RE: Got another beef about an NRTL (haven't we all?)
At one time or another, we certainly all do. Each NRTL has its own level of absurdity, whether by being too harsh or too lax. There is one NRTL the international safety community of a previous employer had agreed was lax to the point of not accepting any component or OEM device that certified exclusively by that NRTL (don't ask me for a name; I'm not interested in a law suit). Another NRTL questioned the validity of _test_data_ generated by another of its offices, not a simple construction feature in a component (this was eventually resolved). While I'd prefer a happy medium, if I had to choose between the two extremes, from an ethical perspective I'd rather have too harsh than too lax. At least with having to work a little harder to make an engineering case, I don't have to be concerned that I failed to show due diligence or have a compromised conscience. With a sound engineering position and escalating to the appropriate levels within an NRTL, you can win the day. Keep in mind that each of these NRTLs has a real concern about their competition, both on the business side and the engineering side. While I appreciate Wyle's acceptance of other NRTL test reports for components, I hope that this is not a blanket acceptance, based on my own experience with lax NRTLs. Peter L. Tarver, PE ptar...@nortelnetworks.com
RE: Got another beef about an NRTL (haven't we all?)
Thank you, Mel, I always try to persuade transformer manufacturers to obtain their own UL Recognition so that I don't have to ask for their construction details. However, since many or most signal transformers are custom or semi-custom parts, X-former manufacturers don't always want the expense of submitting such to various NRTLs. My experience has been that if the transformer is UL Recognized, UL states that in our report, and that's the end of it. However, if the transformer is NOT UL Recognized, then we have to provide samples to UL (to destruct and unwind!) and provide complete construction details, at which point all this information is printed out in OUR UL report. So, the details are out for all to see. I'll bet the same thing happens in CB reports on mains transformers. I think that the CB Scheme should up-date their process and establish their own CB database instead of requiring hard copies of CB reports to be included with our CB reports. (My last CB report is 3 inches thick!!! I have CB reports within CB reports. Where will this stop!) Sorry for getting off the subject. My latest hot button are CB reports;-- there's got to be a better way. Tania Grant, tgr...@lucent.com Lucent Technologies, Switching Solutions Group Intelligent Network and Messaging Solutions -Original Message- From: Mel Pedersen [ mailto:mpeder...@midcom-inc.com mailto:mpeder...@midcom-inc.com ] Sent: Wednesday, October 25, 2000 3:11 PM To: 'Grant, Tania (Tania)'; 'Loop, Robert' Cc: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL (haven't we all?) On Component Recognition: 1) I can certainly sympathize with an NRTL reserving the right to reject another NRTL's component recognition/certification. After all, an NRTL has the right and RESPONSIBITY to protect the integrity of its mark. It seems to me an NRTL listing equipment may be a bit foolish if it does not at least give a cursory review to the report of the NRTL giving component recognition...No NRTL is perfectcertainly some are better than others. (A certain popular NRTL I find myself having to constantly babysitsome of its offices and engineers are VERY good, but the other 50% I have dealt with were incompetent to the point of abysmal absurdity...I have had issues with its own engineers not accepting another offices (same NRTL) component certification because the two different offices (remember - SAME NRTL) had a different Interpretation on a matter. One office would be obviously wrong...this happened more than once...cost our company and our CUSTOMERS a LOT of time and money...I will say no more). It would be nice, however, if there was more of a spirit of cooperations between the various NRTL'sIn the case of component certification/recognition, it seems that BOTH the NRTL granting the component certification, and the NRTL granting the equipment listing (UL terminology here) would have a long term interest in trying to minimize thier customers testing costs headache. Especially these days, when its necessary to make every penny count. A spirit of cooperation would go a long way here. I have had a few experiences with Wyle myself, and the few I have had left me with a good impression of Wyle regarding this issue. I have never give Wyle my business only because they are not nearly as accepted at the component level as UL CSA. 2) Being that I work at a component manufacturer, I can sympathize with your suppliers who are tight fisted with thier UL reports. Certainly, it is silly to think that a modem manufacturer, for example, is only asking for my UL report in order to go into competition against me, a transformer manufacturer. But there ARE certain companies out there which have no sense of propriety, and hand our design information off to cheap competitors. Then we are in a position of providing these companies free engineering support. We like our jobs, but we have to eat too. (In my experience, Tania, your company has not been one of these, this is not a jab against your organization.) But understand, after being repeatedly burned...a component supplier can get paranoid. My company typically is not extremely free in sharing our UL or CB reports with our customer. Not that we NEVER share our UL reports, but we just like to be sure first. One option when dealing with a supplier who does not wish to share UL report, is to ask if they would be willing to share thier UL reports directly with your NRTL Engineer. This way, your NRTL Engineer gets the information he/she needs, and your supplier has little reason for suspicion. Just my humble thoughts on the matter. Regards, Mel Pedersen -Original Message- From: Grant, Tania (Tania) [ mailto:tgr...@lucent.com mailto:tgr...@lucent.com ] Sent: Wednesday, October 25, 2000 1:07 PM To: 'Loop, Robert' Cc: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL (haven't we all?) Importance: High Thank you
RE: Got another beef about an NRTL (haven't we all?)
