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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> 
> -------------------------------------------
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> 

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