OSHA considers the two alternatives, 2 and 3, to be minor exceptions to the requirements for NRTL approval of specific types of equipment, but "An NRTL can and must certify the vast majority of products requiring "approval."

This means that if your product is sold into the 'workplace' it does not need to be specifically UL listed or approved, but it must be tested by another NRTL (see chart) or by methods 2 and 3 above.

The 'cosmic intent' is that no product gets into consumers' hands without considering and validating safety. OSHA requires federal, legal compliance whereas CPSA allows voluntary compliance at this time. However, as we will see below, many consumer groups will demand safety compliance of products, be they for the consumer or to be used in the workplace, making the compliance effectively mandatory due to industry practices, purchasing requirements or other factors.

Now, a bit about the European Union trail-of-safety Regulation

The European Commission (EC) is the executive body of the European Union, which has the right to initiate legislation in all Community areas. Product legislation called the New Approach Directives⁶, which are contained in the Official Journal of the European Community (OJEC), outline the CE Marking process, which is the most notable non-food product safety regulatory effort in the European Union. A CE Mark is probably required if you want to sell to the 25 European Union (EU) and 4 European Free Trade Association (EFTA) countries. This process is claimed as "voluntary", but much in the same sense that the IRS use to claim that paying US taxes was a voluntary obligation. However, not all products are covered under CE marking; only those included in the 20 or so categories of products listed in the New Approach directives require the CE mark. Other products, however, fall within the scope of the General Safety Directive 2001/95/EC) or within the International Electrotechnical Commission (IEC) for Conformity Testing and Certification of Electrical Equipment (IECEE), AKA the CB Scheme.

There's no free lunch.