U.S. Department of Labor

Occupational Safety and Health Administration

Directorate of Technical Support & Emergency Management

Office of Technical Programs and Coordination Activities

CERTIFICATION OF WORKPLACE PRODUCTS BY

NATIONALLY RECOGNIZED TESTING LABORATORIES

This Safety and Health Information Bulletin (SHIB) is

intended to provide information about standards relating to

OSHA’s Nationally Recognized Testing Laboratory

Program. The Occupational Safety and Health Act requires

employers to comply with safety and health standards and

regulations promulgated by OSHA or by a state with an

OSHA-approved state plan. However, this SHIB is not

itself a standard or regulation, and it creates no new legal

obligations.

Purpose

The Occupational Safety and Health Administration

(OSHA) developed this Safety and Health Information

Bulletin (SHIB) to enhance understanding of standards

related to OSHA’s Nationally Recognized Testing

Laboratory (NRTL) Program. Specifically, the

purpose of this SHIB is to aid employers, workers and

others involved in occupational safety and health in:

Identifying specific OSHA

requirements for product1 approval by

NRTLs;

Understanding OSHA’s process for

recognizing NRTLs and the NRTL

product-approval process;

Understanding potentially serious

hazards caused by products that are

not approved (i.e., noncompliant

products); and

Recognizing products that are not

approved and factors that can cause

noncompliance with the approval

requirements.

Introduction

A number of OSHA standards contain requirements

for “approval” of specific products2 by an NRTL. As

explained later, the approval process generally consists

of testing and certification of a product by an

NRTL. The requirements protect workers by

helping to ensure that the products they use, or are

exposed to, in the workplace are safe. The OSHA

standards do not specify the safety requirements the

products must meet; these requirements are specified

by U.S. standards-developing organizations.

NRTLs are third-party (i.e., independent)

organizations recognized by OSHA as having the

technical capability to perform safety testing and

certification of particular types of products. NRTLs

provide testing and certification services to the

manufacturers of a wide range of products used in

the workplace.

After certifying a product, the NRTL authorizes the

manufacturer to apply the NRTL’s registered

certification mark to the product. Generally, the

manufacturer applies the mark to the products at the

time the products are manufactured. If the

certification is done under the NRTL Program, this

mark signifies that the NRTL tested and certified the

product, and that the product complies with the

requirements of one or more appropriate productsafety test standards. Users of the product can

1OSHA standards may also use the term “equipment” or “materials” when requiring approval.

2

In OSHA standards, words signifying “approval” include: “approved,”“tested,”“certified,”“listed,”“labeled,” and

“accepted.”

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SHIB 02-16-2010
2

generally rely on the mark as evidence that the product

complies with the applicable OSHA approval

requirement(s) and is safe or safety compliant.

Situations may arise in which a mark appearing on a

product is not valid and legitimate. Employers and

workers who believe that a mark is valid and

legitimate, when it is not, are using a product not

approved under the NRTL Program. Such use may

be unsafe and is a violation of the standard requiring

NRTL approval of the product.

This SHIB will help users of products and OSHA

compliance officers to identify factors signifying that a

product is noncompliant (i.e., does not meet an OSHA

requirement for approval). It also may be useful to

other authorities responsible for enforcing compliance

with electrical or fire code requirements. The SHIB

provides examples of safety hazards that could arise

with the use of noncompliant products. Before

covering these topics, the SHIB provides an overview

of the approval requirements, followed by a summary

of the OSHA NRTL recognition process, and then

describes the approval (i.e., testing and certification)

process used by NRTLs. Please refer to Appendix B

of the NRTL Program Directive for definitions of

technical terms used in this SHIB (see the link to the

Directive in the “Additional Information” section at the

end of this document).

OSHA Standards Requiring NRTL Approval of

Products

The “approval” of specific products used in

workplaces is required by standards in Title 29 of the

Code of Federal Regulations (CFR), primarily in Part

1910 (general industry), but also in Part 1915

(shipyard employment), Part 1917 (marine terminals),

Part 1918 (longshoring) and Part 1926 (construction)

of this title. The general industry standards require

approval for a number of different types of products

(see a list of these products at the NRTL Program

website (http://www.osha.gov/dts/otpca/nrtl/

index.html; see also the link titled “Types of Products

Requiring NRTL Approval” at the end of this

document). Under the construction standards (e.g.,

29 CFR 1926.403(a) and 1926.449 (definitions)), a

qualified testing laboratory must approve (i.e.,

accept, certify, list, label, or otherwise determine to

be safe) electric equipment; NRTLs are qualified

testing laboratories for this purpose.

