We had a poll on this forum awhile ago which essentially asked would
we accept self certified parts. The answer was pretty distinctly no, and I,
speaking only for myself, haven't change my perception one iota.
A manufacture essentially telling me - Don't worry it works, trust
me! - isn't going to get to far because I am worried about my customers and
products not his. I don't have time to review all of his test results and
conclusions to make a judgment, especially when I can get a condensed
version of it from the competition.
This whole issue is kind of a damned if you do and a damned if you
don't problem.
1) Obviously, even among those that should know the standards
because that is there sole business there is some level of confusion. That
problem, again in my opinion, is greatly enhanced the smaller the NRTL for
because they lack the overhead to fully train the new hires properly and
when they have employee turn-over it is a much larger portion of their staff
and experience. So they stay is this really tight lack of experience loop.
Then when they do get really good at it, just like the big guys they promote
them out of that position. Just the ability to get a peer review is
difficult - there is no one to talk with or the time to spend reviewing each
others problems. This doesn't mean they can't do an adequate job its just
that they have resource constraints that make it very difficult.
2) I know of at least one small NRTL that was so overburdened and
who so strongly advertised faster, better and cheaper (no not NASA) that
they gave advance authorization to begin marking a product with their logo
BEFORE the did any evaluation of the product whatever. I didn't find out
about it until later when they claiming invalid construction. Fortunately,
the standard didn't back them up and after I brought it to their attention
we could proceed to completion.
3) The NRTL acceptance is not pressured by "the Boss" to get the
thing out of the door regardless of problems, we can fix them later. Bosses
have other pressures like money, lack of understanding or just plain, "ain't
letting the gov'ment telling me what to do" mentality. I'm being a little
factious but I think you get the point.
An thread earlier on this site quote the guy in the Washington
Post(?) who had doctored samples to get them through UL (I believe it was
UL) and then was really upset that UL didn't catch him at it. Way too many
manufacturers with that kind of logic to suit me.
Yes, the inability to put pressure on a NRTL is a double edged
sword. That is mostly, but certainly not all, a scheduling problem, or
waiting too long in the development cycle to get product in front of them.
The only thing I can suggest is to just be better than they are at
their jobs, understand not only what the standard says but what it means, do
not be afraid to take them to task if you don't agree, and don't accept an
error even if it seems to work in your favor. (The AC versus DC fuse that
started this could be one of those types of issues and ultimately it may
cost the manufacturer at least one customer).
I know this sounds a little self serving but that isn't the intent.
I suspect that many of you have electronic copies of where I have mis-spoke,
or just plain screwed up. I hate it when that happens, but mostly I just try
to learn and not do it again.
Geeez, I wonder just what the maximum loading force on this soap box
I'm standing on is?
Gary
-----Original Message-----
From: Maxwell, Chris [mailto:chr...@gnlp.com]
Sent: Tuesday, October 24, 2000 10:47 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: Got another beef about an NRTL....
This argument highlights why I like the "self-declaration" route to
conformance.
If I was NRTL A, I would be VERY cautious about accepting data from NRTL B
for a product that will be sold with my (NRTL A) mark on it.
I beleive that the system is much more practical when self declaration is
used. Then, we as the manufacturer take responsibility for selecting an
approved part (approved by NRTL A). We then take responsibility for either
selecting an accredited lab (for instance, NRTL B) to test the entire
product or we test the product in house using approved equipment and
methods. We then self declare our product based upon sound engineering test
data, regardless of whether it's from NRTL A, NRTL B or Sam's Discount
Compliance Lab (assuming Sam is accredited). I don't even bother with
putting the NRTL's mark on the product. After all, if there is a problem,
the customer is coming after my company (maybe even me), not the NRTL.
Also, most NRTL's limit their liability by saying that they have only
performed a type test on a single unit, ... (insert lots of legal blah,
blah, blah here)
So, why should I worry about an NRTL's legal anxiety about putting their
mark on my product? I'm not sure what protection it affords my company (as
suming we already have test data from an accredited lab).
In the end, Duncan. If I was in your position, I would ask your NRTL to
produce a sound ENGINEERING, not legal, not commercial reason that your NRTL
should not accept the other NRTL's data. I would also consider reminding
them that their mark on your product is a form of free advertising for them
and that your product would look just as good to a customer with the other
NRTL's mark on it. (Maybe that's a little harsh). I would also consider
the option of self declaration (if possible) it may lessen your NRTL's
anxiety enough that they would accept the other NRTL's data. I caution
that, if you consider self declaration, you really need to know that the
product is safe and the NRTL is only holding out to either protect their
name or jack up their invoice. This would be a hard call to make. My
experience is that the laboratory and its personnel that I have dealt with
are sincere when they have a concern about one of our products.
Good luck
Chris
The views expressed here are mine alone, neither my employer or any NRTL is
taking responsibility for them :-)
> -----Original Message-----
> From: John Juhasz [SMTP:jjuh...@fiberoptions.com]
> Sent: Tuesday, October 24, 2000 9:58 AM
> To: 'duncan.ho...@snellwilcox.com'; emc-p...@majordomo.ieee.org
> Subject: RE: Got another beef about an NRTL....
>
> Duncan,
>
> I've had the scenario with my end product (very simple product - metal
> enclosure, SELV printed circuit,
> 150W Recognized component Power Supply, Recognized Input module. That's
> it.)
>
> I had it listed with NRTL B. Market pressure forced me to get NRTL A's
> listing mark -
> to the same standard. NRTL A would not accept ANY data (not just test
> data, even part
> number info - I had to send the complete package again).
>
> While I don't like to pay twice for the same thing, and while I was
> exposed to
> what amounted to be different interpretations (between the NRTLs) of the
> specifications
> causing great frustration . . . I looked at it from a different point of
> view.
>
> Don't get me wrong, I do sympathize with you, and I wish they had an MRA
> between
> them - it would save a lot of time, money, and frustration . . . but I can
> see
> NRTL A's point.
>
> If a customer came to me with a product and wanted it listed with my mark,
>
> before I put MY mark on it (which, historically, most consumers consider a
> quality
> indicator) I would make damn sure that the product was compliant, lest I
> incur
> the wrath if it fails. I wouldn't take anyone's word for it (report or
> not)
> and rubber stamp it.
>
>
> John Juhasz
> Fiber Options
> Bohemia, NY
>
>
>
> -----Original Message-----
> From: duncan.ho...@snellwilcox.com [
> <mailto:duncan.ho...@snellwilcox.com>]
> Sent: Tuesday, October 24, 2000 6:58 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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