UL - CSA
1- What is UL certification?
UL certification is issued by an NRTL. The certification attests to the conformity of a product to a certain standard and is valid in the United States. In Europe it is commonly known as "UL" because it often refers to standards called "UL", but in reality Underwriters Laboratories (UL) is only one of many NRTLs and UL standards are not the only reference standards.
It is possible to carry out certifications not only with UL standards, but also with ASME, IEEE, ISA, NEMA, NFPA etc. standards.
After certifying a product, the NRTL authorizes the manufacturer to affix a registered trademark to it. When a product carries a certification mark it means that the NRTL has tested and certified the product and that it complies with the requirements of one or more standards.
2- What is an NRTL? Is the certification mark always the same?
In the United States, an NRTL (Nationally Recognized Testing Laboratory) is a private company or organization recognized by OSHA (Occupational Safety and Health Administration) and authorized to issue certifications and carry out tests for certain types of products and according to certain standards.
Each NRTL has its own registered mark, so certification marks differ depending on the NRTL. The list of recognized NRTLs and the standards for which they are authorized to issue certifications is present on the OSHA website. UL is one of several NRTLs in the United States. Other examples of NRTLs are Intertek, TÜV SÜD America, TÜV Rheinland, MET Laboratories, Nemko and CSA.
In Canada, certification bodies are accredited by the SCC (Standards Council of Canada).
3- What is OSHA?
The reference body for workplace safety in the United States is OSHA. The Occupational Safety and Health Administration (OSHA) is an agency of the Department of Labor whose goal is to ensure workplace safety through the introduction of appropriate standards and regulations.
OSHA defines the federal regulations (CFR or Code of Federal Regulations) on workplace safety, determines which products require certification and which are the federally recognized certification bodies (NRTL).
The general reference regulation for workplace safety is OSHA 29 CFR 1910 Occupational Safety and Health Standards; in particular, the main parts that concern machines are 29 CFR 1910 Subpart O (for mechanical aspects) and 29 CFR 1910 Subpart S (for electrical aspects). The requirements established within the regulation have the force of law. The federal regulation is aimed at users and employers (similarly to our legislative decree 81-08) and not directly at manufacturers. However, manufacturers must provide machines and equipment that comply with the regulations so that their customers can use them.
To meet the requirements established in the regulations it is possible to use the standards written and/or recognized by ANSI. ANSI also approves standards issued by third-party organizations (e.g. UL 508 A).
4- Is UL certification similar to CE marking in Europe?
No, there are fundamental differences between “UL” certification and CE marking:Europe USA
The CE marking in Europe is mandatory and required by law. UL certification in the USA for machines is not mandatory, but voluntary.
The CE marking means that that specific product complies with all the requirements of the directives and regulations applicable to it and does not refer to a specific standard. UL certification certifies compliance with a specific standard and not directly with legal requirements.
The CE marking in Europe is issued by the manufacturer without the intervention of third parties, in self-certification. UL certification in the USA is issued by a third party NRTL.
The manufacturer can - generally - CE mark his machine independently, collecting the documentation supporting the certification in the technical file. To issue the certification, the NRTLs carry out inspections and tests on the products, as required by the regulations.
The CE marking in Europe according to Directive 2006/42/EC relates to the entire machine as a product placed on the market and/or put into service. UL certification may only relate to some aspects or equipment of the machine, depending on the standard applied. For example, it is common to certify only the electrical panel of the machine according to the UL 508A standard.
5- Is the CE marking accepted in the USA?
The CE marking has no value in the USA and is not recognized by OSHA. A CE marked machine may be sold and used in the USA, but does not guarantee compliance with US regulatory requirements. From the OSHA website:
Does OSHA accept the “CE” mark or accept equipment certified by foreign testing organizations?
The CE mark is unrelated to the requirements for product safety in the United States. It is a generic mark used in the European Union (EU) to indicate that a manufacturer has declared that the product meets regulatory requirements in the EU that may or may not include product safety. In the United States, under OSHA's NRTL requirements, the product must have the specific mark of one of the NRTLs recognized to test and certify this type of product.
