Laws and standards in North America

North America

In contrast to Europe, the EC declaration of conformity is irrelevant in North America. In the USA and Canada, various standards, regulations and directives specify how machinery safety is to be guaranteed.

Product standards, fire protection regulations ("Fire Codes"), electrical directives and national laws are particularly relevant in the USA. The Occupational Safety and Health Administration (OSHA) in the USA also regulates the provision of a safe, healthy workplace.

In Canada, the Canadian Centre for Occupational Health and Safety (CCOHS) regulates workplace safety, backed up by a wide range of local regulations in the various provinces.

Laws and standards in the USA

The legal basis in the USA can be seen as a mix of product standards, fire codes, electrical codes (NEC) and national laws. Local government bodies have the authority to monitor that these codes are being enforced and implemented.

US citizens recognise standards from the following organisations, above all:

  • Occupational Safety & Health Administration (OSHA)
  • American National Standards Institute (ANSI)
  • Underwriters Laboratories (UL)
  • National Fire Protection Association (NFPA)

Note: CE certification is a European requirement. It is not recognised in the USA and has no relevance or significance.


Occupational Safety & Health Administration (OSHA)

The Occupational Safety and Health Administration in the USA is an agency of the US Department of Labor. In accordance with the OSH Act (occupation safety and health), employers are responsible for providing a safe, healthy workplace. OSHA's mission is to assure safe workplaces by setting and enforcing standards and by providing training, outreach, education and assistance. Employers must comply with all applicable OSHA standards. They must also comply with the General Duty Clause of the OSH Act, which requires employers to keep their workplaces free from serious hazards.

In 22 US federal states, for example Michigan and California, the respective government operates a safety and health program, which carries out OSHA's duties in this state, implementing equivalent or sometimes even stricter requirements. In four other states, the state plan only covers public sector workers. According to OSHA: "States must set job safety and health standards that are "at least as effective as" comparable federal standards. (Most States adopt standards identical to federal ones.) States have the option to promulgate standards covering hazards not addressed by federal standards."

As government regulations, OSHA standards are in some ways comparable with European directives, although the technical requirements are very different. OSHA is more concerned with describing specific mandatory technical requirements than with abstract requirements. Another important difference is that EU directives are aimed primarily at machine manufacturers and integrators, while OSHA standards are intended for the employers that operate the machine (generally the purchaser or owner of the machine). In the USA, therefore, it is the purchaser's responsibility to demand compliance with OSHA standards.

In addition to making planned and unplanned inspections, OSHA inspectors are also called in when there is an industrial accident. If it is established that "voluntary" ANSI standards have not been taken into account, the OSHA fines may be higher. The penalties may also be stricter when it comes to civil proceedings.

American National Standards Institute (ANSI)

ANSI standards are developed by private organisations and have the status of "voluntary industry standards". However, ANSI standards can still be found included as part of a contract. Many OSHA standards are based on ANSI standards. In many cases the mandatory OSHA standard is based on an older version of a voluntary ANSI standard. In these cases it is advisable to apply both standards.

Underwriters Laboratories (UL)

UL publishes safety standards. These mainly contain requirements for electrical devices and components. One example is UL 508A (industrial control panels). Some UL standards were submitted to ANSI by UL; they are now also ANSI standards. UL standards are mainly concerned with the risk from fires and electric shocks.

OSHA requires that almost all electrical devices and cables in workplaces meet the relevant UL standards and that these are listed / certified by a nationally recognised testing laboratory (NRTL). OSHA publishes lists of NRTLs. The lists include CSA (Canadian Standards Association), Intertek (ETL), TÜV Rheinland, TÜV SÜD and UL (Underwriters Laboratories), for example. Unlisted devices can usually obtain a type of field testing through the same NRTLs. It's worth noting that UL standards are often very different or even contradictory to IEC standards (International Electrotechnical Commission) and European standards (EN). Compliance with the UL standard is displayed by the presence of the NRTL test mark on the device. The organisations also publish a list of compliant products, so these devices are classed as "listed". Electrical engineering inspectors in the USA look for the test mark (UL, CSA, etc.) on the device. Devices without a test mark are not normally accepted.  Most of these laboratories are accredited for several countries. Only their "US" test mark is accepted. (For example, a TÜV test mark for Europe or China is irrelevant in the USA.)

National Fire Protection Association (NFPA)

The National Electrical Code (NEC) is published by the NFPA (National Fire Protection Association) as ANSI/NFPA 70. Compliance with the NEC is verified by local authority inspections (usually municipal), particularly on new buildings and larger structures.

NFPA also publishes the ANSI/NFPA 79 Standard (Electrical Standard for Industrial Machinery). This covers the same scope as EN/IEC 60204-1, but is not identical. Compliance with ANSI/NFPA 79 is essentially voluntary, but is demanded by some US federal states and local authorities.

Laws and standards in Canada

Some workplaces in Canada fall under federal legislation, which is recognised by the Canadian Centre for Occupational Health and Safety (CCOHS). However, the majority are regulated through the province or via local regulations.

Note: CE certification is a European requirement. It is not recognised in Canada and has no relevance or significance.

Electrical standards in Canada are published by CSA (Canadian Standards Association). They are often similar to US requirements. Some electrical CSA standards are based on IEC standards and adapted to Canadian needs; others have been developed in conjunction with UL or NFPA. Electrical safety is certified by laboratories, which are accredited by SCC (Standards Council of Canada). These include CSA and UL for example, but also many more.

CSA also publishes the mechanical standards in Canada. Some are based on ANSI standards or have been developed in conjunction with ANSI; others are based on ISO standards.



In the province of Ontario, technical machinery safety requirements are comparable with those of the EU (European Union). However, self certification by the manufacturer is not permitted. For most newly installed or modified machinery, Ontario Regulation 851 (Industrial Establishments – Safety Regulations) requires the owner or employer to ensure that the machinery is not operated until a PSHSR (Pre-Start Health and Safety Review) has been carried out, normally by a licensed engineer. The PSHSRs from the Ministry of Labour in Ontario consider a combination of regulations from CSA, ANSI, ISO and EN.

In terms of electrical safety, the Ontario Electrical Safety Code and Ontario Regulation 438/07 require that all electrical products and devices are certified and marked in accordance with CSA standards by a SCC-accredited institution. Electrical installations in buildings must also be inspected by the Electrical Safety Authority (ESA).


In the province of Quebec, warning notices and safety instructions must be available in both English and French.

Other provinces

Other provinces in Canada have similar electrical safety requirements to those of Ontario, based on the Canadian Electrical Code (CEC or “CE Code”) and other CSA standards. With regard to machinery safety, provinces other than Ontario mostly use CSA standards.


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