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Frequently Asked Questions

Frequently Asked Questions for NRTLs and NRTL Applicants

OSHA created the NRTL program to ensure that certain types of equipment be tested and certified for their safe use in the workplace. OSHA’s NRTL regulations were established in 1988. The first organization became recognized as a NRTL in 1989.

A Nationally Recognized Testing Laboratory (NRTL) is a private-sector organization that OSHA has recognized as meeting the legal requirements in 29 CFR 1910.7 to perform testing and certification of products using consensus based test standards. These requirements are:

  • The capability to test and evaluate equipment for conformance with appropriate test standards;
  • Adequate controls for the identification of certified products, conducting follow-up inspections of actual production;
  • Complete independence from users (i.e., employers subject to the tested equipment requirements) and from any manufacturers or vendors of the certified products; and
  • Effective procedures for producing its findings and for handling complaints and disputes.

An organization must have the necessary capability both as a product safety testing laboratory and as a product certification body to receive OSHA recognition as an NRTL.

NRTL recognition is an acknowledgment that an organization has necessary qualifications to perform safety testing and certification of the specific products covered within its scope of recognition. As a result, products that have been properly certified by the NRTL are acceptable (PDF) to OSHA for use in the workplace. "Properly certified" generally means: 1) the product is labeled or marked with the registered certification mark of the NRTL; 2) the NRTL issues the certification for a product covered within the scope of a test standard for which OSHA has recognized it; and 3) the NRTL issues the certification from one of its sites (i.e., locations) that OSHA has recognized. OSHA's recognition of an NRTL is not an endorsement of the equipment certified by the NRTL.

OSHA’s standards contain requirements for approval (i.e., testing and certification) of certain products by a Nationally Recognized Testing Laboratory (NRTL).  For example, in 29 CFR 1910.303, OSHA requires NRTL approval for many kinds of electrical equipment when they are used in the workplace. Standards like these help protect workers by ensuring products and equipment are designed for safe use in the workplace.

OSHA follows the "Procedures for Initial OSHA Recognition" found in Appendix A to 29 CFR 1910.7 (Appendix A).  These procedures are clarified in the NRTL Program Directive and NRTL Application Guidelines.  When an organization submits an application for recognition as an NRTL, OSHA staff thoroughly reviews their application materials for completeness and to determine whether the applicant has met the requirements for recognition.  In conjunction with this determination, the NRTL program staff generally performs an in-depth on-site assessment of the applicant's organization, programs, and facilities.  If the NRTL program staff makes a positive determination, the NRTL program staff prepares a report and recommendation that the application be approved by the Assistant Secretary, on behalf of the agency.

OSHA publishes the Agency’s preliminary finding on the application for NRTL recognition in the Federal Register. Following a 30-day comment period, OSHA publishes a second notice announcing its final decision and response to any comments received.

After publication of a final decision to recognize an NRTL, the Assistant Secretary of Labor for Occupational Safety and Health sends the applicant a formal notification of its approval. This notification outlines the specific scope and terms of the NRTL recognition. The NRTL must apply for renewal of recognition every five years.

Any testing agency or organization considering itself to meet the definition of nationally recognized testing laboratory as specified in 29 CFR 1910.7 may apply for OSHA recognition as an NRTL. There is no requirement to have a physical presence in the United States; however, for applications from foreign-based organizations, OSHA must consider the "reciprocity" of the foreign government, as described in Section I.A.1.b of Appendix A.

Yes, OSHA does charge fees for various activities in the NRTL program, including costs for on-site assessments and for changes to existing scopes of recognition.  Additional information on fees, as well as OSHA’s most recent fee schedule, may be found at 29 CFR 1910.7(f), and on OSHA’s website at Fee Payment Instructions and Information.

The NRTL Program requirements are contained in 29 CFR 1910.7.  Organizations also are encouraged to review the NRTL Program Directive, as well as the NRTL Application Guidelines (PDF*).

OSHA notes that it is considering revisions to its NRTL Program policies to more closely align them with International ISO/IEC Standard (ISO) 17025 and ISO 17065. As a result of these potential changes, it is suggested that if an organization wishes to become an NRTL, it contact the NRTL Program staff at nrtlprogram@dol.gov, and inquire about current and potential program policies and how these potential changes might impact its application.

The specific safety test standard or standards for which an NRTL applies for recognition, and that OSHA approves, define one area of its scope of recognition. The other areas are the specific testing locations (sites) and “supplemental programs” that OSHA has recognized for the NRTL.

An NRTL may only certify products to the specific product safety test standards included in its scope of recognition.  When an organization applies for recognition, it submits a list of test standards for which it seeks recognition.  OSHA then determines, among other things, whether these standards are "appropriate" as defined in 29 CFR 1910.7, and whether the organization meets the criteria for recognition in 29 CFR 1910.7.  After initial recognition, an NRTL may seek to expand its scope of recognition by, for example, requesting recognition for additional test standards or sites.

The NRTL Program requirements are contained in 29 CFR 1910.7.  Organizations also are encouraged to review the NRTL Program Directive, as well as the NRTL Application Guidelines (PDF*).

