Electrical product safety: Are testing labs needed or is a supplier's declaration enough?

European Commission asked OSHA to consider Supplier’s Declaration of Conformity (SDoC) as an alternative to third-party certification of electrical products; NEMA prefers nationally recognized testing laboratories (NRTLs) product-approval process, saying anything less could decrease worker safety. Will your company comment to OSHA about this by Jan. 20?


Rosslyn, VA – European Commission asked OSHA to consider Supplier’s Declaration of Conformity (SDoC) as an alternative to third-party certification of electrical products; National Electrical Manufacturers Association (NEMA) and others prefer that

NEMA suggests to OSHA that nationally recognized testing labs do more for electrical product safety than supplier declarations.

Read the rest of NEMA's electrical product testing safety concerns in a related PDF.

NEMA and 17 other organizations have submitted a letter to Thomas M. Stohler, Acting Assistant Secretary for Occupational Safety and Health, delineating concerns about the consideration by the Occupational Safety and Health Administration (OSHA) of a proposal to adopt Supplier’s Declaration of Conformity (SDoC) as an alternative to third-party certification of electrical products in U.S. workplaces.
In October, at the request of the European Commission, OSHA published a Request for Information in the Federal Register on a proposal to permit use of an SDoC as an alternative to the nationally-recognized testing laboratories (NRTLs) product-approval process. In a response to Stohler, NEMA and its coalition allies stress safety benefits of using third-party certification for electrical products and commended the OSHA NRTL program as an efficient and cost-effective way to ensure the safety of workers.
NEMA plans to submit detailed comments on specific issues by Jan. 20, 2009, the deadline for filing individual responses.
The letter cautions, “At a time when the safety and competitive threats posed by substandard and counterfeit products in general are markedly rising, opening the door to uncertified products would seem to exacerbate this problem.”
According to the letter, “The U.S. electrical safety system, which is principally based on third-party certification, is regarded as one of the most effective systems in the world for successfully ensuring workplace safety, while at the same time allowing for free and open market access for products and services, with minimal cost to the taxpayer. Indeed, those who now wish to institutionalize SDoC must accept that the checks-and-balances of our current system have played a fundamental role in driving U.S. electrical products to be the safest in the world.”
Another contention of the group is that during a time of global toy, food, and financial concerns, such a change seems especially inappropriate.
NEMA president and CEO Evan R. Gaddis said, “We are hopeful that OSHA will not be influenced by false claims that international trade priorities necessitate replacing the well-established NRTL program with SDoC. It would be unwise to compromise the most successful electrical safety system in the world.”
Represented in the coalition are the Association of Home Appliance Manufacturers, the Consumers Union, the International Brotherhood of Electrical Workers, the National Electrical Contractors Association, and Underwriters Laboratories, to name a few.
NEMA provides the letter and list of coalition members in a PDF document .

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