Art wrote: A real-world (not hypothetical) experience: I'm aware of products shipped from Asia with UL markings present, prior to the receipt of their "Authorization to ship" letter. The manufacturer's position was that they were in warehouses, awaiting receipt of the "Authorization". The warehouses, in fact, were containers on ships, headed for the U.S. Obviously, this was a business decision (and a gamble that the "Authorization" would be issued without requiring any modifications of the product steaming in this direction). And, yes, the gamble paid off :-)
Hello Art, You are 100% correct.........With ever increasing time pressure to get product to market the above seems to be common practice but it is not authorized by UL, TUV or any Agency I have dealt with. Product built before the Agency approval has been received should not be marked with the Agency mark...The product might be built exactly the same as product built after the approval but no Agency I know of would agree to such a practice without a field inspection you alluded to.....While the risk may be minimal, shipping preapproval product with the Agency mark, this could also become a liability issue if one of the products are marked and shipped before the approval has been received. Should this product cause an issue in the field a sharp lawyer could use this to his advantage in a liability case if they can verify the DOM was before the Agency approval was received............. Again I know it is done in practice but there is certainly a risk..... Regards, John From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Arthur Michael Sent: Monday, April 10, 2006 11:53 AM To: emc-p...@ieee.org Cc: Richards, Carl Subject: Re: UL approvals Hello Carl, On Mon, 10 Apr 2006, Richards, Carl wrote: > Dear Group, > > I am attempting to understand the limitations of shipping UL approved > hardware under the following circumstances: > > 1. A modification made to an approved product without notification to > UL of the change; and with the intent of not applying the UL mark when > shipping the product UL should have no interest in products shipped without their marks present. With respect to the use of the word "approved". UL does not "approve" anything - they "list" it. > 2. A manufacturer certified to perform their own UL compliance subject > to verification by UL, can the manufacturer build systems while > waiting for final approvals; and would it be possible for the > manufacturer to build and ship such a product without applying the UL > mark? Again, you can ship product that does not bear UL marks - but don't expect to subsequently add the mark to those products without a field-inspection later on. UL Marks are, in general, required to be applied at the point of manufacture. A real-world (not hypothetical) experience: I'm aware of products shipped from Asia with UL markings present, prior to the receipt of their "Authorization to ship" letter. The manufacturer's position was that they were in warehouses, awaiting receipt of the "Authorization". The warehouses, in fact, were containers on ships, headed for the U.S. Obviously, this was a business decision (and a gamble that the "Authorization" would be issued without requiring any modifications of the product steaming in this direction). And, yes, the gamble paid off :-) Best regards, Art Michael -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- | http://www.safetylink.com | | | | The Safety Link is the most comprehensive collection | | of product safety and standards resources on the WEB | | | | Int'l Product Safety News | | (In it's 19th year of publication) | | P.O.Box 1561 - WWW | | Middletown CT 06457-8061 U.S.A. | | Phone: (860) 344-1651 Fax: (860) 346-9066 | | http://www.safetylink.com/#IPSN | -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- > I hasten to add, this is a hypothetical and educational question! > > Best Regards > > Carl > > > Carl Richards, > Regulatory Compliance Manager, > Aspect Software > 2, The Square > Stockley Park, Uxbridge, UB11 1AD, > United Kingdom > > > +44 (0)208 589 1461 Office > +44 (0)870 460 1950 Fax > +44 (0)7875 27 1461 Mobile > www.aspect.com > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society > emc-pstc discussion list. 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Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
