Jean-Louis Evans, managing director at TÜV SÜD Product Service, explains the important role that ‘Field Labelling’ plays when exporting product to the US

Bespoke electrical and electronic equipment sold in the US must meet specific regulations and standards. The process of ‘Field Labelling’ proves compliance with electrical laws in each local US jurisdiction, which does not allow unlabelled equipment to be installed at manufacturing or commercial sites within its community.

The US’s Occupational Health & Safety Authority (OSHA), can fine or close down a manufacturer found using unlabelled equipment. Or they may simply be banned by local electrical inspectors from switching such equipment on. In addition, users of non-compliant equipment put themselves at risk of liability related lawsuits.

Manufacturers that want to export to the US must therefore gain the appropriate certification to prove their equipment meets the correct local safety requirements and to persuade US businesses to buy British or European equipment. However, many businesses are confused which route they should take – should it be Nationally Recognised Testing Laboratory (NRTL) certification or Field Labelling?

NRTL Certification

In the US, 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 OSHA’s 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 products meet relevant safety standards and are 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. ‘Properly certified’ generally means – 1) the product is labelled or marked with the registered certification mark of the NRTL, 2) the NRTL issues the certification for a product covered within the scope of a test standard for which OSHA has recognised it, and 3) the NRTL issues the certification from one of its sites (i.e. 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, this would prove to be a very costly exercise for bespoke electrical and electronic equipment.

Field Labelling

Field Labelling is a more effective approach for electrical and laboratory equipment and machinery as it covers one-off or low volume production. As Field Labelling is considered essential by purchasers in the US, it is also essential for any business that wants 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 manufacturer’s site in Europe and then completed on-site in the US 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 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 US. Lists of approved products are published by organisations approved by OSHA and recognised by the AHJs, so it is imperative that designers and manufacturers 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.

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 a less painful process. While this may seem daunting, in reality most well regarded components have dual certification, meeting both NRTL and IEC standards, so manufacturers will not find themselves in the expensive situation of designing one product for the North American market and another for EU countries.

Being aware of the requirements in the US and by acting on them appropriately, manufacturers can dramatically improve the saleability of their products, extend their potential market while reducing their overall liability by ensuring compliance with the proper standards.

TÜV SÜD Product Service

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