6- Is UL certification of machines mandatory?
No, the certification of machines and systems intended to be sold and used in the USA is generally not required by law, but is voluntarily carried out by the manufacturer.
7- What are the obligations for the manufacturer of a machine destined for the USA?
Machines installed in the USA must comply with federal laws but also local laws, which may vary from state to state, county to county or city to city. When it comes to electrical systems, local laws require compliance with the National Electrical Code (NEC), which corresponds to the NFPA 70 standard. The NEC is not a federal law but rather is adopted by each state in different editions; in some cases, local laws may also modify the NEC requirements. To find out which edition of the NEC is in effect where a machine is intended, you should check local laws, for example by using NFPA's Codefinder.
To ensure that the machine complies with the NEC and is accepted by the AHJ (Authority Having Jurisdiction) - which must issue an authorization to use it - machine manufacturers can independently apply various standards recognized and approved by ANSI. For example, compliance with the UL 508A standard for the electrical panel and the NFPA79 standard for the on-board electrical equipment ensures that these comply with the NEC.
8- Why does a manufacturer UL certify the electrical equipment of its machine?
The main reasons why UL certification is carried out are:
to simplify and speed up the acceptance procedure by the AHJ;
because contractually required by the user;
for insurance reasons;
for legal reasons, to support the quality of one's work in the event of future accidents or disputes;
to avoid having to research local laws which can also vary from city to city.
9- Is there only one type of certification?
No, each NRTL develops different certification programs for each standard. Speaking of an electrical panel and UL 508A, for example, there are certification programs for the single panel produced specifically for a machine, or for the certification of a model of panel produced in series, or even for the issuing of authorization to manufacturer to build panels in accordance with UL 508A.
10- What is field evaluation?
In the event that a machine and its electrical equipment are completed directly during installation at the customer's premises or changes are made to the equipment during installation and therefore it is not possible to carry out certification before installation, you can opt for a field evaluation. The field evaluation is an evaluation carried out by the NRTL directly in the field. Field evaluation may be the best choice in the cases described above and for machines and systems that are not mass-produced.
The field evaluation can be requested by the machine manufacturer, but can also be requested by the AHJ if he wants to have an external opinion before providing approval on the installation or has red tagged a portion of equipment, or has not approved it . For this reason, NRTLs often offer “emergency” field evaluation services, carried out within a few days to resolve any issues reported by the AHJ and allow the machine to start up.
However, if you want to opt for a scheduled field evaluation of the machine, instead of carrying out certification, it is a good idea to plan the activity in advance with the chosen NRTL. In fact, the evaluation can often begin directly at the manufacturer's headquarters, before shipping, and be completed with a final check after installation. By doing this, you immediately have feedback on what to change before shipping the machine.
Following the positive outcome of the field evaluation, the NRTL affixes a Field Evaluated Product mark.
11- Who is the AHJ?
AHJ is the acronym for Authority Having Jurisdiction. The AHJ is a local authority responsible for verifying the installation of the machine. The AHJ conducts an inspection to verify that the installation is in compliance with the NEC and local regulations. Following the inspection, the AHJ accepts the installation and issues a start-up permit.
Inspection and authorization by the AHJ is mandatory and necessary for the user to use the machine.
Authorization issued by the AHJ is not the same as certification issued by an NRTL. The AHJ can issue the permit even if the machine is not certified. At its discretion, the AHJ may require a field evaluation.
In the event that the AHJ reports problems and does not grant authorization, it is necessary to resolve the problems that have arisen as soon as possible. A solution may be to request the intervention of an NRTL to carry out a field evaluation. In this case, the NRTL carries out an inspection, issues a report and suggests to the manufacturer how the problem can be resolved.
The AHJ may be a firefighter, electrical inspector, officer, or health department manager, as determined locally.
12- Which standards should be used to design the machine for the USA?
When designing a machine destined for the USA, particular attention must be paid to the electrical equipment as there are very specific requirements that are different from those in Europe.
