RE: Product Marking - new twist

[WOODS]

I am commenting on a question and reply which is further back in this
continuing conversation.

>   Question: For products with external AC power supplies, would the NRTL
mark need >   to be on the supply and the product?  Or the supply only?

Previous reply: The external ac power supply must be "approved." The product
may or may not need to be approved.  If the rated input voltage exceeds 30 V
rms or 42.4 V dc, then it must be approved (per the NEC).  If the rated
input voltage is less than 30 V rms or 42.4 V dc, then the NEC does not
require it to be "approved;" it is a manufacturer's option whether to seek
third-party certification.

My comment: I agree that the NEC does not require products powered by Class
II sources to be Listed; however, we have found several local jurisdictions,
especially in Oregon, Washington and Florida,  that do require these
products to be Listed. It is not clear that these jurisdictions actually
have local amendments to the NEC or if it is an Code interpretation issue,
but after many discussions with these jurisdictions, we have given up and
now require that all of our Class II powered devices be UL Listed.

Richard Woods


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RE: Product Marking - new twist

[Ned Devine]

Hi,

Just having NRTL accreditation from OSHA is not necessarily enough.  Some
states (i.e. North Carolina and Oregon) and local authorities (i.e. City of
Las Angeles) have there own requirements.  These local regulations can
override the OSHA NRTL program.  The NRTL must have/get approval from these
municipalities.

Ned Devine
Entela, Inc.
Program Manager III
Phone 616 248 9671
Fax  616 574 9752
e-mail  ndev...@entela.com 

-Original Message-
From: Veit, Andy [mailto:andy.v...@mts.com]
Sent: Friday, January 26, 2001 7:06 AM
To: 'Rich Nute'
Cc: 'emc-p...@majordomo.ieee.org'
Subject: RE: Product Marking - new twist



Rich-
Thanks for the detailed reply to Chris's questions.  
Is it possible that a piece of equipment with an NRTL listing can be
disconnected by a local electrical inspector/electrician enforcing the NEC
because that paticular NRTL is not "approved" in their jurisdiction?

Doesn't the NRTL approval by OSHA take precedence over whether or not the
local authorities accept the NRTL's listing?

Thanks-
-Andy

Andrew Veit
Systems Design Engineer
MTS Systems Corp
Ph: 919.677.2507
Fax: 919.677.2480
1001 Sheldon Drive 
Cary, NC 27513 


-Original Message-
From: Rich Nute [mailto:ri...@sdd.hp.com]
Sent: Thursday, January 25, 2001 1:39 PM
To: chris.maxw...@gnnettest.com
Cc: emc-p...@majordomo.ieee.org
Subject: Re: Product Marking - new twist






Hi Chris:


>   For instance, one of the messages says that the NEC gives an electrician
the
>   right to unplug an un-NRTL-marked piece of equipment.  Another message
>   states that the NRTL's mark is the proof of product safety.  

"NRTL" is a designation issued by OSHA.  

"Approved" is a designation used by the NEC.

An NRTL may or may not be "approved," depending
on the jurisdiction, i.e., the authority 
enforcing the NEC.

The authority enforcing the NEC can disconnect
any equipment that is not "approved."  The
electrician may be delegated (through licensing)
to enforce the NEC, including disconnecting 
equipment that is not "approved."

>   1. Are other certifications from other labs, such as A2LA and/or NVLAP
>   allowed as long as there is a test report?

Under the NEC, equipment must be "approved."
"Approved" is defined as acceptable to the
jurisdiction enforcing the NEC.  The jurisdiction
decides "approved" on a lab-by-lab basis, and
sometimes by standards or equipment type covered 
by that lab.

Ultimately, it boils down to a certification
mark from one of the labs accepted by the
local jurisdiction.  The test report is nothing
more than a record maintained by the certification
house for its own purposes of granting the right
to use the mark on the equipment.

Under the NEC (and OSHA), it is possible to 
install a non-certified product provided it
is tested in place.  In such a situation, the
test report may be highly useful.

(In Europe, the test report is essential, as
Europe relies on the manufacturer proving the
safety of the product.)

>   2.  Does it matter what the voltage rating of the product is?  

No.

Safety certification process almost always requires
the product to be safe (and therefore certified)
in accordance with the product's ratings, including
its input voltage rating.

Although rare, it is possible to certify a multi-
voltage product for one voltage by one lab and 
another voltage by another lab.  This is done by 
agreement between the submittor and the lab.  In
such a case, the voltage for which the certification
applies is specifically related to the certification
mark.

>   3.  For products with external AC power supplies, would the NRTL mark
need
>   to be on the supply and the product?  Or the supply only?

The external ac power supply must be "approved."

The product may or may not need to be approved.  If
the rated input voltage exceeds 30 V rms or 42.4 V
dc, then it must be approved (per the NEC).  If the
rated input voltage is less than 30 V rms or 42.4 V
dc, then the NEC does not require it to be "approved;"
it is a manufacturer's option whether to seek third-
party certification.

>   4.  Does it matter where the product is used? (home, farm, factory ...)

The NEC applies to almost every location (except 
electric utility locations).



Best regards,
Rich




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This

Re: Product Marking - new twist

[Rich Nute]

Hi Andy:


>   Is it possible that a piece of equipment with an NRTL listing can be
>   disconnected by a local electrical inspector/electrician enforcing the NEC
>   because that paticular NRTL is not "approved" in their jurisdiction?

Yes.

Please recognize:

   "NRTL" is an OSHA program governing electrical
   products used by employees in the workplace.

   Requirements for NRTL are imposed on employers,
   and enforced by OSHA inspectors.

   NRTL is determined solely by OSHA for OSHA
   purposes.

   "Approved" is an NEC requirement for equipment
   and appliances used in electrical installations.

   Requirements for "approved" electrical devices
   are imposed by local electrical inspectors 
   enforcing the electrical code.  Licensed
   electricians are expected to only install 
   "approved" electrical devices.

   "Approved" is determined by the local
   jurisdiction enforcing the code (i.e. a
   branch of the local building code 
   administration).

>   Doesn't the NRTL approval by OSHA take precedence over whether or not the
>   local authorities accept the NRTL's listing?

No.

These are separate and independent requirements.  We
cannot make a generalization that all NRTLs are also
"approved" in every jurisdiction.  Some NRTLs (e.g.,
UL, CSA, ITS) are indeed "approved" in every 
jurisdiction (because they make it their business to
be so approved).

