The USA machinery exports Green Card. By Paul Taylor
The North American market poses unique regulatory requirements for machinery and equipment. Certification for this market involves highly complex requirements, with a multi-tier legal system where laws and applicable electrical and safety codes vary greatly in each city, state and province. Machinery manufacturers that want to export to the US must therefore gain the appropriate certification to prove their equipment meets the correct local safety requirements.
In the US, testing for compliance must be performed by an authorized Nationally Recognized Testing Laboratory (NRTL). In Canada, the equivalent process is known as Special Inspection and must be performed by an Inspection Body approved by the Standards Council of Canada (SCC). The approval of electrical equipment and systems is similar to the USA and is outlined in article 2-024 of the CEC (Canadian Electrical Code).
Manufacturers that produce bespoke machinery for use in the US, end-users that are re-locating existing equipment to a new facility, and those that have purchased used equipment or equipment without proper certification, must comply with local electrical safety requirements. However, many businesses are confused which route they should take – should it be Nationally Recognized Testing Laboratory (NRTL) certification or Field Labelling?
The NRTL programme is administered by the Occupational Safety and Health Administration’s (OSHA) Directorate of Technical Support and Emergency Management. NRTLs are independent, third-party test and certification organizations recognised by OSHA as meeting legal requirements for product safety testing and certification services. An NRTL organization 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 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 accepts products certified by a NRTL when:
- The product is labelled or marked with the registered NRTL certification mark.
- The NRTL issues the certification for a product covered within the scope of a test standard, for which OSHA has recognized it.
- The NRTL issues the certification from one of its OSHA-recognized locations.
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 equipment.
Field Labelling is a more effective approach for individual machinery and low-volume production runs. It is the process of inspection and application of a label onto a product to indicate that basic electrical and safety requirements are met for entrance into the North American market.
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. This preliminary inspection is intended to assess the overall construction and safety of the machine to the relevant technical standards. It is therefore not necessary to assess aspects of compliance that are unique to the final installation site.
Once the equipment has been installed at the machinery end-user’s site in the US, the final evaluation focuses on the installation-specific requirements of machine compliance with the regulations and standards. After the final inspection has confirmed compliance with all applicable requirements, an NRTL field label 15is applied to the equipment.
State OSHA organizations, county and municipal authorities follow the OSHA requirement by requiring electrical products (i.e. 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 US and have responsibility for approving equipment, equipment installations and procedures. A field label denotes to the AHJ that the equipment has been inspected by the NRTL and that all requirements of the technical standard have been complied with.
Lists of approved products are published by organizations 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 Mto 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-recognized components in equipment, including safety-critical components such as fuses and cables. 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.
Field labelling ensures that your business can capitalize on the huge potential of the lucrative US and Canadian markets for industrial products. Conformance to the relevant inspection and field labelling requirements is a prerequisite for local authorities to grant permission for your equipment to be placed into service. A positive inspection result will enable the appropriate label to be applied to your product and thereby facilitate a smooth market entry. Likewise, end-users of machinery in the US can ensure that their site, which is using the machinery, experiences no costly down-time by selecting a diligent supplier and ensuring that every machine they use meets the relevant compliance requirements of local jurisdictions.
Paul Taylor is Head of Industrial Products (UK) at TÜV SÜD, one of the world’s leading experts in product testing and certification, with 150,000 product certificates in circulation globally. Its TÜV SÜD Product Service division analyzes over 20,000 products each year in Europe, Asia-Pacific and the Americas, ensuring that products are safe, reliable and compliant, while minimising liability risks for manufacturers, importers and retailers.
TÜV SÜD’s Machinery Safety Division is the UK market leader in machinery safety, providing a range of services on a world-wide basis; TÜV SÜD BABT is the world’s leading radio and telecommunications certification body.