Recently, I had a discussion with an NTRL regarding product factory 
inspections.
I was under the impression that where the label was applied, that was where
the factory inspection would occur. And, if the contract noted a different
company where the manfacturing was done and being that was typically
(not always) where the lable was applied, that was inspections would happen.

Not so, according to these people. This was in response to a hypothetical
situation I gave them to consider.

For instance, say your company has sells a product in your companys name.
But, you have assembly done at any number of contractors. And the NRTL
label is applied at your company. Even if the contractors aren't on the
contract with the NRTL for whatever reason, the factory inspector will
inspect as much as possible the product at your site, then inspect the
contractor site even though it is not on the contract. Basically at their
discretion.

The result of this is ... if say your company has ten contractors on a list
of approved vendors with which do business (just as an example for the
sake of argument) for possible assembly contracts and at any time you
do business with just one of those contractors, this all really means you
must inform the NRTL of all ten 'posible' manufactoring locations and
all ten, including your own company, are to be inspected on a quarterly
basis and thus increase your factory inspection cost by a factor of 10.

For some reason, this all sounds a little unreasonable to me.

What say you?

Regards, Doug McKean


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