Likewise, we cannot make a generalization that all
"approved" electrical devices are also NRTL-certified.

Determining an NRTL is easy by going to the OSHA-NRTL
web page.

Determining an "approved" product is not easy as each
jurisdiction makes its own determination.  However, 
each safety certification house knows which jurisdictions
have approved its certifications.  So, determining 
whether a product is "approved" in a particular 
jurisdiction is a simple matter of asking the 
certification house.

Having said all this... products installed after the
electrical construction is complete and signed off
by the local electrical inspector are rarely inspected.
Thus, manufacturers of such products rarely get any
feedback regarding "approval" of their products.  So,
it appears that NRTL certification also satisfies 
local "approval" whereas in fact such products are
never inspected.  

Anecdote:  Some years ago, our equipment was installed
in the finished basement of a multi-story building 
that was still under construction.  The electrical 
inspector, during his normal inspection round, returned
to the basement and saw all the various products that
had been installed (plugged in) after he had signed
off the floor.  He inspected the products, and found 
a number of them without any safety certification.
These were disconnected and red-tagged.  The basement
operations were shut down.  The customer was irate.

I hope this explains the difference between NRTL and
"approved."


Best regards,
Rich


ps:  For our colleagues not familiar with the USA...

 NRTL  =  Nationally Recognised Testing Laboratory
 OSHA  =  Occupational Safety and Health Administration
 NEC   =  National Electrical Code




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RE: Product Marking - new twist

[Veit, Andy]

Rich-
Thanks for the detailed reply to Chris's questions.  
Is it possible that a piece of equipment with an NRTL listing can be
disconnected by a local electrical inspector/electrician enforcing the NEC
because that paticular NRTL is not "approved" in their jurisdiction?

Doesn't the NRTL approval by OSHA take precedence over whether or not the
local authorities accept the NRTL's listing?

Thanks-
-Andy

Andrew Veit
Systems Design Engineer
MTS Systems Corp
Ph: 919.677.2507
Fax: 919.677.2480
1001 Sheldon Drive 
Cary, NC 27513 


-Original Message-
From: Rich Nute [mailto:ri...@sdd.hp.com]
Sent: Thursday, January 25, 2001 1:39 PM
To: chris.maxw...@gnnettest.com
Cc: emc-p...@majordomo.ieee.org
Subject: Re: Product Marking - new twist






Hi Chris:


>   For instance, one of the messages says that the NEC gives an electrician
the
>   right to unplug an un-NRTL-marked piece of equipment.  Another message
>   states that the NRTL's mark is the proof of product safety.  

"NRTL" is a designation issued by OSHA.  

"Approved" is a designation used by the NEC.

An NRTL may or may not be "approved," depending
on the jurisdiction, i.e., the authority 
enforcing the NEC.

The authority enforcing the NEC can disconnect
any equipment that is not "approved."  The
electrician may be delegated (through licensing)
to enforce the NEC, including disconnecting 
equipment that is not "approved."

>   1. Are other certifications from other labs, such as A2LA and/or NVLAP
>   allowed as long as there is a test report?

Under the NEC, equipment must be "approved."
"Approved" is defined as acceptable to the
jurisdiction enforcing the NEC.  The jurisdiction
decides "approved" on a lab-by-lab basis, and
sometimes by standards or equipment type covered 
by that lab.

Ultimately, it boils down to a certification
mark from one of the labs accepted by the
local jurisdiction.  The test report is nothing
more than a record maintained by the certification
house for its own purposes of granting the right
to use the mark on the equipment.

Under the NEC (and OSHA), it is possible to 
install a non-certified product provided it
is tested in place.  In such a situation, the
test report may be highly useful.

(In Europe, the test report is essential, as
Europe relies on the manufacturer proving the
safety of the product.)

>   2.  Does it matter what the voltage rating of the product is?  

No.

Safety certification process almost always requires
the product to be safe (and therefore certified)
in accordance with the product's ratings, including
its input voltage rating.

Although rare, it is possible to certify a multi-
voltage product for one voltage by one lab and 
another voltage by another lab.  This is done by 
agreement between the submittor and the lab.  In
such a case, the voltage for which the certification
applies is specifically related to the certification
mark.

>   3.  For products with external AC power supplies, would the NRTL mark
need
>   to be on the supply and the product?  Or the supply only?

The external ac power supply must be "approved."

The product may or may not need to be approved.  If
the rated input voltage exceeds 30 V rms or 42.4 V
dc, then it must be approved (per the NEC).  If the
rated input voltage is less than 30 V rms or 42.4 V
dc, then the NEC does not require it to be "approved;"
it is a manufacturer's option whether to seek third-
party certification.

>   4.  Does it matter where the product is used? (home, farm, factory ...)

The NEC applies to almost every location (except 
electric utility locations).



Best regards,
Rich




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RE: Product Marking

[Don House]

Thanks for your reply Greg,
This is news to me.   My experience is that UL will not accept the test
results of any other laboratory (except one of their own).  I was told they
are being sued over this because they were the only NRTL that would not
accept data from other NRTLs.  Has this changed recently?  Normally we would
not consider using UL because of the high cost and long time intervals
anyway.

Don

-Original Message-
From: Greg Nielsen [mailto:greg.niel...@setengineering.com]
Sent: Thursday, January 25, 2001 10:49 AM
To: 'Don House'
Subject: RE: Product Marking


Don,

I believe the intent of your wording is correct, but a unit does not
necessarily have to be "tested" by UL to be authorized to apply the UL Mark.
A CB or other report with a product sample can be "evaluated" and certified
by UL without UL performing any testing.  

Greg Nielsen
Compliance Engineer
Set Engineering, Inc.


-Original Message-
From: Don House [mailto:dho...@excelsus-tech.com]
Sent: Thursday, January 25, 2001 8:17 AM
To: Praveen Rao; 'Pham, Tac'; 'Courtland Thomas'; emcpost
Subject: RE: Product Marking



Perhaps you are being confused by the symbols.  The UL symbol can only be
used if your product is tested by UL not another lab.  UL1950 and CSA 22.2
are both the same requirements.  They have been "normalized" by
international agreement. 
Text can be used in place of logos if the text is in close proximity to the
logo of the LISTING laboratory.  Of course nothing can be sold in Canada
without the Canadian supplied flag labels with the certification number
imprinted.

