Hi Gary:


You pose yet another provocative idea!  Re-arranging
your statement, I come up with the following:

"The requirements in the standards must be made based on 
    1) the real world situation, and 
    2) engineering judgement,
    3) evaluation, and 
    4) continued investigation into 
       a) what hazards are occurring, and 
       b) how they can be prevented."

These are requirements for STANDARDS.  I'm not sure how
an NRTL will attack these, except by participating on the
standards committees.

The standards committee members are supposed to bring their
expertise to the table so that the standard is relevant to
the hazards.  I suggest that your "want" is what standards
committees do, not NRTLs.

Some certification houses have published their own standards,
e.g., UL, CSA, VDE.  But, proprietary standards do nothing
for world harmonization of standards.

Indeed, UL has done research into various hazards, published
their findings, and based their proprietary standards on 
those findings.  I've not seen much safety research -- from
anybody -- in the last 30 years.  Can anyone cite such 
research since Charles Dalziel published his work on the
Ground Fault Circuit Interrupter?  Standards committees 
don't even bother to test new requirements before publishing
the standards!

The various NRTLs are in business to make money.  Even the
"not-for-profit" NTRLS must have income exceeding expenses
to stay in business.  NRTL customers are the source of 
income.  Most NRTL customers only want certification.  This
is a check-off process.  Most NRTLs don't look at a product
any further than compliance with the standard.  

You COULD pay an NRTL to do the things you request.  But, I'm
not at all sure you would find it worth the money.  Indeed, 
as I have said before, there is no engineering discipline in 
our engineering schools or in post-grad seminars that would 
qualify NRTL engineers to rationally do the things you request.
Yes, they know well the standards, and some can guess as to 
the basis for the requirements.  But, none of us have an
engineering foundation by which we could investigate hazards
not contemplated by the various standards.

So, safety standards continue to be, as one wag has stated:

    "the inversion of bad experiences."


Best regards,
Rich



-------------------------------------------------------------
 Richard Nute                      Product Safety Engineer
 Hewlett-Packard Company           Product Regulations Group 
 All-In-One 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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  • [no subject] Gary McInturff
    • Requirements for an NRTL. Rich Nute

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