Jim,

Thank you for giving us an opportunity to respond.

It would have been very helpful if the telco providers referenced in your
e-mail were more specific as to why they cannot "harmonize" with UL1950
requirements.  By specific, I mean paragraph by paragraph.  But let me guess
from the few statements that you have made.  They cite cost and the added
requirement of measuring creepage and clearance rather than just performing
the dielectric strength tests.  I have a response to that.

The telco providers to the public are no longer providing the hardware; they
are purchasing it from other hardware companies that are not providing telco
connections to the public.  These hardware providers are providing equipment
to world-wide customers.  These customers are requiring IEC950 derivative
standards.  Those of us selling internationally are designing and meeting
UL1950/IEC950 requirements.  To us, the increased cost to design to two
different standards and/or to submit equipment twice for testing to two
different standards is an undue and unnecessary burden.  Whose cost is
greater, can be debated, but I don't think that would resolve anything.  I
think, however, that it should be stated that in either case, there is cost
involved to both parties.   

Thus, we are adamantly opposed to UL's proposal (your 4th paragraph) that
UL1459 be "revived" for network equipment only.   UL should realize that the
traditional "telco providers" are not at the forefront of industry
technology;-- the future is sophisticated PC applications and servers
interconnecting the world utilizing voice, Internet, Ethernet, and fast data
links.  This is indeed "information technology equipment", whether it be
located in a central office telephone switch room or in a hospital, bank, or
university.  The location no longer should matter;--  safety of the
equipment does matter.  And safety should not be relative to geography
(humidity excepted!) 

To alleviate the burden of increased costs for those few hardware providers
who are not selling to the international market, I offer the following
recommendations:

*       Extend or retain UL1459 for the domestic U.S. market only, provided
the UL1950/IEC950 harmonized requirements remain an option to those of us
who wish to ship internationally.  It should be noted that Canada (unless
they change their minds dramatically) has harmonized with IEC950 earlier
than UL and, I don't believe, would consider going back to C22.2, No.220.

                or
    
*       Add another Appendix to UL1950, similar to NAE, that would list
UL1459 only options in lieu of the stated UL1950/IEC950 requirements.
During UL product evaluation, a statement could be added under Engineering
Considerations that this product meets only U.S. requirements.  Under those
circumstances, obviously, UL would never consider providing a CB Scheme
Report and Certificate.   The rest of us will happily take UL1950 and the CB
Scheme Report.

I believe that by considering either of the above two options, UL can make
both parties happy.  But please, do not "revive" UL1459 for telephone
equipment and punish the rest of us. 

        Tania Grant, Lucent Technologies, Octel Messaging Division
        tgr...@lucent.com

> ----------
> From:         JIM WIESE[SMTP:jim.wi...@adtran.com]
> Reply To:     JIM WIESE
> Sent:         Monday, March 22, 1999 4:06 PM
> To:   emc-pstc; 'TREG'; NEBS FORUM
> Cc:   Ron Bernot; Randy Ivans; Mark Vlanich; Jim Brunssen; Tom Burke;
> Kevin Ravo; 'MARK WALKER'; Bob Burek; Tom_Amatulli; Frank Terlato; Bob
> Raskey; harry.vanza...@telops.gte.com; chuck_gr...@smtp.nynex.com;
> tto...@uswest.com; jmla...@uswest.com; mben...@uswest.com;
> sbi...@hotmail.com; Larry Todd; Keith Kuhn
> Subject:      Network Equipment and UL 1459/1950
> 
> TIA 41.7 and Underwriters Laboratories are interested in obtaining
> information and input relating to concerns, complaints and problems with
> the
> cutover from UL 1459 to UL 1950 3rd Edition for equipment designed to be
> owned, installed and maintained by a telecommunications provider.  This is
> equipment and installations that are traditionally exempt from the NEC,
> but
> could make up the demarcation point.  The cutover is scheduled for March
> 15th, 2000.
> 
> Interest in telco providers having "safety listings" on new products they
> purchase has grown rapidly in the last few years.  Equipment installed by
> the telco providers has traditionally been built utilizing design
> guidelines
> based on Bellcore standards (such as GR-1089-CORE), and/or UL 1459.  As
> many
> of you know, UL 1950 3rd edition is based upon spacings called creepage
> and
> clearance.  Traditional telco installations are deficient with regard to
> creepage and clearance, but will meet the dielectric tests called out in
> UL
> 1459.  There are also substantial differences between GR-1089-CORE, UL
> 1459
> and UL 1950 3rd with regard to voltage limits. 
> 
> In discussions with various telco providers over the past month, there has
> been a consensus that there is not a perception of safety problems and
> there
> is some concern that the ramifications of eliminating UL 1459 could have
> an
> undesired impact.  They have stressed that harmonization is not a factor
> as
> the infrastructure used in North America is unique.  They also stressed
> that
> they have 3 basic concerns with regard to safety listings; no increased
> cost
> to the product, can utilize existing shelves, housing, channel banks and
> infrastructure, the listing is to a standard that is acceptable into to
> foreseeable future.  UL 1950 3rd Edition without some substantial
> deviations
> will not meet the needs of the telco providers.
> 
> Work is currently ongoing at UL to determine if UL 1459 needs to be
> revived
> for network equipment, reissued under a new standard number with a revised
> scope for network equipment only, or develop deviations in UL 1950 3rd
> edition.
> 
> As such, if you have any input, concerns or issues with the above
> mentioned
> topic, TIA  41.7.1 and UL would be very interested in your comments.  They
> are trying to determine if there is industry support to look further into
> these issues.  Please forward this E-mail to anybody you know that might
> be
> outside this mailing list that also might be interested.
> 
> Please send comments, complaints, problems etc. to:
> 
> 1.) Randy Ivans (chairman of TIA 41.7.1)
>      iva...@ul.com
>      516-271-6200 ext. 22269
> 
> 2.) Mark Vlanich (UL Engineering Team Leader)
>      vlani...@ul.com
>      919-549-1647
> 
> 3.) Jim Brunssen (Telcordia formerly Bellcore)
>       jbrun...@notes.cc.bellcore.com
>       973-829-2977
> 
> 4.)  Or simply respond to me and I will present it to TIA in May
> 
> Thanks,
> 
> Jim
> 
> Jim Wiese
> Compliance Engineer
> ADTRAN, INC.
> 901 Explorer Blvd.
> P.O. Box 140000
> Huntsville, AL 35814-4000
> 256-963-8431
> 256-963-8250 fax
> jim.wi...@adtran.com 
> 
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