Don

-Original Message-
From: Praveen Rao [mailto:p...@tennyson.com.au]
Sent: Wednesday, January 24, 2001 4:36 PM
To: 'Pham, Tac'; 'Courtland Thomas'; emcpost
Subject: RE: Product Marking


This is the symbol (see attached) we were advised to use by CSA for both
Canada and USA.
But no 'UL' to be mentioned anywhere.
The testing was through the CB scheme tested here in Australia.
Praveen


-Original Message-
From: Pham, Tac [mailto:tac.p...@power-one.com]
Sent: Thursday, 25 January 2001 9:00 AM
To: 'Courtland Thomas'; emcpost
Subject: RE: Product Marking



Courtland,

The NRTL (UL, CSA) would not like the idea that one marked the product with
the word UL or CSA because (their argument) it is misleading. In some cases,
TUV, ETL etc. can certify some products using UL/CSA standards.

Tac,
Power-One TSD


 -Original Message-
From:   Courtland Thomas [mailto:ctho...@patton.com] 
Sent:   Wednesday, January 24, 2001 1:05 PM
To: emcpost
Subject:Product Marking


Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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RE: Product Marking

[JRadomski]

> Of course nothing can be sold in Canada without the Canadian supplied
flag labels with the certification number imprinted.

Don,

The Canadian flag labels can be affixed only to equipment certified by
Industry Canada (different issue, not related to the original question
[NRTL, safety approvals to UL1950/CSA950, etc.]).

Best Regards,

John Radomski
Product Compliance Engineer
Clare


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RE: Product Marking

[Don House]

No arguments here Ron.
Best regards,
Don

-Original Message-
From: Ron Pickard [mailto:rpick...@hypercom.com]
Sent: Thursday, January 25, 2001 10:31 AM
To: Don House
Cc: emc-p...@ieee.org
Subject: RE: Product Marking



Hi Don,

>The requirement for most customers, especially telecommunications
providers,
>is that the product be LISTED or RECOGNIZED to comply with the safety
>standards of concern.  The most important being UL1950 and NEBS.  To be
>listed and participate in continuing compliance (required) you must use the
>logo of the certification laboratory, such as ETL, MET, UL, etc.  The
>listing number is also required in close proximity to the logo. (Since this
>is a legal requirement with the lab, it is a "badge of quality" on the
>product, which should be appreciated by your marketing department!)

All true. However, as to the listing number, different NRTLs
require/recommend different
designations. UL, for instance, requires the word "LISTED", an assigned
control number along with a
product identity marking (e.g., ITE, NWGQ, etc.). I'm sure that the other
NRTLs have similar marking
requirements other than just the use of their mark. And, as for quality,
continued use of a NRTL
mark means only that the product is continuing to be built according to how
it was written up into
the report, nothing more. I have seen many many instances where reports have
been simply wrong,
incorrect, and in one case a while back, negligent (I will offer no further
information about any of
these instances).

>I am told that there are changes "afoot" to allow manufacturers to self
>certify to these requirements, however my experience shows that most of our
>customers will not accept self certification.

IMHO, I don't see self certification in the US happening any time soon, if
at all. Even if it did,
there would be at least 2 federal regulators (OSHA & NEC) to change their
reg's, and not to mention
the thousands of municipal authorities. Of course, to align with the EU-US
MRA, that might actually
happen, but not in the near future or in my lifetime. But, I could be wrong.

Best regards,

Ron Pickard
rpick...@hypercom.com


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RE: Product Marking

[PGodfrey]

Just a 'small' correction here.

As I'm sure most who have been through any of the UL programs will agree, it
took some work to get there!!. Therefore, I'd like to point out that KTL is
a UL CAPS Engineer laboratory and therefore manufacturers who have their
products tested/investigated with us under this scheme will get UL
authorization to apply the UL Listed or Recognized Mark. EXACTLY the same as
they would by going directly to UL, except of course we believe we offer a
faster turnaround time than UL themselves. :>).

Phillip Godfrey
Manager, Product Safety
KTL Dallas, Inc
802 N. Kealy Ave
Lewisville. TX75057-3136

email: pgodf...@icomply.com
Tel: (972) 436-9600
Fax: (972) 436-2667 

-Original Message-
From: Don House [mailto:dho...@excelsus-tech.com]
Sent: Thursday, January 25, 2001 10:17 AM
To: Praveen Rao; 'Pham, Tac'; 'Courtland Thomas'; emcpost
Subject: RE: Product Marking



Perhaps you are being confused by the symbols.  The UL symbol can only be
used if your product is tested by UL not another lab.  UL1950 and CSA 22.2
are both the same requirements.  They have been "normalized" by
international agreement. 
Text can be used in place of logos if the text is in close proximity to the
logo of the LISTING laboratory.  Of course nothing can be sold in Canada
without the Canadian supplied flag labels with the certification number
imprinted.

Don

-Original Message-
From: Praveen Rao [mailto:p...@tennyson.com.au]
Sent: Wednesday, January 24, 2001 4:36 PM
To: 'Pham, Tac'; 'Courtland Thomas'; emcpost
Subject: RE: Product Marking


This is the symbol (see attached) we were advised to use by CSA for both
Canada and USA.
But no 'UL' to be mentioned anywhere.
The testing was through the CB scheme tested here in Australia.
Praveen


-Original Message-
From: Pham, Tac [mailto:tac.p...@power-one.com]
Sent: Thursday, 25 January 2001 9:00 AM
To: 'Courtland Thomas'; emcpost
Subject: RE: Product Marking



Courtland,

The NRTL (UL, CSA) would not like the idea that one marked the product with
the word UL or CSA because (their argument) it is misleading. In some cases,
TUV, ETL etc. can certify some products using UL/CSA standards.

Tac,
Power-One TSD


 -Original Message-
From:   Courtland Thomas [mailto:ctho...@patton.com] 
Sent:   Wednesday, January 24, 2001 1:05 PM
To: emcpost
Subject:Product Marking


Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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Re: Product Marking - new twist

[Rich Nute]

Hi Chris:


>   For instance, one of the messages says that the NEC gives an electrician the
>   right to unplug an un-NRTL-marked piece of equipment.  Another message
>   states that the NRTL's mark is the proof of product safety.  

"NRTL" is a designation issued by OSHA.  

"Approved" is a designation used by the NEC.

An NRTL may or may not be "approved," depending
on the jurisdiction, i.e., the authority 
enforcing the NEC.

