Sign In  |  Register Now  Why Register?

Electrically speaking, the buzz in the lighting industry has long been about success built upon solid partnerships. Ben Franklin’s key and kite ultimately sparked Edison Light’s historical product launch in the New York Herald on Sunday, December 21, 1879. The advertisement for the first commercial light bulb, which was the culmination of years of research by the Edison team, read:

Edison’s Light - The Great Inventor’s Triumph in Electrical Illumination

Fast forward to 1999…While technological advances, accompanied by regulatory reforms, have dramatically altered the landscape that Edison’s original laboratory lit up, the electrical industry’s buzz today is still about partnerships. One of the most important issues facing electrical industry professionals at the end of the 20th century relates to commercial equipment certification to support any electrical installation. To accomplish this objective, the electrical inspector works in partnership with a team of players—third party certifiers, electrical contractors, manufacturers, and building owners—all of whom contribute to the goal of "the practical safeguarding of persons (workers) and property from hazards arising from the use of electricity."¹  Behind these groups are the standards developers who are responsible for writing standards that ensure that conforming equipment can be installed according to Code. This article provides for electrical inspectors a greater understanding of each party’s responsibilities, and how to fulfill their pivotal role in the partnership that ultimately results in commercial equipment certification.

Commercial Equipment Certification:
Understanding the Process
In the United States today, there are over 93,000 product standards. Most electrical standards have been adopted by American National Standards Institute, (ANSI) the controlling agency in the United States. Standards are essentially safety documents that set design, construction, and safety-related performance requirements for commercial electrical equipment in accordance with the installation rules set forth by the National Electrical Code (NEC). The objective of the standards developing organizations that write these standards is to ensure the safe use and installation of electrical equipment and equipment as defined in the NEC.

When a manufacturer develops an electrical product for use in the workplace, however, it must be certified for compliance to product safety standards for its applicable use and environment. There is no self-certification. Federal Law states that a National Recognized Testing Laboratory (NRTL), otherwise known as a third-party certification provider, must be involved throughout the product safety certification process. The building owner or a representative (e.g., architect, engineer) is responsible for purchasing and specifying NRTL-approved equipment. The contractor is responsible for installing only approved equipment using the NEC throughout the installation process. Once the equipment is specified, installed in a commercial environment, and the authorized NRTL has certified the equipment, the inspector is responsible for issuing a Certificate of Occupancy.

Commercial Equipment Certification:
An Historical Perspective
One of the key members of the commercial equipment certification team that the electrical inspector interacts with is the NRTL. The importance of a NRTL is a direct result of certification legislation enacted in the 1970s to cover all equipment used and installed in a workplace environment. (The NEC® covers those installations used in residential occupancy locations.) Federal Law 29 CFR 1910.303—with definitions in 29 CFR 1910.399—became effective in 1970. This Federal Law requires all commercial equipment to be approved. Equipment that is listed and certified by a NRTL is considered "approved" under the law. Then, as now, it is the responsibility of the local building or electrical inspector to look for a certification label from a recognized NRTL on the equipment when it is ready for installation in the workplace. The label indicates that the equipment has been certified to the applicable product safety standards.

In addition to verifying product compliance and issuing the label, NRTLs also provide the means to verify certification through the use of a printed Directory of Listed Products. This is published annually, and available through the NRTL, often via telephone and online communication. Many NRTLs also provide local field engineering support to answer specific product compliance questions that inspectors may have

Understanding NRTLs
NRTLs are accredited by the Occupational Safety and Health Administration (OSHA) to test equipment for compliance to specific standards in specific locations. NRTLs vary widely in terms of the number of accreditations and locations. For example, a NRTL may have only one location and be accredited to test products for compliance to three or four standards. Another NRTL may be accredited to test products for compliance to hundreds of standards in locations worldwide. The appearance of a certification mark on a product from an accredited NRTL may be taken as evidence of compliance to standards.

