Hi Donald:


You ask a whole stack of questions...

Safety certification of a product is done by means of
a contract between the manufacturer (or his representative)
and the certification house.  This contract restricts
all data, including the safety report, if any, as private 
between the "submittor" and the certification house.  

By contract, the only data that the certification house 
can make public is whether or not the product is certified, 
in particular whether or not the product is eligible to bear 
the certification mark.  (There are some certifications which
need not employ a mark and need not be made public.)

Indeed, there are often good reasons why the manufacturer 
would not like product descriptions and test data made
public.  One is that manufacturers do not like to make such
data available to competitors.

The means for making certifications public is usually a
certification house publication identifying the 
manufacturer and the model numbers of certified products.
Nothing more.

However, the manufacturer has the right (under the contract)
to provide copies of the data to whomever he pleases.  Some
manufacturers will do so on request from a customer, and 
others will not.

And, the certification house has the right to refer to the
data when evaluating a product which incorporates a 
certified product.

For certified components, some certifiers will include in
their report some "conditions of acceptability."  These are
safety requirements that must be fulfilled in the end-product
as a condition of using the component.  If such conditions
are a part of the report, then it is imperative for the
end-product manufacturer to get a copy of the conditions.
Otherwise, the certifier will check those conditions and
if they are not met, will fail your product.  This creates
an awkward situation since the certifier cannot reveal the
conditions of acceptability to the end-product manufacturer.

Almost always, end-products incorporate components from 
other manufacturers.  Where these components contribute to
the safety of the end-product, the certification house will
either:

1)  require the component to be certified, or
2)  perform component testing in the end-product.

(The first option is the one that minimizes testing i the
end-product.)

If you are considering substituting one certified component 
for another certified component, the end-product certification 
house may or may not accept the component without some testing.  
This depends on the nature of the construction and of the 
component.

If you are considering substituting a non-certified 
component for a certified component, then testing will indeed
be in order.  This is the ONLY method by which a non-certified
component can be deemed equal to a certified component.  And,
such acceptance only applies to the particular product and
construction that was tested, not a general acceptance.

Beware of non-certified components where the manufacturer
has no plans to certify it but competing products are
certified.  Or where the manufacturer says it meets 
certification house requirements.  More often than not, you
will find the component deficient.  And that's why the
component is not certified.

Also note that you will spend almost as much money for 
testing the component in your product as would the component 
manufacturer if he submitted it for certification.  Consider 
this cost amortized over the quantity of the components you
will use.  The lower cost component may not be the bargain 
you first thought.


Best regards from sunny San Diego,
Rich



-------------------------------------------------------------
 Richard Nute                      Product Safety Engineer
 Hewlett-Packard Company           Product Regulations Group 
 AiO Division                      Tel   :   +1 619 655 3329 
 16399 West Bernardo Drive         FAX   :   +1 619 655 4979 
 San Diego, California 92127       e-mail:  ri...@sdd.hp.com 
-------------------------------------------------------------





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