The authority enforcing the NEC can disconnect
any equipment that is not "approved."  The
electrician may be delegated (through licensing)
to enforce the NEC, including disconnecting 
equipment that is not "approved."

>   1. Are other certifications from other labs, such as A2LA and/or NVLAP
>   allowed as long as there is a test report?

Under the NEC, equipment must be "approved."
"Approved" is defined as acceptable to the
jurisdiction enforcing the NEC.  The jurisdiction
decides "approved" on a lab-by-lab basis, and
sometimes by standards or equipment type covered 
by that lab.

Ultimately, it boils down to a certification
mark from one of the labs accepted by the
local jurisdiction.  The test report is nothing
more than a record maintained by the certification
house for its own purposes of granting the right
to use the mark on the equipment.

Under the NEC (and OSHA), it is possible to 
install a non-certified product provided it
is tested in place.  In such a situation, the
test report may be highly useful.

(In Europe, the test report is essential, as
Europe relies on the manufacturer proving the
safety of the product.)

>   2.  Does it matter what the voltage rating of the product is?  

No.

Safety certification process almost always requires
the product to be safe (and therefore certified)
in accordance with the product's ratings, including
its input voltage rating.

Although rare, it is possible to certify a multi-
voltage product for one voltage by one lab and 
another voltage by another lab.  This is done by 
agreement between the submittor and the lab.  In
such a case, the voltage for which the certification
applies is specifically related to the certification
mark.

>   3.  For products with external AC power supplies, would the NRTL mark need
>   to be on the supply and the product?  Or the supply only?

The external ac power supply must be "approved."

The product may or may not need to be approved.  If
the rated input voltage exceeds 30 V rms or 42.4 V
dc, then it must be approved (per the NEC).  If the
rated input voltage is less than 30 V rms or 42.4 V
dc, then the NEC does not require it to be "approved;"
it is a manufacturer's option whether to seek third-
party certification.

>   4.  Does it matter where the product is used? (home, farm, factory ...)

The NEC applies to almost every location (except 
electric utility locations).



Best regards,
Rich




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RE: Product Marking

[Ron Pickard]

Hi Don,

>The requirement for most customers, especially telecommunications providers,
>is that the product be LISTED or RECOGNIZED to comply with the safety
>standards of concern.  The most important being UL1950 and NEBS.  To be
>listed and participate in continuing compliance (required) you must use the
>logo of the certification laboratory, such as ETL, MET, UL, etc.  The
>listing number is also required in close proximity to the logo. (Since this
>is a legal requirement with the lab, it is a "badge of quality" on the
>product, which should be appreciated by your marketing department!)

All true. However, as to the listing number, different NRTLs require/recommend 
different
designations. UL, for instance, requires the word "LISTED", an assigned control 
number along with a
product identity marking (e.g., ITE, NWGQ, etc.). I'm sure that the other NRTLs 
have similar marking
requirements other than just the use of their mark. And, as for quality, 
continued use of a NRTL
mark means only that the product is continuing to be built according to how it 
was written up into
the report, nothing more. I have seen many many instances where reports have 
been simply wrong,
incorrect, and in one case a while back, negligent (I will offer no further 
information about any of
these instances).

>I am told that there are changes "afoot" to allow manufacturers to self
>certify to these requirements, however my experience shows that most of our
>customers will not accept self certification.

IMHO, I don't see self certification in the US happening any time soon, if at 
all. Even if it did,
there would be at least 2 federal regulators (OSHA & NEC) to change their 
reg's, and not to mention
the thousands of municipal authorities. Of course, to align with the EU-US MRA, 
that might actually
happen, but not in the near future or in my lifetime. But, I could be wrong.

Best regards,

Ron Pickard
rpick...@hypercom.com



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RE: Product Marking - new twist

[Don House]

"The customer is not always right, but they are always the customer."

Most of the telecommunications providers require NRTL lab certification
because they are not familiar with the other laboratory certification
agencies.  This has to do with risk management. They are afraid of "Garage
Labs." Most carriers are self insured.  Having a product certified and
listed by a NRTL is a "comfort level" to the companies marketing and
management.

Don (Ameritech NEBS representative - Retired)
Don Robert House, SMTS
Product Certification & Regulatory Compliance
Excelsus Technologies, Inc.
2875 Loker Avenue East
Carlsbad, CA 92008-6626  USA
(760) 918-2552 Office/Lab
(760) 476-1519 FAX
URL: http://www.excelsus-tech.com




-Original Message-
From: Chris Maxwell [mailto:chris.maxw...@gnnettest.com]
Sent: Thursday, January 25, 2001 6:03 AM
To: emc-p...@majordomo.ieee.org
Subject: RE: Product Marking - new twist



As I read this thread, a couple of the postings stick out in my mind.

For instance, one of the messages says that the NEC gives an electrician the
right to unplug an un-NRTL-marked piece of equipment.  Another message
states that the NRTL's mark is the proof of product safety.  

Courtland's original question asked about products that were not NRTL
marked.  I want to follow that a little more.  

His original posting considers a product that is safety tested by a third
party lab.  The product has passed the third party safety certification.
However the lab is not an NRTL.  So the product just says "Conforms to UL
1950" or some similar verbage.

1. Are other certifications from other labs, such as A2LA and/or NVLAP
allowed as long as there is a test report?
2.  Does it matter what the voltage rating of the product is?  
3.  For products with external AC power supplies, would the NRTL mark need
to be on the supply and the product?  Or the supply only?
4.  Does it matter where the product is used? (home, farm, factory ...)

If the answer to the above questions are "No", "No", "Yes" and "No" then,
theoretically, every piece of electronics in use in the United States would
have been NRTL tested and marked.  The tone of the answers in this thread
sounds like this is true.  But I believe it isn't.  Am I whacked here?

Chris Maxwell
Design Engineer
GN Nettest
6 Rhoads Drive, Building 4
Utica,NY 13502
email: chris.maxw...@gnnettest.com
phone:  315-266-5128
fax: 315-797-8024




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RE: Product Marking

[Don House]

Perhaps you are being confused by the symbols.  The UL symbol can only be
used if your product is tested by UL not another lab.  UL1950 and CSA 22.2
are both the same requirements.  They have been "normalized" by
international agreement. 
Text can be used in place of logos if the text is in close proximity to the
logo of the LISTING laboratory.  Of course nothing can be sold in Canada
without the Canadian supplied flag labels with the certification number
imprinted.