Responsibilities of the NRTL
NRTLs are accredited under Federal Law 29 CFR 1910.7, which specifies various procedures associated with the receipt of the product sample, the testing of the product, and the report that is issued to the manufacturer. Additionally, the product standard sometimes requires production line tests, which the manufacturer conducts as a quality and safety check of the product. OSHA also requires audits of the manufacturing site by the NRTL at least four times a year. Because auditing takes place at the manufacturing site, the NRTL may have employees located throughout the world to meet this need. The purpose of these unannounced follow-up audits is twofold: to verify the product’s ongoing conformance to all applicable standards, as well as its conformance to the listing report issued to the manufacturer when the product was initially submitted to the NRTL.

When testing is complete, the NRTL issues the appropriate certification marks on the equipment, indicating that the device has been tested for conformance to nationally recognized standards. In the United States these are company marks, meaning that the label indicating product compliance is unique to the NRTL that issued it. Other countries worldwide have established country marks that signify certification to the standards in the respective countries, such as the GS Mark (Germany), NOM Mark (Mexico), and T Mark (Japan).

Field Evaluated Equipment
Field labeling is another option in cases where listed products are not readily available. Field labeling occurs on commercial equipment that has not been listed and bears no label. Field labeling may be used on custom-made equipment slated to be manufactured in limited quantities, or on equipment modified to fit a particular installation. Field labeling may also be used on prototype equipment that is being installed at a beta site to determine various performance characteristics that may be changed prior to final design.

Field Labeling poses particular challenges to the inspector who must issue a Certificate of Occupancy. One trap for the unwary, is when a manufacturer, distributor, or end user states that the equipment consists of listed products or recognized components. These parties may produce a past record of approval through a previous field labeling report completed by a NRTL at a different location. It’s important to remember that the use of recognized components, or even Listed Products, does not constitute product certification. In this case, the inspector can either make the determination that the product conforms to codes and standards, or can request a field evaluation by a NRTL to make that determination. The existence of either a certification mark from a NRTL, or a field-evaluated label from one, can be taken as evidence of conformance, and facilitate approval by the electrical inspector.

Making the Partnership Work
Each member of the certification team has unique responsibilities to ensure commercial equipment certification. Standards developers ensure that product standards coordinate with installation codes. Manufacturers make the decision to achieve product compliance to standards, submitting their products through the NRTL certification process to obtain certification. The building owner or representative specifies certification prior to the purchasing and the installation of equipment. At the same time, building officials, plan reviewers, as well as the local field electrical inspector, may accept field labeling to ensure the safe installation and use of equipment that should and must be NRTL-certified. Management at each NRTL makes sure that their organization has the appropriate accreditations and expert engineering staff to conduct product safety testing to applicable standards.

What is the inspector’s role in this process? As technologies advance, and new products are launched into the market, the inspector must be aware of the accompanying new standards and methods of certification for these items. Manufacturers and NRTLs who attend IAEI organizational meetings are excellent sources for this information.

We’ve traveled far from the times of Franklin’s key and kite experiment, and Edison’s "electrical illumination." Indeed, the world of electricity is far more complex, requiring inspectors to forge relationships with key industry professionals. But as with the light bulb, success can come in the form of a thin thread that binds components together. With communication between the inspector and manufacturer, contractor, NRTL, and building owner, it’s possible to shed light on ways of achieving equipment certification with ease.

¹National Electrical Code, Section 90-1(A)

Scott Wilson is site manager of the Intertek Testing Services (ITS) office in Orlando, Florida. He has been associated with ITS since l991 and issues the ETL Product Safety Certification Mark along with various other country marks. He has spoken at numerous IAEI meetings and earned state approval for his educational seminars on the NRTL certification process. Prior to his tenure at ITS, he served on the NFPA 30 committee, and dealt with product regulatory issues in securing product approvals from numerous NRTLs working for major equipment manufacturers. Wilson is an active IAEI member and assists manufacturers in the approval process on a daily basis.

Home  | Join | Advertising | Seminars | Contact Us | Privacy Statement | Legal Notices
Copyright © 1997-2008 IAEI. All Rights Reserved.