Paul Laidler, Business Director for Machinery Safety at TUV SUD Product Service, explains what European machine builders need to know about product testing for exporting to the USA and, in particular, the pros and cons of NRTL Certification and Field Labelling.
Those manufacturers that produce one-of-a-kind machinery for use in the USA, or end-users that are relocating existing equipment to a new facility in the USA or have purchased used equipment or equipment without proper certification, must comply with local electrical safety requirements. If they do not, many local jurisdictions will not allow such 'unlabelled' equipment to be installed or used at manufacturing and commercial sites within their communities.
Any manufacturer found using unlabelled equipment may be fined, or closed down, by the USA's Occupational Health & Safety Authority (OSHA) or simply be banned by local electrical inspectors from switching on such equipment. Also, users of non-compliant machinery put themselves at risk of liability-related lawsuits.
Machine builders wanting to export to the USA must therefore gain the appropriate certification to prove their equipment meets the correct local safety requirements. However, many businesses are confused about which route they should take; should it be Nationally Recognized Testing Laboratories (NRTL) certification or Field Labelling?
In the USA, the NRTL programme is administered by OSHA's Directorate of Technical Support and Emergency Management. NRTLs are private, third-party organisations recognised by OSHA as meeting the legal requirements in the 29 CFR 1910.7 standard. In brief, these requirements cover the capability, control programmes, complete independence, and reporting and complaint handling procedures to test and certify specific types of products for workplace safety. This means that a NRTL organisation must have the necessary capability both as a product safety testing laboratory and as a product certification body to ensure that machinery meets relevant safety standards and is safe for use in commercial environments.
NRTL's field evaluation services include listing, labelling and National Electrical Code (NEC) inspections. The NEC is a set of minimum requirements for safety of wiring and electrical installations, covering the installation of conductors, electric equipment, signalling and communications conductors and equipment, and fibre optic cables.
OSHA can accept products 'properly certified' by a NRTL, where 'Properly certified' generally means:
- the product is labelled or marked with the registered certification mark of the NRTL,
- the NRTL issues the certification for a product covered within the scope of a test standard for which OSHA has recognised it, and
- the NRTL issues the certification from one of its sites (ie locations) that OSHA has recognised.
NRTL certification is required for many mass-produced products and involves full type-testing of product samples and ongoing audits of the factory. However, NRTL Certification would prove to be a very costly exercise for bespoke equipment.
In contrast, Field Labelling is a more effective approach for machinery that is a one-off or produced in low volumes. As Field Labelling is considered essential by purchasers in the USA, it is also essential for any machinery suppliers that want to export and sell to them.
An evaluation of such equipment by an approved NRTL will typically take three or four days, depending on the complexity of the equipment. The first part of this evaluation is done at the machinery manufacturer's site in Europe and then completed on-site at the end-user's site in the USA once the equipment has been installed, at which point the NRTL engineer applies the Field Label.
State OSHA organisations, county and municipal authorities follow the OSHA requirement by requiring electrical products (ie machinery) to be approved before the product may be used in workplaces within their jurisdiction. These authorities, who enforce safety requirements for specific locations, are referred to as AHJs (Authorities Having Jurisdiction) in the USA and have responsibility for approving equipment, equipment installations and procedures. Lists of approved products are published by organisations approved by OSHA and recognised by the AHJs, so it is imperative that both manufacturers and US-based end-users of machinery review these periodically to check if there has been any change to the equipment listed.
Such listed equipment is subject to periodic inspections to ensure that it still meets local safety requirements and that the equipment is being used for its intended purpose. During such ad-hoc inspections, AHJs will look for this mandatory label to prove that the equipment complies with local regulations and standards.
Approved safety components
Another layer of complexity is the requirement to use NRTL-recognised components in equipment, including safety-critical components such as fuses and cables. If manufacturers do this, Field Labelling certification will be a faster and simpler process, so it is important that end-users ensure that their supplier is doing this.
While this may seem daunting, in reality most well-regarded components have dual certification, meeting both NRTL and IEC standards, so manufacturers should not find themselves in the expensive situation of designing one product for the North American market and another for EU countries.
By being aware of the requirements in the USA and acting on them appropriately through Field Labelling certification, manufacturers can enhance the saleability of their machines, extend their potential market and reduce their overall liability in a cost effective way. This approach will also help end-users to ensure that their equipment is safe and compliant, and avoid costly down-time in demonstrating compliance to local jurisdictions.
Follow the link to find out more about the preliminary inspection service offered by TUV SUD Product Service for European machine builders exporting to the USA and wanting to utilise the Field Labelling route to certification.