Don

-Original Message-
From: Praveen Rao [mailto:p...@tennyson.com.au]
Sent: Wednesday, January 24, 2001 4:36 PM
To: 'Pham, Tac'; 'Courtland Thomas'; emcpost
Subject: RE: Product Marking


This is the symbol (see attached) we were advised to use by CSA for both
Canada and USA.
But no 'UL' to be mentioned anywhere.
The testing was through the CB scheme tested here in Australia.
Praveen


-Original Message-
From: Pham, Tac [mailto:tac.p...@power-one.com]
Sent: Thursday, 25 January 2001 9:00 AM
To: 'Courtland Thomas'; emcpost
Subject: RE: Product Marking



Courtland,

The NRTL (UL, CSA) would not like the idea that one marked the product with
the word UL or CSA because (their argument) it is misleading. In some cases,
TUV, ETL etc. can certify some products using UL/CSA standards.

Tac,
Power-One TSD


 -Original Message-
From:   Courtland Thomas [mailto:ctho...@patton.com] 
Sent:   Wednesday, January 24, 2001 1:05 PM
To: emcpost
Subject:Product Marking


Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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RE: Product Marking

[Don House]

Hi Ron,
The requirement for most customers, especially telecommunications providers,
is that the product be LISTED or RECOGNIZED to comply with the safety
standards of concern.  The most important being UL1950 and NEBS.  To be
listed and participate in continuing compliance (required) you must use the
logo of the certification laboratory, such as ETL, MET, UL, etc.  The
listing number is also required in close proximity to the logo. (Since this
is a legal requirement with the lab, it is a "badge of quality" on the
product, which should be appreciated by your marketing department!) 

I am told that there are changes "afoot" to allow manufacturers to self
certify to these requirements, however my experience shows that most of our
customers will not accept self certification.

Regards,
Don

Don Robert House, SMTS
Product Certification & Regulatory Compliance
Excelsus Technologies, Inc.
2875 Loker Avenue East
Carlsbad, CA 92008-6626  USA
(760) 918-2552 Office/Lab
(760) 476-1519 FAX
URL: http://www.excelsus-tech.com


-Original Message-
From: Ron Pickard [mailto:rpick...@hypercom.com]
Sent: Wednesday, January 24, 2001 11:52 AM
To: Courtland Thomas
Cc: emc-p...@majordomo.ieee.org; owner-emc-p...@ieee.org
Subject: Re: Product Marking




Hi Courtland,

You asked:

>I have a question concerning labeling a product. If we go to a NRTL and get
>Safety testing performed, we typically put the Safety logo (UL for example)
>on the product label. Our marketing people have a problem with having
>different logo's. They would like to standarize on a single logo such as
UL.
>This kind of thinking hinders the process of getting the best price
>possible. I would like to get the testing performed at a lab which doesn't
>use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
>1950" on the label and forget the logo? Or is there a requirement to have a
>logo?

Exactly what will "Conforms to UL1950 and CSA 1950" mean to your customers,
given that they are
unfamiliar with your products and knowers of the law? Personally, I would
not believe it since a
NRTL mark is not present (not legal in the workplace environment) and
especially since I believe you
were referring CSA C22.2 No. 950-95.

I'm curious, do you switch NRTLs because one is cheaper (um, less expensive)
than another? In my
experience, I like to stick with a single NRTL. They get to know me, I get
to know them, and we both
get a good working relationship and respect out of the deal. This is worth
far more than a few bucks
saved by switching NRTLs.

Here in the US, such practice is mandated by US law in the Code of Federal
Regulations (CFR),
specifically 29 CFR Part 2910 Subpart S. These federal regulations come from
OSHA and the US Dept.
of Labor and can be viewed on-line at:

http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910_SUBPART_S.html

BTW, 1910.399(a) gives 3 routes to compliance:
1. Listing by a NRTL,
2. Inspection by a local municipal inspector of every installation*, or
3. For custom-made equipment, test data must be made available for
inspection by the Asst. Secretary
of Labor.

* will likely fall back to a NRTL anyway due to the inspector's lack of
technical expertise.

IMHO, I do believe that choice #1 would be the path of least resistance.
And, why would anyone
willingly invite the government into their organization? (rhetorical
question here)

Also, the US National Electric Code (NEC) requires NRTL listing of products.

I am very sure that Canada has a similar system in place requiring product
certification.

>Thanks,

No problem. I hope this helps.

Best regards,

Ron Pickard
rpick...@hypercom.com



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RE: Product Marking

[Joe Finlayson]

Vitaly,

I believe you misinterpreted my statement.  I was not implying that
you test to a standard and then arbitrarily place an NRTL mark on your
product.  The original question was, "If we go to a NRTL and get Safety
testing performed ..would it be possible to just put "Conforms to
UL 1950 and CAN/CSA 1950" on the label and forget the logo? Or is there a
requirement to have a logo?"  My point was that if you have the product
tested by NRTL X and do not affix the logo of NRTL X, your product is not
considered to be NRTL Listed as it will not audited at the factory.  Does it
comply with the standard? - yes.  Can you print on a label that it complies?
- yes.  Can you tell your customers that your are NRTL Listed, no.  This, in
addition to the other valuable input, validates the fact (for me, anyway)
that the NRTL mark should be affixed to the product, especially since you
just went through all that work!!  My apologies if I misinterpreted the
intent of the original question.  

Thx,


Joe


Joe Finlayson
Manager, Compliance Engineering
Telica, Inc.
734 Forest Street, Bldg. G, Suite 100
Marlboro, MA 01752
Tel:(508) 480-0909 x212
Fax:(508) 480-0922
Email:  jfinlay...@telica.com


-Original Message-
From: Gorodetsky, Vitaly [mailto:vgorodet...@canoga.com]
Sent: Wednesday, January 24, 2001 8:26 PM
To: 'Joe Finlayson'; 'Courtland Thomas'; emcpost
Subject: RE: Product Marking



Joe -

It is the other way around: you can mark your product only if it's NRTL
Listed.  Manufacturers are supposed to obtain Authorization to mark from an
NRTL Lab which performed safety evaluation.   There's no Mutual Agreement
allowing arbitrary mark alternation: you can't use UL mark if, let's say,
you obtained Authorization from ITS (all marks were born equal but some
marks are more equal than others).  Product Listing results in Follow up
Service, it is required for continuous use of the mark. 

