OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

June 29, 2015

Mr. Kim G. Feddersen Vac-U-Max
69 William Street
Belleville, NJ 07109

Dear Mr. Feddersen:

Thank you for your correspondence to the Occupational Safety and Health Administration's (OSHA), Directorate of Enforcement Programs. You requested clarification from OSHA on Nationally Recognized Testing Laboratory (NRTL) approval requirements for equipment in combustible dust atmospheres.

Scenario: Some equipment manufacturers believe that all equipment used in combustible dust atmospheres, including non-electrically powered vacuum cleaners, requires NRTL listing/approval.

Question: Could OSHA clarify the NRTL listing/approval requirements for non-electrical vacuum cleaners used in combustible dust atmospheres?

Response: Currently, no NRTL is recognized to certify non-electric vacuums for hazardous locations. Generally, non-electrical vacuums used in any hazardous (classified) locations, must meet the applicable manufacturer's listing and labeling requirements. OSHA only recognizes certification and testing by NRTLs. A list of currently recognized NRTLs and the scope of NRTL recognition can be viewed at this site: https://www.osha.gov/dts/otpca/nrtl/.

OSHA's requirements for hazardous (classified) locations are in 29 CFR 1910.307, and those requirements are only for electrical and electronic equipment and wiring in hazardous (classified) locations. OSHA standards are similar to NFPA standards for equipment used in classified locations. Therefore, OSHA requires equipment used in any hazardous (classified) location to be rated for the location by Class, Zone, Division, and/or Group, as necessary.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

 

Thomas Galassi, Director
Directorate of Enforcement Programs