1. WQA Issue Document Electrical Compliance in DWTU Standards NSF/ANSI Standards 42, 44, 55, 62, and 222

2. Background The ‘Electrical safety and operation’ section of the listed NSF Standards requires that Electrical controls and components of the systems shall comply with the requirements of the National Electrical Code (NEC), or an equivalent where appropriate. For ANSI/NSF 222 in particular, the NEC indicates that compliance with article 680 can be fulfilled by product listing to UL 1563. Therefore, in order to certify products to NSF 222 Standard, it is required that the company’s product be listed to UL 1563.

3. Problems The electrical safety and operation statement is inconsistent with the DWTU NSF Standards because it is not listed in Standards 53 and 58, but it is listed in the other DWTU Standards. The following disclaimer is found in all NSF DWTU Standards: NSF Standards provide basic criteria to promote sanitation and protection of the public health. Provisions for mechanical and electrical safety have not been included in this Standard because governmental agencies or other national standards-setting organizations provide safety requirements.  This disclaimer contradicts the electrical safety and operations statement.

4. Problems The manufacturer of a product is responsible for ensuring their product meets the required codes for the marketplace they are selling to. The electrical requirement in the DWTU standards is not needed. The electrical safety and operation statement contradicts the scope. “Shall comply” wording in the statement requires evidence of conformance which means companies seeking certification have to pay for conformity assessment evaluation of electrical twice.

5. Solution (Recommendation) WQA suggests removing the electrical safety and operation requirement in NSF DWTU Standards 42, 44, 55, 62, and 222 because it is outside the scope, contradicts the standards disclaimer, and requires companies seeking certification to pay for conformity assessment evaluation of electrical twice with no added value to the consumer. Alternatively, WQA proposes the following statement to replace the current wording, “Manufacturers and installers should exercise due diligence in the design, production and installation of electrical products to achieve compliance with the National Electrical Code (NEC) NFPA 70, or other applicable national or local requirements.” This wording comes from NSF Standard 50 – most current version.