The two main standards to use are:
UL 508A Industrial Control Panels for the design of electrical panels
NFPA 79 Electrical standard for Industrial Machinery for the design of on-board machine equipment
Meeting the requirements of these two standards ensures that electrical equipment complies with the NEC. Be careful though, if portions of the electrical equipment are installed on parts of the building, for these you must use the NEC directly and not the standards listed above.
13- Which standards should be used for the mechanical part of machines in the USA?
Unlike the electrical part, the safety of the mechanical part of the machine is very similar to what is required in Europe, with the difference that there is no "machinery directive" that establishes the fundamental requirements. In this case it is possible to take as reference various standards issued mainly by ANSI, which generally implement the same ISO standards also adopted in Europe.
In this field the main reference standards are the ANSI B11 series standards.
The manufacturer must provide a safe machine also from a "mechanical" point of view so that its customer-user complies with the CFRs (Code of Federal Regulations) issued by OSHA, which are mandatory by law.
14- What to do if you want to sell a car in the USA?
Check the destination of the machine (state, county, city) and, possibly with the help of the customer, check the local regulations and which edition of the NEC is in force.
Check for the presence of contractual certification or regulatory obligations.
Design the machine's electrical equipment using the NEC and relevant standards (e.g. UL 508A and NFPA79).
Carry out a risk assessment, take safety measures and install protective devices using ANSI standards.
Produce the documentation accompanying the machine, including the manual and system diagrams, paying attention to following the rules for manuals and safety signs provided in the ANSI standards. As regards electrical equipment, the reference standards contain many requirements for the drafting of diagrams and manuals.
Choose whether to obtain certification from an NRTL or a field evaluation.
At Quadra Srl we know many American standards and are able to advise which ones to use, just as we can help in verifying the conformity of the machines to the regulatory requirements. We can also help prepare the appropriate documentation to address the certification procedures with the NRTL.
15- What to do if you want to obtain a UL certification?
The company is free to choose any NRTL that is accredited by OSHA, but each NRTL is authorized to issue certifications only for certain types of products and according to specific standards.
The list of recognized NRTLs and the standards for which they are authorized to issue certifications is present on the OSHA website.
When choosing the NRTL it is important to verify that it is authorized to issue certification for the standard you are interested in. Additionally, if the machine is intended for both the US and Canada, it may be helpful to choose an NRTL that addresses both US and Canadian (CSA) standards. The list of accredited certification bodies in Canada is present on the SCC website.
Finally, it is a good idea to discuss with the end customer to check if there are specific contractual requests on the brand to be affixed.
In summary we need to check:
- NRTL authorization for the field of interest;
- acceptability of the NRTL by the end customer;
- type of certification;
- testing location (where the checks and tests will be carried out);
- if you want to certify for both the US and Canadian markets it is advisable to choose an organization recognized by both countries;
- timing;
- costs.
16- UL certification: which documents to prepare?
You should check with your chosen NRTL what documents are required. Generally it is necessary to create a collection of exhaustive technical documentation, which can be:
- list of safety-critical components and materials and possibly their safety data sheets;
- mechanical layouts;
- photo of the machine;
- component certification declarations and any test reports;
- electrical / pneumatic / hydraulic diagrams with parts list;
- use and maintenance manuals.
17- What to do if you want to sell a car in Canada?
The reference body for workplace safety is the SCC. The Standards Council of Canada (SCC) is a government body that aims to promote standardization; it is the equivalent of OSHA in the USA. The SCC defines federal regulations, determines which products require certification and which bodies are accredited for product certification.
The product certification logic is entirely similar to that of the USA. There are some certification bodies accredited in both Canada and the USA and certification marks valid for both countries.
The Canadian equivalent of the NEC is the CEC (Canadian Electrical Code), which corresponds to the CSA C22.1 standard. The main safety standards in Canada are released by the CSA Group (Canadian Standards Association).
When selling a car in Canada it is very important to check the destination province. At the individual provincial level, there may be some local regulations that differ from federal regulations and standards and, in some cases, require particular certifications. One province to pay particular attention to is Ontario, as it adopts the Ontario Electrical Safety Code (OESC).
