UL - CSA
1- What is UL certification?
UL certification is issued by an NRTL. The certification certifies the conformity of a product to a specific 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 the many NRTLs and UL standards are not the only reference standards.
Certifications can be made not only with UL standards, but also with ASME, IEEE, ISA, NEMA, NFPA etc.
After certifying a product, the NRTL authorizes the manufacturer to affix a registered mark to it. When a product bears 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 a NRTL? Is the certification mark always the same?
In the United States, a Nationally Recognized Testing Laboratory (NRTL) is a private company or organization recognized by the Occupational Safety and Health Administration (OSHA) and authorized to issue certifications and perform tests for certain types of products and according to certain standards.
Each NRTL has its own registered mark, so certification marks differ between NRTLs. A list of recognized NRTLs and the standards they are authorized to certify to is available on the OSHA website. UL is one of several NRTLs in the United States. Other examples of NRTLs include 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 agency 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 objective is to ensure safety in the workplace through the introduction of appropriate standards and regulations.
OSHA establishes federal regulations (CFR or Code of Federal Regulations) regarding workplace safety, determines which products require certification, and which are the federally recognized certifying bodies (NRTLs).
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, manufacturers must however provide machines and equipment that comply with the regulations so that their customers can use them.
To meet the requirements set forth in the regulations, it is possible to use standards written and/or recognized by ANSI. ANSI also approves standards issued by third-party organizations (for example, UL 508 A).
4- Is UL certification similar to CE marking in Europe?
No, there are some fundamental differences between the “UL” certification and the CE marking:Europe USA
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 the product complies with all the requirements of the directives and regulations applicable to it and does not refer to a specific standard. The UL certification certifies compliance with a specific standard and not directly to legal requirements.
The CE marking in Europe is issued by the manufacturer without the intervention of third parties, in self-certification. The UL certification in the USA is issued by a third party NRTL.
The manufacturer can – generally – CE mark his machine independently, collecting in the technical file the documentation to support the certification. To issue the certification, the NRTLs carry out inspection visits and tests on the products, depending on what is required by the standards.
The CE marking in Europe according to the directive 2006/42/CE is related to the entire machine as a product placed on the market and/or put into service. The UL certification can be related only to some aspects or equipment of the machine, depending on the applied standard. For example, it is common to carry out the certification of 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 US and is not recognized by OSHA. A CE marked machine can be sold and used in the US, 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, certification of machinery 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 of the manufacturer of a machine destined for the USA?
Machines installed in the USA must comply with federal laws as well as local laws, which may vary from state to state, county to county, or city to city. When it comes to electrical installations, local laws require compliance with the National Electrical Code (NEC), which corresponds to NFPA 70. The NEC is not a federal law but is adopted by each state in different editions; in some cases, local laws may also modify the requirements of the NEC. To find out which edition of the NEC is in force where a machine is intended, you should check the local laws, for example by using the NFPA 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 be able 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 electrical equipment on the machine ensure that these are compliant 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 AHJ acceptance process;
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 vary even 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 release of the authorization to the 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, a field evaluation can be chosen. The field evaluation is an assessment carried out by the NRTL directly in the field. The field evaluation may be the best choice in the cases described above and for machines and systems not produced in series.
Field evaluations may be requested by the machine manufacturer, but may also be requested by the AHJ if they want an outside opinion before providing approval for the installation or have red-tagged a piece of equipment, meaning they have not approved it. For this reason, NRTLs often offer “emergency” field evaluations, which are performed within a few days to resolve any issues reported by the AHJ and allow the machine to be started 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 premises, before shipping, and be completed with a final check after installation. In this way, you will immediately have feedback on what to change before shipping the machine.
Following a successful field evaluation, the NRTL affixes a Field Evaluated Product mark.
11- Who is the AHJ?
AHJ stands for Authority Having Jurisdiction. The AHJ is a local authority that is responsible for verifying the installation of the machine. The AHJ performs an inspection to verify that the installation is in compliance with the NEC and local regulations. After 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 may issue authorization even if the machine is not certified. At its discretion, the AHJ may require a field evaluation.
If the AHJ does report problems and does not grant the permit, it is necessary to resolve the issues as soon as possible. One solution may be to request the intervention of an NRTL to perform a field evaluation. In this case, the NRTL conducts an inspection, issues a report and suggests to the manufacturer how to resolve the problem.
The AHJ may be a firefighter, electrical inspector, or health department officer or manager, as determined locally.
12- Which standards should be used to design the machine for the USA?
When designing a machine intended 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 rules to use are:
UL 508A Industrial Control Panels for electrical panel design
NFPA 79 Electrical standard for Industrial Machinery for the design of on-board equipment
Meeting the requirements of these two standards ensures that the electrical equipment complies with the NEC. However, be careful, if portions of the electrical equipment are installed on parts of the building, the NEC must be used directly for these and not the standards listed above.
13- What 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 a reference various standards issued mainly by ANSI, which generally incorporate 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 machine that is also safe from a "mechanical" point of view so that its user customer complies with the CFR (Code of Federal Requlations) issued by OSHA, which are required by law.
14- What to do if you want to sell a car in the USA?
Check where the machine is going (state, county, city) and, if necessary, with the customer's help, check local regulations and which edition of the NEC is in effect.
Check for contractual or regulatory certification obligations.
Design the machine's electrical equipment using the NEC and reference standards (e.g. UL 508A and NFPA79).
Conduct a risk assessment, implement safety measures, and install protective devices using ANSI standards.
Produce the documentation accompanying the machine, including manuals and system diagrams, taking care to follow 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 can advise which ones to use, as well as helping in verifying the conformity of machines to regulatory requirements. We can also help prepare the appropriate documentation to deal with the certification procedures with the NRTL.
15- What to do if you want to do 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.
A list of recognized NRTLs and the standards for which they are authorized to issue certifications is available on the OSHA website.
When choosing a NRTL, it is important to verify that it is authorized to issue certification for the standard you are interested in. Also, if the machine is intended for both the USA and Canada, it may be useful to choose a NRTL that deals with both US and Canadian standards (CSA). The list of certification bodies accredited in Canada is available on the SCC website.
Finally, it is a good idea to consult with the end customer to check if there are specific contractual requests on the brand to be applied.
To summarize, it is necessary to verify:
- 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 a body recognized by both countries;
- timing;
- costs.
16- UL Certification: What documents to prepare?
It is necessary to check with the chosen NRTL what documents are required. Generally, a comprehensive collection of technical documentation must be created, which can be:
- list of components and materials critical to safety and, where applicable, their safety data sheets;
- mechanical layouts;
- photo of the machine;
- component certification declarations and any test reports;
- electrical / pneumatic / hydraulic diagrams with component 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 has the objective of promoting 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 logic of product certification is completely analogous 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 issued by the CSA Group (Canadian Standards Association).
When selling a car in Canada, it is very important to check the province you are going to. At the level of individual provinces, there may be some local regulations that differ from federal regulations and standards and, in some cases, require special certifications. One province to pay particular attention to is Ontario, as it adopts the Ontario Electrical Safety Code (OESC).