Vitaly  Gorodetsky

The suitability of this information for making decision is solely with the
reader


-Original Message-
From:   Joe Finlayson [SMTP:jfinlay...@telica.com]
Sent:   Wednesday, January 24, 2001 12:45 PM
To: 'Courtland Thomas'; emcpost
Subject:RE: Product Marking



My understanding of the NRTL marking is that if you don't
mark it,
it is not considered Listed.  It doesn't matter if it has been
tested or
not.  I believe the issue is that if the NRTL is performing a
factory audit,
they will only review marked product.  Therefore, if you do not mark
it, you
can not claim NRTL Listing.

-Original Message-
From: Courtland Thomas [mailto:ctho...@patton.com]
Sent: Wednesday, January 24, 2001 4:05 PM
To: emcpost
Subject: Product Marking



Hello group,

I have a question concerning labeling a product. If we go to a NRTL
and get
Safety testing performed, we typically put the Safety logo (UL for
example)
on the product label. Our marketing people have a problem with
having
different logo's. They would like to standarize on a single logo
such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which
doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and
CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to
have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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RE: Product Marking

[rfm]

None of the MARKS are listed on the web site. Only the company name(s) are
shown, with links to their scopes of accreditation.



-Original Message-
From: geor...@lexmark.com [mailto:geor...@lexmark.com]
Sent: Wednesday, January 24, 2001 4:49 PM
To: bolin...@dscltd.com
Cc: emc-p...@majordomo.ieee.org
Subject: RE: Product Marking



I see no cETL listed at http://www.scc.ca/certific/colist.html
I did see ITS listed.




bolintic%dscltd@interlock.lexmark.com on 01/24/2001 04:52:35 PM

To:   "George_Alspaugh/Lex/Lexmark.LEXMARK"@sweeper.lex.lexmark.com,
  emc-pstc%majordomo.ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  RE: Product Marking



Dear George,

Just a small clarification: in regard to item 5, "one of the following..",
are mixed-up TESTING AGENCIES(NRTLs) with MARKS. In Canada, are acceptable
the following MARKS:

CSA, cETL (issued by ITS - Intertek Testing Services, formerly Inchcape
T.S.), cUL and ULC. (for CERTIFICATION purposes.)

Respectfully yours,
Constantin

Constantin Bolintineanu P.Eng.
DIGITAL SECURITY CONTROLS LTD.
3301 LANGSTAFF Road, L4K 4L2
CONCORD, ONTARIO, CANADA
e-mail: bolin...@dscltd.com
telephone: 905 760 3000 ext 2568
www.dscgrp.com


-Original Message-
From: geor...@lexmark.com [mailto:geor...@lexmark.com]
Sent: Wednesday, January 24, 2001 3:49 PM
To: emc-p...@majordomo.ieee.org
Subject: Product Marking



Courtland,

You raise a very interesting question, prompted by the usual "Dilbert"
marketing thinking.  Here are some comments, in no particular order,
nor do I draw a conclusion:

1.  As you know, OSHA has approved multiple NRTLs to issue certifications
to UL 1950 and other standards.  We were once acquiring a product which
used the CSA/NRTL mark, i.e. perfectly acceptable.  Marketing thought
the world would come to an end, as they would not be able to respond to
bids (particularly gov't bids) specifying "UL" approval. I personally
assured marketing that if a U.S. gov't bid held to the "UL" approval
requirement they would be at odds with OSHA, i.e. the Code of Federal
Regulations. We wrote a statement for them to the effect that the
product was tested as conforming to UL 1950 etc. without specifying
the agency.  They finally accepted our position, but we still get the
UL mark on most products.

2.  Similarly, Canada will accept a CSA or c-UL mark. However, it seems
that the Canadian gov't prefers the CSA mark when bidding for their use.
Hence, we normally require the CSA mark for models that would most likely
be candidates for gov't office use.

3.  It is my observation and position that customers buying off-the-
shelf or over the internet have no clue what a power rating label is nor
do they look at it after purchase.  Therefore, for the average consumer,
the particular marks or absence thereof matters little.

4.  Large customers of business products do often want know the details
of marks and approvals, but do not necessarily understand that UL =
CSA/NRTL = ITS = MET etc. if tested to the same UL/CSA standards.

5.  If you do NOT market to Canadian gov't, I suggest using any one of
the following, acceptable for other customers in both countries, assuming
your marketing can live with any of these:

-  c-UL-us
-  MET
-  ITS
-  TUVR


George Alspaugh
-- Forwarded by George Alspaugh/Lex/Lexmark on
01/24/2001
03:35 PM ---

cthomas%patton@interlock.lexmark.com on 01/24/2001 04:05:09 PM

Please respond to cthomas%patton@interlock.lexmark.com

To:   emc-pstc%majordomo.ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  Product Marking




Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics



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---
This m

RE: Product Marking - new twist

[Chris Maxwell]

As I read this thread, a couple of the postings stick out in my mind.

For instance, one of the messages says that the NEC gives an electrician the
right to unplug an un-NRTL-marked piece of equipment.  Another message
states that the NRTL's mark is the proof of product safety.  

Courtland's original question asked about products that were not NRTL
marked.  I want to follow that a little more.  

His original posting considers a product that is safety tested by a third
party lab.  The product has passed the third party safety certification.
However the lab is not an NRTL.  So the product just says "Conforms to UL
1950" or some similar verbage.

1. Are other certifications from other labs, such as A2LA and/or NVLAP
allowed as long as there is a test report?
2.  Does it matter what the voltage rating of the product is?  
3.  For products with external AC power supplies, would the NRTL mark need
to be on the supply and the product?  Or the supply only?
4.  Does it matter where the product is used? (home, farm, factory ...)

If the answer to the above questions are "No", "No", "Yes" and "No" then,
theoretically, every piece of electronics in use in the United States would
have been NRTL tested and marked.  The tone of the answers in this thread
sounds like this is true.  But I believe it isn't.  Am I whacked here?

