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Workplace Electrical Product Safety: OSHA Seeks Comments on EC Proposal

New York, Oct 30, 2008

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has announced a request for comments on a proposal submitted to OSHA by the European Commission (EC).

OSHA’s Request for Information (RFI) is a U.S. deliverable under the auspices of the Transatlantic Economic Council (TEC), a bilateral body established in 2007 to fortify the U.S.-EU trade relationship and facilitate cooperation between the two economies.

The proposal suggests permitting the use of Supplier’s Declaration of Conformity (SDoC) as an alternative to the Nationally Recognized Testing Laboratories (NRTLs) product-approval process that OSHA currently employs for certain electrical products.

NRTLs are third-party independent laboratories that have met OSHA’s specified requirements to perform safety testing and certification of electrical and other products used in the workplace. These laboratories determine whether products conform to applicable U.S. product-safety testing standards.

The NRTL program has been in place since 1988, and fifteen private-sector laboratories are currently recognized by OSHA under the requirements of the program.

An SDoC, as proposed for use, is an equipment manufacturer or supplier’s written statement that assures a product conforms to a specified test standard or a set of requirements. A manufacturer's self-approval in the form of an SDoC is allowed in the U.S. (by some federal agencies) and other countries for certain types of products.

Details on current SDoC use and the proposal can be found in OSHA’s RFI.

All interested parties are encouraged to provide comments by January 20, 2009. Comments can be submitted electronically at, by fax to the OSHA Docket Office (202.693.1648), or by post to the OSHA Docket Office, Docket No. OSHA-2008-0032, U.S. Department of Labor, Room N-2625, 200 Constitution Avenue, NW, Washington, DC 20210.

Comments provided should include detailed technical rationale to support positions, including the protection of safety in the workplace, noting that this is OSHA’s regulatory scope. Further submission guidelines are provided in section VII of the RFI.

Please contact Bridgette Dziedzic, program manager of regional and bilateral programs for the American National Standards Institute (ANSI), with any questions (202.331.3622;

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