As stated above, OSHA is considering revising NRTL Program policies to more closely align them with ISO 17025 and ISO 17065.  As a result of these potential changes, it is suggested that if an NRTL wishes to expand its scope of recognition, it contact the NRTL Program staff at nrtlprogram@dol.gov, and inquire about current and potential program policies and how potential changes might impact its application.

Yes, provided the NRTL has met certain criteria.  OSHA has broadly grouped NRTL activities into ten "programs" and included the description and criteria for each program in Federal Register notices published on March 9, 1995 (60 FR 12980) and January 9, 2009 (74 FR 923).  The first or basic program stipulates that an NRTL that will certify a product must perform all product testing and evaluation itself.  An NRTL's initial recognition will always include this first program.  The other nine programs, called "supplemental programs," involve the NRTL's acceptance of testing and evaluation data or services, or certain contract services, from outside parties, to perform functions necessary for the NRTLs' testing and certification operations.  An NRTL must apply for recognition to use any of the supplemental programs. OSHA will grant the request if the NRTL has met the criteria for the specific program.

An NRTL must use appropriate product safety test standards in certifying products. These test standards contain technical requirements that products must meet for workplace safety. OSHA does not develop these test standards.  However, OSHA defines what it means by “appropriate test standard” in its regulation (29 CFR 1910.7).  Organizations such as the American National Standards Institute (ANSI) and the American Society for Testing and Materials (ASTM) publish many appropriate product safety test standards. A product safety test standard for which an NRTL is recognized is different than, but must be consistent with, OSHA standards, with which employers must comply pursuant to the Occupational Safety and Health Act of 1970 (29 USC 651 et seq).

Given that each NRTL has met the requirements for recognition, OSHA considers NRTLs recognized for the same product safety test standard to be capable of testing to, and certifying under, that standard.  OSHA’s recognition of an NRTL does not reflect a judgment of the NRTL’s relative (when compared with other NRTLs) experience, personnel, facilities and equipment, testing methods, and other aspects of its operations for testing and certifying products.

Frequently Asked Questions for Employers and Regulators

OSHA created the NRTL program to ensure that certain types of equipment be tested and certified for their safe use in the workplace. OSHA’s NRTL regulations were established in 1988. The first organization became recognized as a NRTL in 1989.

A Nationally Recognized Testing Laboratory (NRTL) is a private-sector organization that OSHA has recognized as meeting the legal requirements in 29 CFR 1910.7 to perform testing and certification of products using consensus based test standards. These requirements are:

  • The capability to test and evaluate equipment for conformance with appropriate test standards;
  • Adequate controls for the identification of certified products, conducting follow-up inspections of actual production;
  • Complete independence from users (i.e., employers subject to the tested equipment requirements) and from any manufacturers or vendors of the certified products; and
  • Effective procedures for producing its findings and for handling complaints and disputes  

An organization must have the necessary capability both as a product safety testing laboratory and as a product certification body to receive OSHA recognition as an NRTL.

OSHA's recognition of an NRTL is not an endorsement of the equipment certified by the NRTL. Instead, NRTL recognition is an acknowledgment that an organization has necessary qualifications to perform safety testing and certification of the specific products covered within its scope of recognition. As a result, products that have been properly certified by the NRTL are acceptable (PDF) to OSHA for use in the workplace. "Properly certified" generally means: 1) the product is labeled or marked with the registered certification mark of the NRTL; 2) the NRTL issues the certification for a product covered within the scope of a test standard for which OSHA has recognized it; and 3) the NRTL issues the certification from one of its sites (i.e., locations) that OSHA has recognized.

OSHA’s standards contain requirements for NRTL product testing and certification for 39 product types. For example, in 29 CFR 1910.303, OSHA requires NRTL approval for many kinds of electrical equipment when they are used in the workplace. OSHA’s website contains a listing of the type of products requiring NRTL approval.

After certifying a product under the NRTL program, the NRTL authorizes the manufacturer to apply a registered certification mark to the product. This mark signifies that the NRTL tested and certified the product under the NRTL program, and that the product complies with the requirements of one or more appropriate product safety test standards. Users of the product can generally rely on the mark as evidence that the product complies with applicable OSHA approval requirement(s) and is safe for use in the workplace.

OSHA does not mandate the use of, a specific "NRTL" mark. Some NRTLs have voluntarily included the acronym "NRTL" with their regular certification marks, although OSHA does not require this practice. However, with or without the use of the "NRTL" acronym, a registered certification mark by an NRTL on a product designates product conformance to the applicable product safety standard.

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.

Similarly, ATEX Certification is a certification of equipment intended for use in potentially explosive atmospheres in the European Union.  Equipment intended for use in potentially explosive atmospheres in the United States must have the specific mark of one of the NRTLs recognized to test and certify this type of equipment.

An NRTL must, with limited exception, certify products requiring "approval" by OSHA standards.  For example, the OSHA standards addressing electrical hazards (subpart S of 29 CFR Part 1910) define the term "approved" as acceptable to the Assistant Secretary of Labor for Occupational Safety and Health, and provide that equipment is acceptable to the Assistant Secretary of Labor:

  • 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
  • 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
  • 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.

