Thank you, Robert, for providing information that Wyle accepts other NRTL's test reports; however, I note your term "...typically will accept...." I, therefore, infer, that Wyle reserves the right to not accept whenever, for whatever reason, this warrants. Also, it would be helpful if you clarified whether Wyle requires the submission of the other NRTL test report in order to evaluate a product. I know that in the past I sometimes had trouble obtaining UL test reports from our vendors because they were afraid that we would use the information to go in competition against them! UL, however, has a vast database of Recognized components which is not available to other NRTLs. Thus, UL can check out the actual testing performed on these Recognized parts and use engineering judgement as to how that might affect the equipment under evaluation. Thus, you don't have to provide UL with their own test reports, but I find it extremely helpful, especially in the case of power supplies. Listed equipment is less of a risk,-- however, Listed units were approved to be used by an end-user and are not evaluated when stuffed and interconnected into somebody else's equipment or cabinet. Again, without a test report, the final evaluation may not be complete. Thus, I would think that anybody using other NRTLs than UL should always obtain all test reports of critical components. I am not being partial to UL and singing their praises;-- I am stating facts. Don't underestimate the vast UL Listing and Recognized (and Classified) database that UL has. UL can pull the Listing or Recognition at any time for non-compliance. Each time they evaluate a product, they check that the Listing or Recognition is still valid. (How often has your UL evaluation been held up because some part was not in UL's database and you had to scramble to obtain the UL N of A (Notice of Authorization) of this newly UL approved part?) Other NRTLs can check their own files, but they cannot validate the status of another NRTL's approved part (unless they telephone each time. And how many actually do that????) I find that this is a big loophole for any manufacturer who uses other approved units in their own equipment. Moral: you need to obtain those test reports and hope that the other NRTL accepts this data. Also note that legally, UL Recognition (note the capital R) is a specific term describing a UL process (and not anybody else's) of evaluating and approving components; component recognition is NOT in the public domain and UL does not have to share its Recognized component database that they carefully built over the ages. To describe this as "... stranglehold on component recognition..." is a bit unfair. Let's just say that their lawyers are better and more forward thinking than some others.
Tania Grant, tgr...@lucent.com Lucent Technologies, Switching Solutions Group Intelligent Network and Messaging Solutions -----Original Message----- From: Loop, Robert [ mailto:rl...@hnt.wylelabs.com <mailto:rl...@hnt.wylelabs.com> ] Sent: Wednesday, October 25, 2000 9:58 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> > < 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. > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com > Michael Garretson: pstc_ad...@garretson.org > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com > Michael Garretson: pstc_ad...@garretson.org > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