The requirements for NRTL approval of electric

equipment, which is the type of equipment most

often requiring NRTL approval, are in 29 CFR

1910.303(a) and 29 CFR 1910.307(c). As a result

of these requirements, most electric equipment used

in the workplace must be NRTL approved. States

having OSHA-approved State Plans must have the

same requirements, or requirements that provide

workers with protection that is at least as effective as

the OSHA requirements. Currently, there are no

State Plan approved NRTLs. (For a listing of State

Plan States, see http://www.osha.gov/dcsp/osp/

index.html.)

Employers should review carefully the NRTLapproval requirements in OSHA standards to

determine which requirements specifically apply to

the products they use. A description of these

requirements is available from the NRTL Program

website previously noted (at this website, click the

link titled, “Specific References to OSHA Standards

Requiring NRTL Approval”). In some cases,

specific circumstances or conditions of use dictate

NRTL approval of the products. For example, 29

CFR 1910.106(d)(4)(i) requires approval of selfclosing fire doors, but this provision applies only to

doors installed in openings inside rooms used for the

storage of flammable and combustible liquids. In

addition, requirements other than NRTL-approval

requirements may apply to the products. For

example, electric equipment is subject to standards

governing installation, grounding, disconnection,

marking and operation. One such standard (29

CFR 1910.303(e)) requires that electric equipment

bear the manufacturer’s name, trademark, or other

descriptive marking that provides the voltage,

current, wattage, or other ratings, as necessary, of

the equipment.
3

OSHA’s Recognition of NRTLs

To ensure that each NRTL is qualified to approve

products used in the workplace, OSHA established

the NRTL Program. The regulations for the program,

including the requirements for NRTL recognition, are

at 29 CFR 1910.7. OSHA’s recognition of an

organization as an NRTL assures that it is: (1)

independent of the product’s manufacturer, supplier

and vendor, (2) capable of testing and certifying the

product using specified product-testing standards, and

(3) regularly evaluated by OSHA for compliance with

OSHA’s requirements and policies regarding the

NRTL Program. OSHA evaluates an NRTL’s

capability by reviewing its testing and certification

procedures as well as its quality assurance program.

OSHA recognizes an NRTL for testing and certifying

specific products. The scope of recognition specifies:

the product-testing standards which an NRTL can use

to test and certify products; the types of test results

that an NRTL may accept from other organizations

(including manufacturers); and which of the NRTL’s

testing facilities (i.e., subsidiary facilities) are covered

by OSHA’s recognition. Each NRTL’s scope of

recognition and other useful information about the

NRTL is available at the NRTL Program website

noted above.

NRTL testing must utilize a U.S. consensus-based test

standard, developed and maintained by a U.S.

standards-developing organization (SDO). An NRTL

may use an international test standard (i.e., developed

through a multi-country consensus process) if a U.S.

SDO makes the international test standard consistent

with applicable U.S. codes and requirements.

The NRTL’s Product Approval Process

An NRTL’s approval of a product generally consists

of testing, inspection and certification. Testing

involves determining whether a sample or prototype of

the product meets the applicable requirements of one

or more specific consensus-based, U.S. productsafety test standards. If the product meets the teststandard requirements, the NRTL then performs an

initial inspection of the factory that manufactures, or

will manufacture, the product to verify that the

products resulting from production runs are or will be

in conformance with the test standard’s requirements.

Following a satisfactory initial inspection, the NRTL

issues its certification which provides assurance that

the product conforms to the specific test standard(s).

The NRTL also authorizes the manufacturer to apply

the NRTL’s mark to each unit of the manufactured

product. After issuing its certification, the NRTL

conducts periodic follow-up (i.e., quality-assurance

and compliance) inspections of each manufacturing

facility to provide assurance that the product currently

manufactured at the facility and bearing the NRTL’s

mark is identical to the product that the NRTL tested

and certified.