OSHA ensures the competence of NRTLs to test and certify products, in large part, by: 1) recognizing NRTLs as qualified to test and certify products used in the workplace; and 2) auditing NRTLs regularly to verify that they sustain the quality of their operations and continue to meet the requirements for recognition. OSHA enforces the requirements for NRTL approval of products, in large part, by performing workplace inspections during which OSHA compliance safety and health officers (CSHOs) may examine specific products for which OSHA requires approval to check whether they are in fact approved (for example, by checking if a particular product contains the certification mark of an NRTL). OSHA may cite and impose penalties on an employer if it finds a violation of an OSHA standard requiring approval of a product.

Given that each NRTL has met the requirements for recognition, OSHA considers NRTLs recognized for the same product safety test standard to be capable of testing to, and certifying under, that standard.

Twenty-seven states and territories operate their own OSHA-approved occupational safety and health programs, called State Plans. Twenty-two State Plans cover both private sector and state and local government workplaces, while five State Plans cover state and local government workplaces only. In these five states, Federal OSHA covers private sector workers.

States that operate State Plans must adopt and enforce occupational safety and health programs that are at least as effective as the Federal OSHA program. To meet this burden, a State Plan may adopt standards that are identical to those Federal OSHA standards requiring approval of certain products by a Federal OSHA-recognized NRTL. Alternatively, a State Plan might meet this burden by establishing its own program for recognizing testing laboratories and certifying bodies.  In such cases, the recognition granted and products approved would only apply within the State Plan’s area of coverage. For more information on State Plans: https://www.osha.gov/dcsp/osp/index.html

OSHA notes that local governments (whether or not part of a State Plan) generally may determine the nature and extent of their acceptance of NRTL certifications as part of local-code promulgation and enforcement efforts.

Frequently Asked Questions for Product Manufacturers and Suppliers

OSHA’s standards contain requirements for NRTL product testing and certification for 39 product types. For example, in 29 CFR 1910.303, OSHA requires NRTL approval for many kinds of electrical equipment when they are used in the workplace. OSHA’s website contains a listing of the type of products requiring NRTL approval.

Manufacturers should contact one or more NRTLs directly to obtain a time and price quotation for product certification.  The NRTL will advise what documentation and samples are required for testing and certification. OSHA does not need to be contacted for product evaluation, testing, registration or certification.

OSHA’s authority is limited to employers; therefore, OSHA does not require manufacturers or suppliers, as applicable, to have the products they manufacture or supply certified by an NRTL.  That said, it would be in the interest of manufacturers or suppliers, as applicable, to have products requiring approval under OSHA standards to be NRTL-certified, as many, if not all, of their customers are most likely employers that must follow applicable OSHA standards requiring approval of products and equipment.

An NRTL must, with limited exception, certify products requiring "approval" by OSHA standards. For example, the OSHA standards addressing electrical hazards (subpart S of 29 CFR Part 1910) define the term "approved" as acceptable to the Assistant Secretary of Labor for Occupational Safety and Health, and provide that equipment is acceptable to the Assistant Secretary of Labor:

  • 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
  • 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
  • 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.

An NRTL must use appropriate product safety test standards in certifying products for workplace safety. These test standards contain technical requirements that products must meet for workplace safety. OSHA does not develop these test standards. However, OSHA defines what it means by “appropriate test standard” in its regulation (29 CFR 1910.7).  Organizations such as the American National Standards Institute (ANSI) and the American Society for Testing and Materials (ASTM) publish many appropriate product safety test standards. A product safety test standard for which an NRTL is recognized is different than, but must be consistent with, OSHA standards, with which employers must comply pursuant to the Occupational Safety and Health Act of 1970 (29 USC 651 et seq). 

OSHA allows NRTLs to accept product testing, certifications, approvals and work output conducted by other NRTLs.

While OSHA does allow NRTLs to accept product testing, certifications, approvals and work output conducted by other NRTLs, OSHA does not require an NRTL to accept testing, certifications, approvals or work output conducted by other NRTLs.  That is solely a business decision of each NRTL.

Given that each NRTL has met the requirements for recognition, OSHA considers NRTLs recognized for the same product safety test standard to be capable of testing to, and certifying under, that standard. OSHA’s recognition of an NRTL does not reflect a judgment of the NRTL’s relative (when compared with other NRTLs) experience, personnel, facilities and equipment, testing methods, and other aspects of its operations for testing and certifying products.


*Accessibility Assistance: Contact OSHA's Directorate of Technical Support and Emergency Management at (202) 693-2300 for assistance accessing PDF materials.

All other documents, that are not PDF materials or formatted for the web, are available as Microsoft Office® formats and videos and are noted accordingly. If additional assistance is needed with reading, reviewing or accessing these documents or any figures and illustrations, please also contact OSHA's Directorate of Technical Support and Emergency Management at (202) 693-2300.

**eBooks - EPUB is the most common format for e-Books. If you use a Sony Reader, a Nook, or an iPad you can download the EPUB file format. If you use a Kindle, you can download the MOBI file format.

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