Bravo Robert - you're right on the mark.
Dan Kinney
Horner APG
> -----Original Message-----
> From: Loop, Robert [SMTP:rl...@hnt.wylelabs.com]
> Sent: Wednesday, October 25, 2000 11:58 AM
> To: tgr...@lucent.com
> Cc: emc-p...@majordomo.ieee.org
> Subject: RE: Got another beef about an NRTL (haven't we all?)
>
>
> Hi Tania,
>
> At Wyle Laboratories (one of the many NRTL's), we typically will accept
> test
> data from another NRTL. Our assumption is that other NRTL demonstrated
> proficiency to OSHA requirements and probably many others (A2LA, NVLAP,
> ISO
> Guide 25, etc.), hence their test data is assumed to be valid.
>
> It is not practical to retest every approved component or sub-assembly as
> if
> it had never been investigated by another NRTL. The time and cost to the
> customer would put us out of the product safety business. Each standard
> that we investigate a product to is done on a clause-by-clause basis to
> ensure nothing is missed. And the test methodology is adequately
> described
> in the standard to ensure uniformity of testing.
>
> As long as the COA's are reviewed and tested accordingly in the
> end-product
> application, we have done our job in ensuring the safety of the final
> assembly.
>
> One of the complaints from industry that has lead to worldwide harmonized
> standards was that different countries were using safety marks as a trade
> barrier. My personal opinion is that this holds true with any NRTL that
> will not accept test data from another NRTL without a signed MRA in place.
> It is not an easy accomplishment to achieve NRTL status, OSHA holds the
> bar
> pretty high up. Refusing to accept test data from another NRTL, is a way
> of
> saying that OSHA doesn't know its business on how to qualify a lab (again,
> my opinion).
>
> UL has a stranglehold on component recognition by requiring retesting of
> any
> component approved by another NRTL. The net effect is that this denies a
> large segment of business to its competitors. Fair? Hardly. Smart
> business
> strategy? Absolutely!
>
> That is my not-for-profit opinion and not my employers.
>
> Sincerely,
> Robert Loop
> Engineering Supervisor
> Wyle Laboratories
> Product Safety
> ph - (256) 837-4411 x313
> fax- (256) 721-0144
> e-mail: rl...@hnt.wylelabs.com
>
>
> > ----------
> > From: Grant, Tania (Tania)[SMTP:tgr...@lucent.com]
> > Reply To: Grant, Tania (Tania)
> > Sent: Tuesday, October 24, 2000 5:37 PM
> > To: 'duncan.ho...@snellwilcox.com'; emc-p...@majordomo.ieee.org
> > Subject: RE: Got another beef about an NRTL....
> > Importance: High
> >
> >
> > All right, let's get specific here and actually use some names! UL has
> a
> > Mutual Recognition Agreement with CSA to accept each other's test
> reports.
> > This agreement also specifies details about how they conduct the various
> > tests (it used to be that earth leakage current measurements were
> > performed
> > differently by the two agencies). The agreement also allows them to
> > "harmonize" standards, and many have been harmonized since the MRA was
> > first
> > signed. Where the standards still differ, my understanding is that
> both
> > UL
> > and CSA will perform both sets of test to satisfy both agencies'
> > requirements.
> >
> > I am not aware that MRAs exist between the different NRTLs. And how is
> > one
> > NRTL going to know whether the test procedures are the same between the
> > different NRTLs? In other words, there is no allegiance between them.
> > And yes, they do compete. But so did UL and CSA, but now they sing the
> > same tune.
> >
> > Any NRTL mark is good, per OSHA and the U.S. NEC, for end-use product.
> > But
> > if you are incorporating components and other equipment into your
> systems,
> > you need to specify your expectations when you purchase parts. We
> > specify
> > X NRTL and we get that.
> >
> > Tania Grant, tgr...@lucent.com
> > Lucent Technologies, Switching Solutions Group
> > Intelligent Network and Messaging Solutions
> >
> >
> > -----Original Message-----
> > From: duncan.ho...@snellwilcox.com [ mailto:duncan.ho...@snellwilcox.com
> > <mailto:duncan.ho...@snellwilcox.com> ]
> > Sent: Tuesday, October 24, 2000 3:58 AM
> > To: emc-p...@majordomo.ieee.org
> > Subject: Got another beef about an NRTL....
> >
> >
> >
> > Group,
> >
> > What about another scenario that I have been in with two NRTL's.
> > For the sake of embarrassment,lets call them 'NRTL A' and 'NRTL B'
> >
> > Firstly any components or equipment recognised or listed by an NRTL are
> > deemed
> > 'acceptable' to OSHA so long as it is used as prescribed in its
> conditions
> > of
> > acceptability or use. so can I presume that as OSHA accepts any NRTL
> mark
> > they
> > are all of equal standing.
> >
> > Why is it then that NRTL A will not accept a power supply approved by
> NRTL
> > B.
> > The latter is true for NRTL B who will accept NRTL A's mark with no
> > problems
> > (in
> > all cases the conditions of acceptability are followed)
> >
> > So long as the conditions of acceptability are followed and there are no
> > engineering reasons for NRTL A to reject NRTL B's approval then what
> > happens
> > next. Is there any recourse or would we have to go to one NRTL and get
> the
> > whole
> > lot retested. If there is no engineering reason, can an NRTL reject
> > anothers
> > recognition just because it distlikes it or maybe sees it as
> competition!
> >
> > Has anyone else had a similar experience, if so what did you do to
> resolve
> > it
> > without paying out for more NRTL approvals on an already recognised
> > component.
> >
> > Any comments would be greatly recieved.
> >
> > Regards,
> >
> > Duncan Hobbs, Product Safety Engineer
> > Snell and Wilcox Ltd.
> >
> >
> >
> > -------------------------------------------
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