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. This is a tool that the inspector can use when the product is not listed.

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) This slide shows the CFR (Code of Federal Regulation) that identifies the need for NRTL’s.

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) This slide shows the CFR (Code of Federal Regulation) that identifies the need for NRTL’s.

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: This slide and the next one define and show the basic requirement for the labs to show they are knowledgeable and can provide suitable listings.

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. Behind the scenes, describe the process of getting a NRTL.

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). Taking apart products in the field or at home is not a good idea as there always seems to be left over screws when put back together.

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! NRTL’s partner with the AHJ to provide safety for buildings and electrical installations. Manufacturers having their products evaluation by NRTL is one leg, the qualifications of the installers as noted by licensing and the inspection by electrical inspectors are all parts of the system to help verify that installations are done safely and in accordance with published standards and codes. Inspections are typically 2-4 times per year. But can be more often as some manufacturers products are inspected daily.

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. NRTL’s partner with the AHJ to provide safety for buildings and electrical installations. Manufacturers having their products evaluation by NRTL is one leg, the qualifications of the installers as noted by licensing and the inspection by electrical inspectors are all parts of the system to help verify that installations are done safely and in accordance with published standards and codes.

The NEC, NRTLs and FEBs How does this apply to AHJs and Electrical Inspectors? We have been talking about OSHA rules so far and now switching to how Electrical Inspections are helped by NRTLs

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) Approved by whom??? Approved by the AHJ!. How does the AHJ know if the equipment is OK?

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 Approved by whom??? Approved by the AHJ!. How does the AHJ know if the equipment is OK? Lots of work here for an inspector to do to determine if the product is acceptable.

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.   From 2011 NEC Handbook. Third Party approved by the Jurisdiction and NRTLs are typically automatically approved.

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. From 2011 NEC Handbook. The installation instructions are part of the requirements of the NEC for the proper use of the equipment and need to be considered by the AHJ when looking at the installation.

(Note: Other forms and older labels are also shown there.) 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.) The following is the list of approved NRTLs as of April 15, 2011 and the scopes of the testing accepted in the NRTL program by OSHA varies for each laboratory. The acceptance of each lab by local jurisdictions may also vary based on state and local laws.

NRTL Listing Marks Canadian Standards Association Communication Certification Laboratory (CCL) The following is the list of approved NRTLs as of April 15, 2011 and the scopes of the testing accepted in the NRTL program by OSHA varies for each laboratory. The acceptance of each lab by local jurisdictions may also vary based on state and local laws.

NRTL Listing Marks Curtis-Strauss LLC (CSL) FM Global Technologies LLC (FM) The following is the list of approved NRTLs as of April 15, 2011 and the scopes of the testing accepted in the NRTL program by OSHA varies for each laboratory. The acceptance of each lab by local jurisdictions may also vary based on state and local laws.

NRTL Listing Mark Intertek MET Laboratories, Inc (MET) Need to get drawings of listing marks and add to slides.

NRTL Listing Marks NSF International National Technical Systems Inc NTS Need to get drawings of listing marks and add to slides.

NRTL Listing Marks TUV SUD America, Inc TUV SUD Product Services Need to get drawings of listing marks and add to slides.

NRTL Listing Marks TUV Rheinland of No. America TUV Rheinland PTL, LLC Need to get drawings of listing marks and add to slides.

NRTL Listing Marks Underwriters Laboratories, Inc QPS Evaluation Services Inc (QPS) Need to get drawings of listing marks and add to slides.

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) The following is the list of approved NRTLs as of April 15, 2011 and the scopes of the testing accepted in the NRTL program by OSHA varies for each laboratory. The acceptance of each lab by local jurisdictions may also vary based on state and local laws.

FEB Labels MET Laboratories, Inc. LabTest Certification Inc. Need to get drawings of listing marks and add to slides.

FEB Labels TUV SUD America Inc. NSS Laboratories, Incorporated

FEB Labels QPS Evaluation Services, Inc SGS North America Need to get drawings of listing marks and add to slides.

FEB Labels CSA International Applied Research Laboratories Need to get drawings of listing marks and add to slides.

FEB Labels Intertek ASC Engineering Service Need to get drawings of listing marks and add to slides.

FEB Labels Underwriters Laboratories eti Conformity Services Need to get drawings of listing marks and add to slides.

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. Here we are talking about the perfectly listed product being misused. Examples: Dry location luminaire being located outdoors Normal motor being used in a hazardous classified location. Inspectors need to not allow just because the label is on the product.

Importance of NRTLs and FEBs US Electrical Safety System NRTL’s partner with the AHJ to provide safety for buildings and electrical installations. Manufacturers having their products evaluation by NRTL is one leg, the qualifications of the installers as noted by licensing and the inspection by electrical inspectors are all parts of the system to help verify that installations are done safely and in accordance with published standards and codes. Two middle boxes are the labs and inspectors working together!

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. Provide a list as a handout of the website addressed for each lab indicating the location of the field investigation form and where to send it for processing.

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. This is a tool that the inspector can use when the product is not listed.

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. This is a tool that the inspector can use when the product is not listed.

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.

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