On Component Recognition: 1) I can certainly sympathize with an NRTL reserving the right to reject another NRTL's component recognition/certification. After all, an NRTL has the right and RESPONSIBITY to protect the integrity of its mark. It seems to me an NRTL listing equipment may be a bit foolish if it does not at least give a cursory review to the report of the NRTL giving component recognition...No NRTL is perfectcertainly some are better than others. (A certain popular NRTL I find myself having to constantly babysitsome of its offices and engineers are VERY good, but the other 50% I have dealt with were incompetent to the point of abysmal absurdity...I have had issues with its own engineers not accepting another offices (same NRTL) component certification because the two different offices (remember - SAME NRTL) had a different Interpretation on a matter. One office would be obviously wrong...this happened more than once...cost our company and our CUSTOMERS a LOT of time and money...I will say no more). It would be nice, however, if there was more of a spirit of cooperations between the various NRTL'sIn the case of component certification/recognition, it seems that BOTH the NRTL granting the component certification, and the NRTL granting the equipment listing (UL terminology here) would have a long term interest in trying to minimize thier customers testing costs headache. Especially these days, when its necessary to make every penny count. A spirit of cooperation would go a long way here. I have had a few experiences with Wyle myself, and the few I have had left me with a good impression of Wyle regarding this issue. I have never give Wyle my business only because they are not nearly as accepted at the component level as UL CSA. 2) Being that I work at a component manufacturer, I can sympathize with your suppliers who are tight fisted with thier UL reports. Certainly, it is silly to think that a modem manufacturer, for example, is only asking for my UL report in order to go into competition against me, a transformer manufacturer. But there ARE certain companies out there which have no sense of propriety, and hand our design information off to cheap competitors. Then we are in a position of providing these companies free engineering support. We like our jobs, but we have to eat too. (In my experience, Tania, your company has not been one of these, this is not a jab against your organization.) But understand, after being repeatedly burned...a component supplier can get paranoid. My company typically is not extremely free in sharing our UL or CB reports with our customer. Not that we NEVER share our UL reports, but we just like to be sure first. One option when dealing with a supplier who does not wish to share UL report, is to ask if they would be willing to share thier UL reports directly with your NRTL Engineer. This way, your NRTL Engineer gets the information he/she needs, and your supplier has little reason for suspicion. Just my humble thoughts on the matter. Regards, Mel Pedersen -Original Message- From: Grant, Tania (Tania) [mailto:tgr...@lucent.com] Sent: Wednesday, October 25, 2000 1:07 PM To: 'Loop, Robert' Cc: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL (haven't we all?) Importance: High Thank you, Robert, for providing information that Wyle accepts other NRTL's test reports; however, I note your term ...typically will accept I, therefore, infer, that Wyle reserves the right to not accept whenever, for whatever reason, this warrants. Also, it would be helpful if you clarified whether Wyle requires the submission of the other NRTL test report in order to evaluate a product. I know that in the past I sometimes had trouble obtaining UL test reports from our vendors because they were afraid that we would use the information to go in competition against them! UL, however, has a vast database of Recognized components which is not available to other NRTLs. Thus, UL can check out the actual testing performed on these Recognized parts and use engineering judgement as to how that might affect the equipment under evaluation. Thus, you don't have to provide UL with their own test reports, but I find it extremely helpful, especially in the case of power supplies. Listed equipment is less of a risk,-- however, Listed units were approved to be used by an end-user and are not evaluated when stuffed and interconnected into somebody else's equipment or cabinet.Again, without a test report, the final evaluation may not be complete. Thus, I would think that anybody using other NRTLs than UL should always obtain all test reports of critical components. I am not being partial to UL and singing their praises;-- I am stating facts. Don't underestimate the vast UL Listing and Recognized (and Classified) database that UL has. UL can pull the Listing or Recognition at any time for non-compliance
RE: Got another beef about an NRTL (haven't we all?)
