Technical information

1. Comparison between two cultures and markets:

The United States and the European Union

1.1 Different juridical approaches: how are "Safety" and

"Security" implemented?

In the European Union

The national technical regulations are subject to provisions of articles 28 and 30

of the treaty establishing the European Community (the EU treaty) that

prohibit quantitative restrictions and all other measures having equivalent effect.

With the Council's decision on a new strategy aiming at technical harmonisation

and standardisation, a new technical regulation has been established to set the

following principles:

■ Legislative harmonisation is limited to the essential requirements that products

imported to the Community market should respect to circulate freely within

the Community

■ The product technical specifications that meet the essential requirements

set in the directives are defined as harmonised standards

■ The application of harmonised standards or other kinds are voluntary and the

manufacturer can always apply other technical specifications to meet the

foreseen requirements

■ The products manufactured following the harmonised standards are

considered as complying to the corresponding essential requirements

■ The provisions in the directives of the new approach prevail over any other

equivalent national provision

■ The member states have the obligation to incorporate the directives of the

new approach in their national law

■ Any national legislative, regulatory or administrative provisions adopted must

be reported to the European Commission

In The United States

Regulations for the United States are contained in the “Code of Federal

Regulations” (CFR) which is the Code of the standards issued by the Executive

and the Federal Agencies.The CFR is divided into titles (for example, title 29 -

Labor,is about all regulations related to employment). Every title is sub-divided

into chapters (chapter XVII of title 29 is about occupational health and safety

standards, divided by sectors).

It is important to highlight how the CFR details health and safety requirements,

unlike the European system in which this role is subjected to specific standards.

Regulations on electrical equipment is contained in title 29, chapter XVII, subpart

S (1910.3).

Besides CFR, the National Electrical Code (NEC) is the reference standard

for electrical systems in the United States.

INTRODUCTION TO NORTH AMERICAN STANDARDS