Chris Maxwell
Design Engineer
GN Nettest
6 Rhoads Drive, Building 4
Utica,NY 13502
email: chris.maxw...@gnnettest.com
phone:  315-266-5128
fax: 315-797-8024




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RE: Product Marking

[Andrews, Kurt]

Praveen,

The symbol you attached is the CSA Listing mark showing approval for use in
the U.S. and Canada. It is the equivalent of the UL Listing mark for the
U.S. and Canada. CSA has been approved as a NRTL by OSHA so a product with
this mark will satisfy the requirements of both OSHA and the NEC along with
the regulatory authorities in Canada. It indicates evaluation to both the
U.S. and Canadian standards. Some U.S. consumers may not know that this mark
is essentially the same as the UL mark, which can be a marketing issue.
However consumers in Canada would be more familiar with this mark. The
reason you see so many different marks on some products is a marketing
issue. Consumers are typically more familiar with marks from their own
countries. If you look at the back of any newer computer monitor you can see
what I mean. I have seen monitors with as many as 7 or 8 different marks,
most of which indicate compliance to the same standards.

Kurt Andrews
Compliance Engineer

Tracewell Systems, Inc.
567 Enterprise Drive
Westerville, Ohio 43081
voice:  614.846.6175
toll free:  800.848.4525
fax: 614.846.7791

http://www.tracewellsystems.com/ <http://www.tracewellsystems.com/> 


-Original Message-
From:   Praveen Rao [SMTP:p...@tennyson.com.au]
Sent:   Wednesday, January 24, 2001 7:36 PM
To: 'Pham, Tac'; 'Courtland Thomas'; emcpost
    Subject:    RE: Product Marking

This is the symbol (see attached) we were advised to use by CSA for
both
Canada and USA.
But no 'UL' to be mentioned anywhere.
The testing was through the CB scheme tested here in Australia.
Praveen


-Original Message-
From: Pham, Tac [mailto:tac.p...@power-one.com]
Sent: Thursday, 25 January 2001 9:00 AM
To: 'Courtland Thomas'; emcpost
Subject: RE: Product Marking



Courtland,

The NRTL (UL, CSA) would not like the idea that one marked the
product with
the word UL or CSA because (their argument) it is misleading. In
some cases,
TUV, ETL etc. can certify some products using UL/CSA standards.

Tac,
Power-One TSD


 -Original Message-
From:   Courtland Thomas [mailto:ctho...@patton.com] 
Sent:   Wednesday, January 24, 2001 1:05 PM
To: emcpost
Subject:Product Marking


Hello group,

I have a question concerning labeling a product. If we go to a NRTL
and get
Safety testing performed, we typically put the Safety logo (UL for
example)
on the product label. Our marketing people have a problem with
having
different logo's. They would like to standarize on a single logo
such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which
doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and
CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to
have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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 << File: CSA NRTL.doc >> 

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RE: Product Marking

[Gorodetsky, Vitaly]

Joe -

It is the other way around: you can mark your product only if it's NRTL
Listed.  Manufacturers are supposed to obtain Authorization to mark from an
NRTL Lab which performed safety evaluation.   There's no Mutual Agreement
allowing arbitrary mark alternation: you can't use UL mark if, let's say,
you obtained Authorization from ITS (all marks were born equal but some
marks are more equal than others).  Product Listing results in Follow up
Service, it is required for continuous use of the mark. 

Vitaly  Gorodetsky

The suitability of this information for making decision is solely with the
reader


-Original Message-
From:   Joe Finlayson [SMTP:jfinlay...@telica.com]
Sent:   Wednesday, January 24, 2001 12:45 PM
To: 'Courtland Thomas'; emcpost
    Subject:RE: Product Marking



My understanding of the NRTL marking is that if you don't
mark it,
it is not considered Listed.  It doesn't matter if it has been
tested or
not.  I believe the issue is that if the NRTL is performing a
factory audit,
they will only review marked product.  Therefore, if you do not mark
it, you
can not claim NRTL Listing.

-Original Message-
From: Courtland Thomas [mailto:ctho...@patton.com]
Sent: Wednesday, January 24, 2001 4:05 PM
To: emcpost
Subject: Product Marking



Hello group,

I have a question concerning labeling a product. If we go to a NRTL
and get
Safety testing performed, we typically put the Safety logo (UL for
example)
on the product label. Our marketing people have a problem with
having
different logo's. They would like to standarize on a single logo
such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which
doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and
CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to
have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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RE: Product Marking

[Praveen Rao]

This is the symbol (see attached) we were advised to use by CSA for both
Canada and USA.
But no 'UL' to be mentioned anywhere.
The testing was through the CB scheme tested here in Australia.
Praveen


-Original Message-
From: Pham, Tac [mailto:tac.p...@power-one.com]
Sent: Thursday, 25 January 2001 9:00 AM
To: 'Courtland Thomas'; emcpost
Subject: RE: Product Marking



Courtland,

The NRTL (UL, CSA) would not like the idea that one marked the product with
the word UL or CSA because (their argument) it is misleading. In some cases,
TUV, ETL etc. can certify some products using UL/CSA standards.

Tac,
Power-One TSD


 -Original Message-
From:   Courtland Thomas [mailto:ctho...@patton.com] 
Sent:   Wednesday, January 24, 2001 1:05 PM
To: emcpost
Subject:Product Marking


Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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CSA NRTL.doc
Description: MS-Word document

Re: Product Marking

[Ron Pickard]

Hi Courtland,

You asked:

>I have a question concerning labeling a product. If we go to a NRTL and get
>Safety testing performed, we typically put the Safety logo (UL for example)
>on the product label. Our marketing people have a problem with having
>different logo's. They would like to standarize on a single logo such as UL.
>This kind of thinking hinders the process of getting the best price
>possible. I would like to get the testing performed at a lab which doesn't
>use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
>1950" on the label and forget the logo? Or is there a requirement to have a
>logo?

Exactly what will "Conforms to UL1950 and CSA 1950" mean to your customers, 
given that they are
unfamiliar with your products and knowers of the law? Personally, I would not 
believe it since a
NRTL mark is not present (not legal in the workplace environment) and 
especially since I believe you
were referring CSA C22.2 No. 950-95.

I'm curious, do you switch NRTLs because one is cheaper (um, less expensive) 
than another? In my
experience, I like to stick with a single NRTL. They get to know me, I get to 
know them, and we both
get a good working relationship and respect out of the deal. This is worth far 
more than a few bucks
saved by switching NRTLs.

Here in the US, such practice is mandated by US law in the Code of Federal 
Regulations (CFR),
specifically 29 CFR Part 2910 Subpart S. These federal regulations come from 
OSHA and the US Dept.
of Labor and can be viewed on-line at:

http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910_SUBPART_S.html

BTW, 1910.399(a) gives 3 routes to compliance:
1. Listing by a NRTL,
2. Inspection by a local municipal inspector of every installation*, or
3. For custom-made equipment, test data must be made available for inspection 
by the Asst. Secretary
of Labor.

