations to be made in evaluating equipment:

▪ Suitability

▪ Mechanical strength

▪ Wire bending space

▪ Insulation

▪ Heating effects under normal and abnormal conditions

The NEC, NRTLs and FEBs

» In itself, 110.3(A) does not require listing or labeling of equipment. It does, however, require considerable evaluation of equipment. Section 110.2 requires that equipment be acceptable only if approved. The term approved is defined in Article 100 as acceptable to the authority having jurisdiction (AHJ). Before issuing approval, the authority having jurisdiction may require evidence of compliance with 100.3(A).

» The most common form of evidence considered acceptable by authorities having jurisdiction is a listing or labeling by a third party.

The NEC, NRTLs and FEBs

» Another important Point from the NEC!

▪ (B) Installation and Use. Listed or labeled

equipment shall be installed and used in

accordance with any instructions included in

the listing or labeling.

NRTL Listing Marks

» The following slides show typical NRTL

listing marks and were taken from the

OSHA NRTL Website:

www.osha.gov.dts/otpca/nrtl/nrtlmrk.html

(Note: Other forms and older labels are also

shown there.)

NRTL Listing Marks

» Canadian Standards Association

» Communication Certification Laboratory

(CCL)

NRTL Listing Marks

» Curtis-Strauss LLC (CSL)

» FM Global Technologies LLC (FM)

NRTL Listing Mark

» Intertek

» MET Laboratories, Inc (MET)

NRTL Listing Marks

» NSF International

» National Technical Systems Inc NTS

NRTL Listing Marks

» TUV SUD America, Inc

» TUV SUD Product Services

NRTL Listing Marks

» TUV Rheinland of No. America

» TUV Rheinland PTL, LLC

NRTL Listing Marks

» Underwriters Laboratories, Inc

» QPS Evaluation Services Inc (QPS)

FEB Labeling Marks

» The following slides show typical FEB

labels.

(Note: Since there are many more FEBs than NRTLs,

this if far from a comprehensive listing of FEB labels)

FEB Labels

» MET Laboratories, Inc.

» LabTest Certification Inc.

FEB Labels

» TUV SUD America Inc.

» NSS Laboratories, Incorporated

FEB Labels

» QPS Evaluation Services, Inc

» SGS North America

FEB Labels

» CSA International

» Applied Research Laboratories

FEB Labels

» Intertek

» ASC Engineering Service

FEB Labels

» Underwriters Laboratories

» eti Conformity Services

What do NRTLs and FEBs do?

» NRTLs and FEBs evaluate products for

safety.

» This evaluation includes:

▪ Determination of the proper standard to use to

evaluate the product.

▪ Review samples and information provided by

the manufacturer or customer.

What do NRTLs and FEBs do?

» This evaluation includes (continued):

▪ Verification of the information provided by

checking references and comparing to the

actual product.

▪ Review of the standard and comparing the

product to the standard, evaluating each part

covered by the standard.

▪ Conducting testing required per the standard.

What do NRTLs and FEBs do?

» Once the testing and evaluation is done and product is determined to comply with the standard, the product or equipment is eligible to receive the listing mark of the NRTL, or label of the FEB.

What do NRTLs and FEBs do?

» The listing process requires that representative samples of a product be tested to determine acceptability. Therefore NRTLs perform factory follow-up inspections on new production (typically 2-4 times/year). These inspections check that critical components are the same.

AHJs, NRTLs, FEBs and NEC

The safety system is a cooperative effort:

» The NRTLs and the FEBs determine that products meet safety standards and are capable of being installed in accordance with the NEC.

» The AHJs determine that the installation has been made in accordance with applicable codes.

Importance of NRTLs and FEBs

» US Electrical Safety System

AHJs, NRTLs and FEBs

» AHJs rely on the NRTL listing or FEB label to

know products have been evaluated and are

suitable for the identified purpose.

» Should product problems arise, NRTLs and

FEBs rely on the AHJ, consumers and others

to identify problems with products, so that

further investigation can be done to improve

the system.

AHJs, NRTLs and FEBs

» When AHJs rely on listed or labeled products, it can make the job easier since the inspector does not need to evaluate all the parts as required by NEC 110.3(A).

» Use of listed or labeled products provides a minimum level of consistent safety when installed properly. NRTLs, FEBs and inspectors working together!

AHJs, NRTLs and FEBs

» We have discussed NRTL and FEB

processes and how they help the

inspectors in general.

» Now we will look at some places where

working together we make a difference

and how the NRTL or FEB can help the

Electrical Inspector complete work more

efficiently.

Inspector Issues

» What if a listed or labeled product just does not look right or has obvious violations?▪ Notify the NRTL or FEB.

• Might be a counterfeit label on a product.

• Might be modified somehow.

• Might be the manufacturer is incorrectly manufacturing the product.

▪ In any case the NRTL or FEB has a process to review, evaluate and stop problems in the future.

Inspector Issues

» What if a product bears an NRTL mark but has been

repaired, reconditioned, modified, refurbished or

remanufactured such that its features or design have

been changed?

» These product changes, even if inadvertent, void the

NRTL’s approval for that product, and an employer’s

use of these products in the workplace violates the

OSHA standard requiring that products be NRTL

approved.

» Recommended Action: ASK if any equipment falls

under above criteria.Refer to OSHA’s Safety and Health Informational Bulletin (SHIB) 02-16-2010.

Inspector Issues

» What if a listed or labeled product just does not look right or has obvious violations?

▪ Once you notify the NRTL or FEB, now what? What about the item holding up the opening of the business?

▪ FEBs provide field label service paid for by one of the parties involved - typically the manufacturer or installer - to determine if the specific unit in the field is compliant in the specific installation.

What Is Field Labeling ?

» What if a product is not listed, or has been field

modified, refurbished or relocated?

» OSHA’s Safety and Health Informational Bulletin

(SHIB) 02-16-2010 states: “Changes made to a

product after NRTL approval will void the NRTL’s

approval of the product.”

» Such products can be field evaluated to provide

assurance to the AHJ that the equipment

complies with applicable safety standards.

What Is Field Labeling ?

Field Labeling

» FEBs and most NRTLs offer field evaluation

services.

» NFPA – the same organization that publishes the

NEC – also published NFPA 790. This standard

will help formalize and bring more consistency to

the field labeling process.

Inspector Issues

» Field Labeling

▪ NFPA 790 – Standard for Competency of

Third Party Field Evaluation Bodies.

• Used by accreditors to show an FEB is qualified

and has minimum skills and procedures necessary

to do this type of work.

• These rules could also be used by states and local

jurisdictions to determine if a field evaluation firm

meets minimum requirements.

Inspector Issues

» Field Labeling

▪ NFPA 791 – Recommended Practice and

Procedures for Unlabeled Equipment

Evaluation.

• These are the guidelines that accredited Field

Evaluation Bodies will use to evaluate equipment

in the field.

• These guidelines will provide for more consistency

in the evaluation process and in evaluation reports.

Inspector Issues

The CE Mark

» It looks like this:

» The CE Mark is the manufacturer’s self-

declaration of compliance to European

standards.

» It says nothing about compliance with

US requirements.

Conclusion

» The use of listed and labeled products are

great evidence that the products you are

seeing are in compliance with US

standards and codes.

For More Information:

» Contact Us:eti Conformity Services

800-Go to eti (468-6384)

www.eticonformity.com