ORBIS Compliance

OSHA Seeks Comment on Intertek's Application to Add UL 3100 to Its NRTL Scope

Published /Effective /United States of America

On September 29, 2026, OSHA published Intertek Testing Services NA, Inc.'s application to expand its Nationally Recognized Testing Laboratory scope and issued a preliminary finding in favour of the request. Intertek seeks authority to test and certify products under UL 3100, ANSI/CAN/UL Automated Mobile Platforms (AMPs).

Comments and requests for an extension are due October 14, 2026 under Docket OSHA-2007-0039. OSHA states expressly that the preliminary finding is not an interim or temporary approval.

A final decision will be issued through a second Federal Register notice after review of comments. The notice may increase future availability of recognised testing and certification services for automated mobile platforms, but it does not change UL 3100, create a new product requirement or currently expand Intertek's recognised scope.

Impact

Impact assessment: Medium.

Key reasons: A final grant would add another recognised certification option for UL 3100 products, but the September 29 notice is only an application and preliminary finding.

Who is affected?

Manufacturers of automated mobile platforms, industrial mobile robots and related systems, employers using such products, Intertek customers, competing NRTLs and safety compliance teams.

Conclusion:

Track the docket through October 14 and wait for OSHA's final-decision notice before treating UL 3100 as part of Intertek's recognised NRTL scope.

Regulatory Authority

Occupational Safety and Health Administration (OSHA), U.S. Department of Labor

Regulatory Impact

Impact TypeStatus
Top Priority
Type Certificate
Spectrum Bands
Import Changes (HS Codes)
Standard Changes
Product Changes
Label Changes

United States of America Quick Facts

Regulatory AgencyFederal Communications Commission (FCC)
Certification TypeMandatory for most telecom equipment
License ValidityValid indefinitely as long as compliance is maintained
Application LanguageEnglish
Legal License HolderLocal representative may be required for some cases
In-country Testing RequirementMay be required for certain telecom equipment

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