An NRTL certification mark appears on a label affixed

to each unit of a product or is stamped on the

product; for small products, the mark may be on the

product’s packaging. OSHA does not require that

NRTLs use a standardized NRTL mark; therefore,

each NRTL uses a unique and distinctive mark to

certify products under the NRTL Program. An NRTL

registers its mark with the U.S. Patent and Trademark

Office, and each mark appears on OSHA’s web page

of NRTL marks3 (see http://www.osha.gov/dts/otpca/

nrtl/nrtlmrk.html). OSHA does not require the use of

certification marks containing the initials “NRTL.”

However, a few NRTLs voluntarily include these

initials on their certification marks to signify they have

certified the product under the NRTL Program.

Products requiring approval when used in the

workplace may bear non-NRTL certification marks,

such as the “CE” mark. (The CE mark is a generic

mark recognized by the European Union (EU) to

3To ensure that employers recognize NRTL-approved products prior to their purchase, employers should review OSHA’s web

page of registered NRTL marks. If uncertain regarding the authenticity of the mark appearing on the product, employers may

wish to contact the NRTL to verify that the product in question has been approved by the organization.
4

indicate that a product meets EU requirements for

product safety.) Products that bear only non-NRTL

certification marks (including the CE mark) do not

meet any OSHA standard requiring NRTL approval of

the product.

Manufacturers of electric equipment often use electric

components, such as fuses, capacitors and resistors

that are factory installed into end products such as

electric office equipment. In such cases, the end

product (but not the individual components) requires

NRTL approval. However, when a component

functions as a stand-alone electric product that

requires NRTL approval under an OSHA standard

(e.g., a motor, cord, or plug), an NRTL must approve

it before it is used in a workplace.

Hazards of Using Non-Approved Products

Employers may expose workers to serious hazards

when they use a non-approved (e. g., job-built4),

counterfeit, improperly approved, or modified product

instead of an NRTL-approved product as required by

an OSHA standard. As noted above, NRTL approval

ensures that a product meets applicable test-standard

requirements and will operate safely in the workplace.

For example, NRTL approval ensures that an electric

product will operate at its rated voltage, current and

power, and will not exceed limits that pose hazards to

workers. These hazards include electric shock, arc

flash, blast events, electrocution, equipment shorts,

explosions, burns, fires, toxic atmospheres generated

by burning and decomposing insulation and other

materials associated with electrical fires, and wiring

and component failures. Other products requiring

NRTL approval in OSHA standards, such as

equipment that uses liquefied petroleum gas, or

powered industrial trucks, can cause explosions if not

properly tested by an NRTL.

Recognizing Noncompliant Products

This section will help users recognize when products

are not NRTL-approved or have lost NRTL approval.

The following discussion provides information on how

to: (1) determine the authenticity of an NRTL’s mark;

and (2) identify whether an NRTL’s approval is no

longer within its scope of recognition. The following

paragraphs describe conditions in which a product

bearing an NRTL’s mark is not NRTL-approved.

 The product bears a counterfeit

certification mark that resembles a

NRTL’s mark. Even when the product

looks normal, an examination of the product’s

mark, either on the product or on the

packaging, may indicate that it is counterfeit.

Most NRTL marks have distinctive graphic

features not easily or accurately reproduced

by counterfeiters. For example, the letters

used in a counterfeit mark often do not have

the same proportions as the letters in the

authentic mark. A counterfeit mark also may

have unclear printing or spelling errors. A

discrepancy between the contents of the

product package and the description on the

package, or missing product information or

other package enclosures, may indicate that

the product (and its mark) are counterfeit.

When in doubt, OSHA encourages product

users to contact the NRTL to determine the

authenticity of its mark.

 The product bears a genuine NRTL mark,

but the NRTL did not test and certify it

for OSHA purposes. The NRTL’s mark

might not differentiate products that it tested

and certified under the NRTL Program from

products it tested under another (non-NRTL)

program. To determine whether a product

meets the applicable NRTL approval

requirements, a consumer (or inspector) needs

4Examples of job-built or repaired equipment which may not be approved include distribution panels, repaired extension

cords, and equipment assembled under temporary wiring situations.
5

to check the NRTL Program website to

ensure that OSHA recognizes the NRTL for

testing and certifying the type of product (i.e.,

the test standard for these types of products is

within the NRTL’s scope of recognition). If

the product cannot be found on the NRTL’s

website, contact the NRTL to confirm that the

product was not tested and certified under the

NRTL Program.

