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  • OSHA Announces UL LLC's Application for NRTL Recognition Expansion to Include New Michigan Test Site

OSHA Announces UL LLC's Application for NRTL Recognition Expansion to Include New Michigan Test Site

  • By: Learn Laws®
  • Published: 02/18/2026
  • Updated: 02/18/2026

The Occupational Safety and Health Administration (OSHA), part of the U.S. Department of Labor, announced on February 18, 2026, in the Federal Register that UL LLC has applied to expand its recognition as a Nationally Recognized Testing Laboratory (NRTL). The application seeks to add one new test site located at 4322 New Energy Way in Auburn Hills, Michigan. OSHA's preliminary review supports granting this expansion, following an on-site assessment that identified and resolved initial nonconformances. This notice opens a public comment period until March 5, 2026, allowing stakeholders to provide input before a final decision. The move underscores ongoing efforts to ensure robust independent testing and certification of workplace equipment, which is critical for compliance with federal safety standards and protecting workers from hazards related to faulty products.

Background on the NRTL Program

The NRTL program, established under 29 CFR 1910.7, requires OSHA to recognize organizations capable of independently testing and certifying products to meet safety standards. Recognition confirms that an NRTL meets specific criteria for technical competence, independence, and quality control. It allows employers to use NRTL-certified products to comply with OSHA regulations that mandate tested and certified equipment in workplaces. UL LLC, headquartered in Northbrook, Illinois, has been an NRTL since its initial recognition, currently operating 57 recognized sites worldwide. These sites test products ranging from electrical equipment to fire safety devices, ensuring they adhere to applicable standards before market entry.

The program's origins trace back to the Occupational Safety and Health Act of 1970, which aimed to reduce workplace injuries by enforcing safety standards. Over time, OSHA has expanded the NRTL framework to include multiple organizations, fostering competition while maintaining rigorous oversight. UL's application aligns with this framework, as Appendix A to 29 CFR 1910.7 outlines the process for expansions, including public notices and comment periods to promote transparency.

Details of UL's Application and OSHA's Review

UL submitted its application on October 6, 2023, requesting recognition for the Auburn Hills facility. As detailed in the Federal Register notice, OSHA conducted an on-site review on February 24-25, 2025. Assessors identified some nonconformances with 29 CFR 1910.7 requirements, but UL addressed these issues to OSHA's satisfaction. The notice states, 'UL has addressed these issues sufficiently, and OSHA staff has preliminarily determined that OSHA should grant the application.' This preliminary finding highlights UL's compliance efforts and the site's readiness for product testing and certification activities.

The Auburn Hills site would join UL's extensive network, potentially focusing on emerging technologies such as renewable energy equipment, given its address on 'New Energy Way.' While the notice does not specify the site's exact testing focus, UL's overall scope includes standards for electrical safety, hazardous locations, and more. Recognition would enable the site to certify products under UL's existing NRTL scope, which OSHA maintains on its website.

Key Players and Legal Framework

OSHA, led by Principal Deputy Assistant Secretary Amanda Laihow, who authorized the notice, plays the central role in evaluating NRTL applications. The agency processes these under strict guidelines to ensure impartiality. UL LLC, a global safety science company founded in 1894, is a key player with a long history in standards development and testing. It collaborates with standards organizations like ANSI and IEC to create test methods.

Relevant legal precedents include OSHA's past expansions for other NRTLs, such as Intertek and TUV Rheinland, which followed similar notice-and-comment procedures. The framework in 29 CFR 1910.7 emphasizes independence, requiring NRTLs to avoid conflicts of interest. Court cases, like those challenging OSHA's authority under the Administrative Procedure Act, have upheld the agency's discretion in recognition decisions, provided they follow public participation rules.

Political forces influencing this area include bipartisan support for workplace safety, though debates arise over regulatory burdens on businesses. Industry groups often advocate for efficient NRTL expansions to speed product approvals, while labor unions emphasize thorough vetting to prevent substandard certifications.

Implications for Workplace Safety and Industry

Expanding UL's recognition could streamline certification processes for manufacturers, particularly in the automotive and energy sectors near Auburn Hills, a hub for Michigan's manufacturing economy. Short-term implications include increased testing capacity, potentially reducing backlogs and enabling faster market access for safe products. This aligns with OSHA's goal of preventing hazards like electrical fires or equipment failures, which contribute to thousands of workplace injuries annually, according to agency data.

Long-term effects might involve broader adoption of advanced testing for innovative products, such as electric vehicle components or smart manufacturing tools. However, challenges persist, including ensuring consistent quality across sites and adapting to evolving standards amid technological changes. Different perspectives emerge: manufacturers view expansions as efficiency boosters, while safety advocates stress the need for rigorous oversight to avoid diluting standards. Regulators balance these by requiring ongoing audits.

Potential Next Steps and Ongoing Debates

Following the comment period ending March 5, 2026, OSHA will review submissions and recommend a final decision to the Assistant Secretary. If granted, a second Federal Register notice will confirm the expansion. Stakeholders can request extensions for comments, but justifications must be strong. Future challenges include integrating new sites amid global supply chain disruptions or regulatory shifts. Debates continue on whether the NRTL program sufficiently addresses emerging risks like cybersecurity in connected devices, with potential for policy updates to enhance its scope. This application reflects the program's adaptability, ensuring continued relevance in promoting safe workplaces.

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