Bravo Robert - you're right on the mark. Dan Kinney Horner APG -Original Message- From: Loop, Robert [SMTP:rl...@hnt.wylelabs.com] Sent: Wednesday, October 25, 2000 11:58 AM To: tgr...@lucent.com Cc: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL (haven't we all?) Hi Tania, At Wyle Laboratories (one of the many NRTL's), we typically will accept test data from another NRTL. Our assumption is that other NRTL demonstrated proficiency to OSHA requirements and probably many others (A2LA, NVLAP, ISO Guide 25, etc.), hence their test data is assumed to be valid. It is not practical to retest every approved component or sub-assembly as if it had never been investigated by another NRTL. The time and cost to the customer would put us out of the product safety business. Each standard that we investigate a product to is done on a clause-by-clause basis to ensure nothing is missed. And the test methodology is adequately described in the standard to ensure uniformity of testing. As long as the COA's are reviewed and tested accordingly in the end-product application, we have done our job in ensuring the safety of the final assembly. One of the complaints from industry that has lead to worldwide harmonized standards was that different countries were using safety marks as a trade barrier. My personal opinion is that this holds true with any NRTL that will not accept test data from another NRTL without a signed MRA in place. It is not an easy accomplishment to achieve NRTL status, OSHA holds the bar pretty high up. Refusing to accept test data from another NRTL, is a way of saying that OSHA doesn't know its business on how to qualify a lab (again, my opinion). UL has a stranglehold on component recognition by requiring retesting of any component approved by another NRTL. The net effect is that this denies a large segment of business to its competitors. Fair? Hardly. Smart business strategy? Absolutely! That is my not-for-profit opinion and not my employers. Sincerely, Robert Loop Engineering Supervisor Wyle Laboratories Product Safety ph - (256) 837-4411 x313 fax- (256) 721-0144 e-mail: rl...@hnt.wylelabs.com -- From: Grant, Tania (Tania)[SMTP:tgr...@lucent.com] Reply To: Grant, Tania (Tania) Sent: Tuesday, October 24, 2000 5:37 PM To: 'duncan.ho...@snellwilcox.com'; emc-p...@majordomo.ieee.org Subject:RE: Got another beef about an NRTL Importance: High All right, let's get specific here and actually use some names! UL has a Mutual Recognition Agreement with CSA to accept each other's test reports. This agreement also specifies details about how they conduct the various tests (it used to be that earth leakage current measurements were performed differently by the two agencies). The agreement also allows them to harmonize standards, and many have been harmonized since the MRA was first signed. Where the standards still differ, my understanding is that both UL and CSA will perform both sets of test to satisfy both agencies' requirements. I am not aware that MRAs exist between the different NRTLs. And how is one NRTL going to know whether the test procedures are the same between the different NRTLs? In other words, there is no allegiance between them. And yes, they do compete. But so did UL and CSA, but now they sing the same tune. Any NRTL mark is good, per OSHA and the U.S. NEC, for end-use product. But if you are incorporating components and other equipment into your systems, you need to specify your expectations when you purchase parts. We specify X NRTL and we get that. Tania Grant, tgr...@lucent.com Lucent Technologies, Switching Solutions Group Intelligent Network and Messaging Solutions -Original Message- From: duncan.ho...@snellwilcox.com [ mailto:duncan.ho...@snellwilcox.com mailto:duncan.ho...@snellwilcox.com ] Sent: Tuesday, October 24, 2000 3:58 AM To: emc-p...@majordomo.ieee.org Subject: Got another beef about an NRTL Group, What about another scenario that I have been in with two NRTL's. For the sake of embarrassment,lets call them 'NRTL A' and 'NRTL B' Firstly any components or equipment recognised or listed by an NRTL are deemed 'acceptable' to OSHA so long as it is used as prescribed in its conditions of acceptability or use. so can I presume that as OSHA accepts any NRTL mark they are all of equal standing. Why is it then that NRTL A will not accept a power supply approved by NRTL B. The latter is true for NRTL B who will accept NRTL A's mark with no problems (in all cases the conditions of acceptability are followed) So long as the conditions of acceptability are followed and there are no engineering reasons for NRTL A to reject NRTL B's approval
RE: Got another beef about an NRTL (haven't we all?)
