Fine and valuable responses. Thank you.

Can anyone respond to my question?


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


Peter Tarver


Date sent:              Fri, 26 Feb 2016 14:59:02 -0800
From:                   Peter Tarver <ptar...@enphaseenergy.com>
> 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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