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Letter to Inspector Concerning ARL Revocation

[NOTE: This document varies slightly, but not significantly, from the original.]

May 12, 2009

Letter to Specific Inspector

Thank you for contacting us. We are responding to your April 24, 2009, e-mail requesting clarification on the issue you discussed with my staff concerning Applied Research Laboratories' ("ARL") status as a Nationally Recognized Testing Laboratory ("NRTL"). You inquired whether an ARL label on a product or equipment is still acceptable to the Occupational Safety and Health Administration ("OSHA"), and indicated that the product was manufactured by [a lighting manufacturer].

OSHA requires that certain types of products be approved (involving testing and certification) by NRTLs to ensure that these products are safe for use in the workplace. OSHA grants organizations recognition through its NRTL Program. OSHA revoked ARL's NRTL status on January 28, 2008. As a result, OSHA no longer accepts product certifications performed by ARL on or after this date ("revocation date"). The revocation was publicly announced on February 22, 2008 (see enclosed pages 9838 and 9839 of this dates' Federal Register publication). ARL's NRTL-related certifications were signified by the ARL "NRTL" mark, which consisted of the ARL logo accompanied by the abbreviation "NRTL" appearing below this logo.

The following examples illustrate product certifications that OSHA no longer accepts from ARL if the certifications occurred on or after the revocation date: authorizing manufacturers to use its ARL NRTL mark by imprinting the mark on labels or on products, or to use or apply labels containing this mark; issuing such labels to manufacturers; or manufacturers applying this mark or such labels to products. ARL had authority under the NRTL Program only to issue its ARL NRTL labels to manufacturers before the revocation date, and then only for products manufactured before that date.

If you have any specific questions regarding this letter, you may contact my staff at (202) 693-2110.

Directorate of Technical Support and Emergency Management


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