 The product bears a genuine NRTL mark,

and the NRTL tested and certified the

product, but OSHA did not recognize the

NRTL for approving this type of product

or the NRTL’s approval is no longer

within its scope of recognition. In this

case, the NRTL has certified a product even

though it has not been or no longer continues

to be recognized to do so by OSHA. Similar

to the preceding case, the product user should

check the NRTL Program website to ensure

that OSHA recognizes the NRTL for testing

and certifying the product. If the product is

not listed within the NRTL’s scope of

recognition, the product user should contact

OSHA’s NRTL Program Office to determine

whether the testing was conducted under the

NRTL Program.

 The product bears a genuine NRTL mark,

the NRTL tested and certified the

product, and OSHA recognized the NRTL

for approving that type of product, but

subsequent repair, reconditioning,

modification, refurbishing, or

remanufacturing of the product changed

its features or design. Changes made to a

product after NRTL approval will void the

NRTL’s approval of the product. Obvious

changes may not involve extensive

investigation, but other changes may require a

review of documentation to determine

upgrades, modifications, or other changes

made to the product. Such documentation

may be available only when changes follow a

formal approval process. In other cases, a

product user can determine whether changes

have been made by comparing the product’s

features to the features shown in a schematic

in the owner’s manual for the product. The

product user should report any changes found

to the NRTL so that the NRTL can determine

if the changes require reapproval of the

product.5

If a product does not have NRTL approval as

required by an OSHA standard, or if the product no

longer meets NRTL approval requirements because of

changes made to it, the product must be (1) replaced

with a properly approved product, (2) approved by

an NRTL that is recognized for testing this type of

product, or (3) reinspected and reapproved by an

NRTL, if it was properly approved but the user has

changed it.

Additional Information6

Information on OSHA’s NRTL Program is available

at:

OSHA’s NRTL Directive: NRTL Program Policies,

Procedures, and Guidelines (NRTL Directive - CPL

01-00-003 - CPL 1-0.3); [PDF, 150 KB, 70 pages].

OSHA’s NRTL Program website: https://

www.osha.gov/dts/otpca/nrtl/index.html.

29 CFR 1910.7 – Definition and Requirements for a

Nationally Recognized Testing Laboratory: http://

www.osha.gov/pls/oshaweb/

owadisp.show_document?p_table=STANDARDS&p_id=9703.

5These product changes, even if inadvertent, void the NRTL’s approval for that product, and an employer’s use of these

products in the workplace violates the OSHA standard(s) requiring that the products be NRTL-approved.

6Please direct questions regarding the NRTL Program by telephone or via e-mail (see link to OSHA’s NRTL Program website

above) to OSHA’s Office of Technical Programs and Coordination Activities, which is the office that administers the NRTL

Program.
6

Frequently Asked Questions (FAQs) about the NRTL

Program:

http://www.osha.gov/dts/otpca/nrtl/faq_nrtl.html

Types of products requiring NRTL approval: https://

www.osha.gov/dts/otpca/nrtl/prodcatg.html

OSHA standards requiring NRTL approval: https://

www.osha.gov/dts/otpca/nrtl/1910refs.html

Quick Tips for Identifying Counterfeit Marks:

Developed through the OSHA and American Council

of Independent Laboratories (ACIL) Alliance, the

Quick Tips provides information on how to identify

counterfeit marks and products in the workplace:

http://www.acil.org/associations/1304/files/

OSHA%202007QuickTips.pdf

White Paper: The Threat of Counterfeit Product

Approval Marks Warrants Aggressive Detection and

Enforcement Action.

Developed through the OSHA and ACIL Alliance,

the White Paper provides information to help safety

and health professionals and the public understand the

dangers of products with counterfeit marks:

http://www.acil.org/associations/1304/files/

OSHA2007FinalWhitePaper.pdf