Safety Approval USA?

Do Electronic Products Require Safety Approval In The USA?

This common question deserves special attention.

Most non-medical consumer products intended for use outside of the workplace are not required to be “approved” by a third party safety laboratory, although most big-box stores will require it before they allow electronic devices on their shelves. Therefore this page is devoted to electronic products for workplace applications.  Information concerning the The U.S. Consumer Product Safety Improvement Act (CPSIA) may be found at–Standards/Statutes/The-Consumer-Product-Safety-Improvement-Act

With that said, if the typical “domestic product” is used in the workplace (e.g. a refrigerator in a break room, a TV in a conference room or executive’s office, a space heater at a worker’s desk, etc.) then those products would be required to be certified by a Nationally Recognized Test Laboratory ( NRTL) prior to installation within the workplace.

The U.S. Occupational Safety and Health Administration (OSHA) is the source of the following information. The following OSHA web page provides and excellent overview at:

The remainder of this page will be devoted to lower level details concerning this issue.

The requirements for electrical equipment are contained in the US Code of Federal Regulations 29CFR 1910 Subpart S.  The requirements are summarized below.

29 CFR 1910.301 addresses the electrical safety requirements for the workplace

29 CFR1910.302 establishes the scope of Subpart S which includes electric “utilization equipment”

Utilization Equipment” is defined in 29CFR1910.399 as “Equipment that utilizes electric energy for electronic, electromechanical, chemical, heating, lighting or similar purposes”.  This is a very broad definition.  Therefore if the device uses electricity it would be subject to the requirements of Subpart S (the definition for Utilization Equipment appears on the page numbered 897).

29CFR1910.303(a) says “The conductors and equipment required or permitted by this subpart shall be “acceptable” only if approved as defined in 1910.399

29 CFR 1910.399 provides a definition for the term “Acceptable”:

Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this subpart S:

 (1) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory recognized pursuant to § 1910.7; or

(2) With respect to an installation or equipment of a kind that no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code, and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or

(3) With respect to custom-made equipment or related installations that are designed, fabricated for, and intended for use by a particular customer, if it is determined to be safe for its intended use by its manufacturer on the basis of test data which the employer keeps and makes available for inspection to the Assistant Secretary and his authorized representatives.

A few comments about the definition of “Acceptable”.

Most products fall under category 1 above.  In my years in the industry, I have never seen or heard of any product falling under category 2 above.  For category 3 to apply, the product would have to be truly custom.  A product that is simply “custom-made” for a particular client who selected various predetermined options and features (similar to how you might “customize a computer” on a major manufacturer’s website) would not meet the requirements for custom-made equipment.

1910.399 also includes definitions for “Approved”, “Certified”, “listed and “Labeled”, all of which point back to NRTL approval.