Thank you, Robert, for providing information that Wyle accepts other NRTL's test reports; however, I note your term ...typically will accept I, therefore, infer, that Wyle reserves the right to not accept whenever, for whatever reason, this warrants. Also, it would be helpful if you clarified whether Wyle requires the submission of the other NRTL test report in order to evaluate a product. I know that in the past I sometimes had trouble obtaining UL test reports from our vendors because they were afraid that we would use the information to go in competition against them! UL, however, has a vast database of Recognized components which is not available to other NRTLs. Thus, UL can check out the actual testing performed on these Recognized parts and use engineering judgement as to how that might affect the equipment under evaluation. Thus, you don't have to provide UL with their own test reports, but I find it extremely helpful, especially in the case of power supplies. Listed equipment is less of a risk,-- however, Listed units were approved to be used by an end-user and are not evaluated when stuffed and interconnected into somebody else's equipment or cabinet.Again, without a test report, the final evaluation may not be complete. Thus, I would think that anybody using other NRTLs than UL should always obtain all test reports of critical components. I am not being partial to UL and singing their praises;-- I am stating facts. Don't underestimate the vast UL Listing and Recognized (and Classified) database that UL has. UL can pull the Listing or Recognition at any time for non-compliance. Each time they evaluate a product, they check that the Listing or Recognition is still valid. (How often has your UL evaluation been held up because some part was not in UL's database and you had to scramble to obtain the UL N of A (Notice of Authorization) of this newly UL approved part?) Other NRTLs can check their own files, but they cannot validate the status of another NRTL's approved part (unless they telephone each time. And how many actually do that) I find that this is a big loophole for any manufacturer who uses other approved units in their own equipment. Moral: you need to obtain those test reports and hope that the other NRTL accepts this data. Also note that legally, UL Recognition (note the capital R) is a specific term describing a UL process (and not anybody else's) of evaluating and approving components; component recognition is NOT in the public domain and UL does not have to share its Recognized component database that they carefully built over the ages. To describe this as ... stranglehold on component recognition... is a bit unfair. Let's just say that their lawyers are better and more forward thinking than some others. Tania Grant, tgr...@lucent.com Lucent Technologies, Switching Solutions Group Intelligent Network and Messaging Solutions -Original Message- From: Loop, Robert [ mailto:rl...@hnt.wylelabs.com mailto:rl...@hnt.wylelabs.com ] Sent: Wednesday, October 25, 2000 9:58 AM To: tgr...@lucent.com Cc: emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL (haven't we all?) Hi Tania, At Wyle Laboratories (one of the many NRTL's), we typically will accept test data from another NRTL. Our assumption is that other NRTL demonstrated proficiency to OSHA requirements and probably many others (A2LA, NVLAP, ISO Guide 25, etc.), hence their test data is assumed to be valid. It is not practical to retest every approved component or sub-assembly as if it had never been investigated by another NRTL. The time and cost to the customer would put us out of the product safety business. Each standard that we investigate a product to is done on a clause-by-clause basis to ensure nothing is missed. And the test methodology is adequately described in the standard to ensure uniformity of testing. As long as the COA's are reviewed and tested accordingly in the end-product application, we have done our job in ensuring the safety of the final assembly. One of the complaints from industry that has lead to worldwide harmonized standards was that different countries were using safety marks as a trade barrier. My personal opinion is that this holds true with any NRTL that will not accept test data from another NRTL without a signed MRA in place. It is not an easy accomplishment to achieve NRTL status, OSHA holds the bar pretty high up. Refusing to accept test data from another NRTL, is a way of saying that OSHA doesn't know its business on how to qualify a lab (again, my opinion). UL has a stranglehold on component recognition by requiring retesting of any component approved by another NRTL. The net effect is that this denies a large segment of business to its competitors. Fair? Hardly. Smart business strategy? Absolutely! That is my not-for-profit opinion and not my employers. Sincerely, Robert Loop Engineering
RE: Got another beef about an NRTL (haven't we all?)
