PSNet

UL Practical application guide discussion

Several good points have been made in the discussion of the practical
application guide supplied by UL; I’ll add my U$ two-bits worth here

Let's start with a story: the question of interpretation has been with us
for a long time.  An old timer, a German trained engineer who later worked
for a test house, described his indoctrination into the world of safety
testing.  As a beginning engineer, one day his boss came to him and said
when they go up to VDE to have the product examined he should remember to
take along his copy of the standard and make notes in the margin as to the
interpretation of requirements as they were described.  Later, as a project
engineer, when he took his product to VDE his boss reminded him to take
along the new engineer with his copy of the standard to do the same thing.
This was obviously training by apprenticeship.

Having worked in standards development arena for 25 years or so, I found
that is not easy to make the standard absolutely clear – there is an ongoing
pressure for conciseness and compromise (since it is written by a
committee - you know all the old jokes: an elephant is a mouse designed to
MIL specs; a camel is a donkey designed by a committee).  This means that
there also is ongoing effort to get clarification of requirements and to
clarify the written standard itself.

We know that in large companies there is considerable discussion among
designers and safety engineering professionals as to the intent and
requirements of the standards.  In some cases it is organized, but much is
not.

Much of the discussion that we have here on the PSNet is along the same
lines - to provide the experience of others to help clarify the requirements
or the intent of the requirements in a standard.  As with the company
efforts, the advent of email has gone a long way to get things written down,
but not always organized in any recoverable way (RCIC not withstanding).  My
experience is that UL engineers are generally not familiar with the PSNet
discussions.

There are some formal, traditional efforts to do this clarification &
codification.

Some standards committees themselves work to clarify the requirements; for
instance TC74/IEC 60950 has a chairman's advisory panel that will answer
questions from IEC national committees (not from individuals) that are
phrased in a manner that they can be answered by a simple yes/no response.
On occasion the process of answering these questions has prompted a change
in the standard to provide additional clarification to the issue.  These
answers are provided back to the IEC national committees for distribution.

Within the CB Scheme the CTL (Committee of Testing Laboratories) has an
internal method for polling laboratories as to interpretation of
requirements or testing practice and, after discussion, providing an
agreed-upon interpretation for all labs to use.  This is intended to provide
uniform interpretation and application of requirements and testing
throughout all of the participating labs on a worldwide basis. I don’t
believe that these interpretations are generally available outside the labs.

Finally, UL has its P. A. G. that we've been discussing.  This guide was
developed so that UL engineers would provide the same interpretation of
requirements from any office.  It's really quite convenient that they offer
this outside of the lab for use but there's no obligation to do so.
Charging a nominal amount to support making this available does not, in my
opinion, seem unreasonable.  This could also easily be done on-line where
you would be charged on a page-by-page basis (how many peeks per U$ dollar
at those Russian sneak-a-peek sites - once you enter your credit card
number?).

Whether or not these are more than guidelines - it seems that trying to work
around them is like trying to push aside the preponderance of the evidence
in legal proceedings.  In each case they are considered opinions from a
group of knowledgeable participants in each process.

It would be most convenient to find some way to combine all the interpretive
information into the standard such as is done with the US NEC (National
Electric Code) Handbook.  In that book each clause is followed by
interpretive information to further explain the application of the
requirements.  (Hmmm – on reflection this looks like it would be a good
retirement project for me if I could get my hands on the interpretations.
What would you be willing to pay?)

I hope that this little summary is useful.

  br,     Pete

  Peter E Perkins, PE
  Principal Product Safety Consultant
  Tigard, ORe 97281-3427
  503/452-1201     fone/fax
  p.perk...@ieee.org



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