Howdy, howdy, howdy.

Product incorporates Type 5 component VDRs and is installed in an OVC III
environment via field wiring connections. Evaluation for a CB Scheme
Certificate and Test Report.

In recent dealings with a CBTL, I was told that the VDRs in a product
needed to be Type 2. In referencing UL 1449 (for convenience), a Type 2
VDR has the assumption of fixed wiring for the VDR itself and mounting by
solder onto a board is not a consideration (except that a Type 2 VDR may
include a system of Type 4 and/or Type 5 VDRs and other components) .

Per the CBTL, the Type 5 VDR certifications used may or may not be
suitable for the application, depending on the level of testing performed
on the VDR during its component evaluation, primarily associated with the
combination wave open-circuit voltage amplitude related to the OVC.

I checked the CTL Decisions and OSM Decisions for 61010-1 for both the
third edition and fourth edition and found zero related decisions. The
CBTL was unmoved by my efforts, claiming this matter has been a long term
discussion in TC66 and imposed their will irrespective of a defined
requirement in the IEC.

Likewise, the CBTL was unmoved by the testing performed by another
division of the mothership that applied 6 kVpk surge testing to the
complete product as a part of another evaluation to type. This may be
because the staff and intent of the testing was not under the
accreditation of the CBTL/NCB, but I'm not certain.

In checking publicly available databases for components, the kind of
information needed to preselect an appropriate Type 5 VDR is not possible.
This ultimately boils down to evaluation of each Type 5 VDR by the CBTL
for each and every prospective alternate or substitute VDR.

Has anyone else encountered this sort of requirement? The CBTL either
could not or would not provide a written requirement, so this smells off.


Regards,

Peter L. Tarver

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