OSHA Adds UL 8400 to NRTL Program’s List of Safety Standards

On Jan. 16, 2024, the Occupational Safety and Health Administration (OSHA) announced the expansion of the scope of recognition of UL Solutions as a Nationally Recognized Testing Laboratory (NRTL).

Along with this expansion, OSHA also added 13 safety standards to the NRTL program’s List of Appropriate Test Standards. UL 8400, the Standard for Virtual Reality, Augmented Reality and Mixed Reality Technology Equipment, is one of the additional test standards included that applies to AR/VR/MR equipment, including headsets in commercial and enterprise environments.

What is the impact?

United States employers continue exploring multiple applications of AR/VR/MR — often described as spatial computing or immersive technologies — even after the pandemic, as they provide a better experience to their employees not just in complex skill learning, e.g., professional or interpersonal, but also interactive product design, prototyping, demonstrations, etc. According to IoT Analytics, the enterprise VR/AR market was $1.4 billion (USD) in 2022 and is projected to reach $4 billion (USD) by 2027, exhibiting a compound annual growth rate (CAGR) of 23%. As these technologies provide employees with more intense and immersive experiences, a new set of safety concerns comes alongside that require attention from all U.S.-based employers.

Standards listed in the NRTL program’s List of Appropriate Test Standards are considered effective at the time OSHA recognizes them. With UL 8400 being added, immersive technology — AR/VR/MR equipment — is now expected to be Listed, or third-party certified, by an OSHA NRTL. This is to ensure risk of injury is reduced for use in the workplace. Under the Occupational Safety and Health Act of 1970, 29 U.S.C. § 651 and § 652-659, enterprises are required to procure equipment with NRTL certification for their employees’ use. This includes enterprise electronic equipment, such as laptops, tablets, smartphones, displays, printers and, now, AR/VR/MR headsets.

Recommendations

When procuring AR/VR/MR:

• To mitigate workplace risks and protect employees, enterprises should only furnish employees with equipment evaluated, tested and certified by an authorized OSHA NRTL¹.
• To provide a workplace free from recognized hazards by following the manufacturer’s instructions, including necessary precautions, installations and/or supervisions, preparation of a safe area prior to use, procedures for safe use, post use, maintenance and storage, etc.

For enterprises that develop, manufacture, distribute or sell AR/VR/MR equipment:

• Ensure equipment is designed to meet UL 8400.
• If advertising equipment is to be used in enterprise environments, ensure equipment is evaluated, tested and certified to UL 8400 by an authorized OSHA NRTL.
• To verify if the NRTL has the scope of the appropriate safety standards, visit OSHA’s homepage for the NRTL program. Each NRTL can be checked for its scope of recognition; UL Solutions can be found here.

Other related links

• UL LLC: Grant of Expansion of Recognition and Modification to the NRTL Program's List of Appropriate Test Standards

About the author

Flore Chiang has been with UL Solutions for 22 years and serves as the principal engineer for consumer and enterprise technology equipment and power supplies. He also serves as a convenor and an expert on various national, regional and international technical committees covering a broad range of consumer and business products. Chiang authored the draft of UL 8400.

Note

1. UL Solutions is the first and currently the only NRTL for UL 8400.