Hi Tania, At Wyle Laboratories (one of the many NRTL's), we typically will accept test data from another NRTL. Our assumption is that other NRTL demonstrated proficiency to OSHA requirements and probably many others (A2LA, NVLAP, ISO Guide 25, etc.), hence their test data is assumed to be valid. It is not practical to retest every approved component or sub-assembly as if it had never been investigated by another NRTL. The time and cost to the customer would put us out of the product safety business. Each standard that we investigate a product to is done on a clause-by-clause basis to ensure nothing is missed. And the test methodology is adequately described in the standard to ensure uniformity of testing. As long as the COA's are reviewed and tested accordingly in the end-product application, we have done our job in ensuring the safety of the final assembly. One of the complaints from industry that has lead to worldwide harmonized standards was that different countries were using safety marks as a trade barrier. My personal opinion is that this holds true with any NRTL that will not accept test data from another NRTL without a signed MRA in place. It is not an easy accomplishment to achieve NRTL status, OSHA holds the bar pretty high up. Refusing to accept test data from another NRTL, is a way of saying that OSHA doesn't know its business on how to qualify a lab (again, my opinion). UL has a stranglehold on component recognition by requiring retesting of any component approved by another NRTL. The net effect is that this denies a large segment of business to its competitors. Fair? Hardly. Smart business strategy? Absolutely! That is my not-for-profit opinion and not my employers. Sincerely, Robert Loop Engineering Supervisor Wyle Laboratories Product Safety ph - (256) 837-4411 x313 fax- (256) 721-0144 e-mail: rl...@hnt.wylelabs.com -- From: Grant, Tania (Tania)[SMTP:tgr...@lucent.com] Reply To: Grant, Tania (Tania) Sent: Tuesday, October 24, 2000 5:37 PM To: 'duncan.ho...@snellwilcox.com'; emc-p...@majordomo.ieee.org Subject: RE: Got another beef about an NRTL Importance: High All right, let's get specific here and actually use some names! UL has a Mutual Recognition Agreement with CSA to accept each other's test reports. This agreement also specifies details about how they conduct the various tests (it used to be that earth leakage current measurements were performed differently by the two agencies). The agreement also allows them to harmonize standards, and many have been harmonized since the MRA was first signed. Where the standards still differ, my understanding is that both UL and CSA will perform both sets of test to satisfy both agencies' requirements. I am not aware that MRAs exist between the different NRTLs. And how is one NRTL going to know whether the test procedures are the same between the different NRTLs? In other words, there is no allegiance between them. And yes, they do compete. But so did UL and CSA, but now they sing the same tune. Any NRTL mark is good, per OSHA and the U.S. NEC, for end-use product. But if you are incorporating components and other equipment into your systems, you need to specify your expectations when you purchase parts. We specify X NRTL and we get that. Tania Grant, tgr...@lucent.com Lucent Technologies, Switching Solutions Group Intelligent Network and Messaging Solutions -Original Message- From: duncan.ho...@snellwilcox.com [ mailto:duncan.ho...@snellwilcox.com mailto:duncan.ho...@snellwilcox.com ] Sent: Tuesday, October 24, 2000 3:58 AM To: emc-p...@majordomo.ieee.org Subject: Got another beef about an NRTL Group, What about another scenario that I have been in with two NRTL's. For the sake of embarrassment,lets call them 'NRTL A' and 'NRTL B' Firstly any components or equipment recognised or listed by an NRTL are deemed 'acceptable' to OSHA so long as it is used as prescribed in its conditions of acceptability or use. so can I presume that as OSHA accepts any NRTL mark they are all of equal standing. Why is it then that NRTL A will not accept a power supply approved by NRTL B. The latter is true for NRTL B who will accept NRTL A's mark with no problems (in all cases the conditions of acceptability are followed) So long as the conditions of acceptability are followed and there are no engineering reasons for NRTL A to reject NRTL B's approval then what happens next. Is there any recourse or would we have to go to one NRTL and get the whole lot retested. If there is no engineering reason, can an NRTL reject anothers recognition just because it distlikes it or maybe sees it as competition! Has anyone else had a similar experience, if so what did you do to resolve it without paying out for more NRTL approvals on an already recognised component. Any comments would be greatly
