Hi Fabian:
> We have a potential supplier of an OEM equipment that is not
> NRTL listed. They suggested we have it listed (i. e. pay for the testing
> ourselves) as part of our system. I am not aware of any case histories of
> this nature. Has anyone had this experience? Can an NRTL issue a listing
> for one company (buyer of product), yet audit another (the manufacturer)? I
> am skeptical of this suggestion.
I have done this (although it was long time ago).
Anyone can submit any product for certification.
Anyone can submit an OEM equipment (or component)
as a part of their own equipment, and have it
evaluated as part of that equipment.
However, such processes makes the submittor the
"owner" of the certification. This is awkward
because:
1. To make the submittal, you must obtain all
of the construction and component data from
the OEM.
If the OEM cooperates, then he does exactly
the same job for you as he would for the
certifier. You become the middle-man.
If the OEM does not cooperate, then you have
to ferret out all the data based on your own
review of the product. A daunting task. And,
you have no idea of alternate constructions
and components. These could trip up
production-line inspections.
2. If the product is to be labeled with the
certifier's mark, you would be responsible
for applying the mark. The mark would go
ONLY on those units supplied to you from the
OEM, and cannot be applied to any other OEM
production of the same model (because the
unit was evaluated as part of YOUR system
and is not necessarily for general use).
Note that the OEM product may not need the
certifier's mark -- depending on how it is
incorporated in your equipment.
3. You assume all responsibility for continued
compliance as if you were the manufacturer.
The big problem is that the OEM controls
production, and makes changes as appropriate
for his purposes, and without regard to any
consequences to the certification.
If the OEM cooperates, you can get in the
loop to approve all production changes.
If the OEM does not cooperate, then you will
somehow need to periodically inspect the
units to verify that the OEM has not changed
any certification-critical construction or
component.
If the OEM cooperates, inspections would be
conducted at the OEM factory and the OEM
would build according to the FUS Procedure.
If the OEM does not cooperate, inspections
would be conducted at your factory. You
would then be responsible for resolving any
non-compliance situation. In the worst case,
this may mean re-working the OEM unit on your
factory floor.
I'm sure there are still other points to be made,
but these are some of the big ones.
Considering all of these situations, it is better
that the OEM own the certification.
Another option is for you to act as the agent of
the OEM, and obtain certification on his behalf.
If you pay for the certification, then you should
retain ownership of the certification such that
the OEM cannot sell any certified products to
anyone else. (This usually convinces the OEM to
pay for the certification.)
Personally, I would be wary of an OEM who suggests
his product be tested as a part of your system.
For some reason, he wants to avoid certification
even though his customer requires it!
He knows enough about certification to know that
you can do it as a part of your end-product
certificaton -- yet he doesn't want to certify
his product.
I strongly suggest you find out why he does not
want to certify his product. This will tell you
what you will need to carefully control when you
own the certification.
Better still, find another OEM.
Regards,
Rich
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