Hello, I am perplexed in my efforts as a Quality Manager for electrical power distribution center manufacturer trying to insure our internal manufacturing processes are in compliance with NEC requirements as I interpret NEC/NFPA-70 in particular the new 2020 edition. I am challenged by my coworkers to prove that NEC specifies that all electrical equipment must be NRTL listed and labeled. The new 2020 edition article 110.3 has commentary text that states: "Listing or labeling is the most common method of establishing suitability. This section does not require listing or labeling of equipment, but it does require considerable evaluation for approval. Before approving the installation, the AHJ may require evidence of compliance with 110.3."
Well in all my almost 11 years in this business, absolutely none of the AHJ's have commented on listing and labeling of equipment when I know we have at times violated the requirement. Sometimes as a result of inability to find listed components or earlier shear ignorance of the requirement. Recently we have been told by a reputable relay panel supplier that NEC does not require their equipment be listed and labeled. However, they are registered with UL and provide the labels for additional healthy fees. I was and remain flabbergasted by this response. None the less, they present a challenge in that my management seems to believe this statement. The supplier has further indicated that 95% of their products do not get NRTL labels.
Please help me by explaining the logic behind the 2020 commentary text indicating this section does NOT require listed and labeled equipment. Is the requirement in another section of the standard? Or, does the standard avoid specifically stating it is required for legal purposes? I also understand that approval of equipment is the responsibility of the AHJ but that is a fairly nebulous or abstract method of getting to where the requirement lies? Additionally, we do have the occasional problem where their is not a source for listed special equipment. What should we do in those rare but occasional circumstances?
I look forward to your response and assistance.