* will likely fall back to a NRTL anyway due to the inspector's lack of 
technical expertise.

IMHO, I do believe that choice #1 would be the path of least resistance. And, 
why would anyone
willingly invite the government into their organization? (rhetorical question 
here)

Also, the US National Electric Code (NEC) requires NRTL listing of products.

I am very sure that Canada has a similar system in place requiring product 
certification.

>Thanks,

No problem. I hope this helps.

Best regards,

Ron Pickard
rpick...@hypercom.com



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RE: Product Marking

Consider the cost of educating the customer.  For a low-priced commodity
product a recognizable NRTL logo is preferable.  An expensive product with
considerable pre-sales contact can use a legal but rarer logo because there
is time to explain the approval.
 
Some NRTL's logos include specification numbers beside their mark (e.g.
'UL1950', 'CSA 22.2#950').  Other NRTL's allow some latitude (code letters
or specification #).
 
Marketing should be made aware that certain major cities require NRTL marks
on product placed in offices and large buildings.  A CB report or self
declaration is insufficient.  The logo implies the manufacturing line is
under the NRTL's surveillance.
 
David
 

-Original Message-
From: John Juhasz [mailto:jjuh...@fiberoptions.com]
Sent: Wednesday, January 24, 2001 2:35 PM
To: 'Courtland Thomas'; emcpost
Subject: RE: Product Marking



Courtland, 

There is nothing in UL1950 that says you MUST have an NRTL logo . . . 
there are requirements for ratings/safety markings, but not a logo. 

NRTLs typically have specifications on their logos, and how they must
appear/be 
used. I don't recall seeing that you MUST apply the mark . . . 

Simply put, the NEC dictates (I don't have the exact location handy) that an
electrical/electronic 
product must be evaluated by an NRTL against the standard that is applicable

to that product. Once you have permission to apply a mark from an NRTL, you 
demonstrate the 'listing' by application of the logo. Electricians
(competent ones) 
look for a logo and act accordingly. If they don't see one they may not 
wire it up, or they can unplug it (they have that right through the NEC). 

On another note, using one NRTL over another does have it's advantages
(evaluation 
cost aside). Some NRTL logos are more readily recognizable than others by
consumers. 
In many cases that I've directly experienced, market pressure forced my to
use 
one NRTL logo over another. It depends on your customer base. 
If your customers are regulatory savy, and understand the NRTL program, it
doesn't 
matter who you use . . . 
Unfortunately, the average person does not know about any other logo other 
than one particular prominent one. That makes it difficult . . . 

It is wise to evaluate your customer base from this respect. . . . 

The opinions expressed here are solely my own, and do not necessarily
reflect those of 
my employer . . . 

John Juhasz 
Fiber Options 
Bohemia, NY 


-Original Message- 
From: Courtland Thomas [ mailto:ctho...@patton.com
<mailto:ctho...@patton.com> ] 
Sent: Wednesday, January 24, 2001 4:05 PM 
To: emcpost 
Subject: Product Marking 



Hello group, 

I have a question concerning labeling a product. If we go to a NRTL and get 
Safety testing performed, we typically put the Safety logo (UL for example) 
on the product label. Our marketing people have a problem with having 
different logo's. They would like to standarize on a single logo such as UL.

This kind of thinking hinders the process of getting the best price 
possible. I would like to get the testing performed at a lab which doesn't 
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA 
1950" on the label and forget the logo? Or is there a requirement to have a 
logo? 

Thanks, 

Courtland Thomas 
Patton Electronics 


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RE: Product Marking

[Mel Pedersen]

Joe:

I believe you are correct.

Check the following URL
http://www.osha-slc.gov/dts/otpca/nrtl/nrtlmrk.html, and you will find the
following:

"...OSHA accepts only those products that contain the NRTL's mark and that
the NRTL has certified within its scope of recognition, which includes the
test standards and testing sites that OSHA has recognized for the NRTL"

Of course, OSHA only has jurisdiction over the workplace, but my
understanding the the requirement that NRTL listed products be marked is
written into the NEC and Local codes as well.  I can't site chapter and
verse, but I believe you are correct Joe.  Also, we know that many consumer
electronic devices are used within the workplace, and I believe OSHA
inspectors look for NRTL labels on equipment used in the workplace.


Regards All, 

- Mel

-Original Message-
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, January 24, 2001 2:45 PM
To: 'Courtland Thomas'; emcpost
Subject: RE: Product Marking




My understanding of the NRTL marking is that if you don't mark it,
it is not considered Listed.  It doesn't matter if it has been tested or
not.  I believe the issue is that if the NRTL is performing a factory audit,
they will only review marked product.  Therefore, if you do not mark it, you
can not claim NRTL Listing.

-Original Message-
From: Courtland Thomas [mailto:ctho...@patton.com]
Sent: Wednesday, January 24, 2001 4:05 PM
To: emcpost
Subject: Product Marking



Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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RE: Product Marking

[Pham, Tac]

Courtland,

The NRTL (UL, CSA) would not like the idea that one marked the product with
the word UL or CSA because (their argument) it is misleading. In some cases,
TUV, ETL etc. can certify some products using UL/CSA standards.

Tac,
Power-One TSD


 -Original Message-
From:   Courtland Thomas [mailto:ctho...@patton.com] 
Sent:   Wednesday, January 24, 2001 1:05 PM
To: emcpost
Subject:Product Marking


Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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RE: Product Marking

[georgea]

I see no cETL listed at http://www.scc.ca/certific/colist.html
I did see ITS listed.




bolintic%dscltd@interlock.lexmark.com on 01/24/2001 04:52:35 PM

To:   "George_Alspaugh/Lex/Lexmark.LEXMARK"@sweeper.lex.lexmark.com,
  emc-pstc%majordomo.ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  RE: Product Marking



Dear George,

Just a small clarification: in regard to item 5, "one of the following..",
are mixed-up TESTING AGENCIES(NRTLs) with MARKS. In Canada, are acceptable
the following MARKS:

CSA, cETL (issued by ITS - Intertek Testing Services, formerly Inchcape
T.S.), cUL and ULC. (for CERTIFICATION purposes.)

Respectfully yours,
Constantin

Constantin Bolintineanu P.Eng.
DIGITAL SECURITY CONTROLS LTD.
3301 LANGSTAFF Road, L4K 4L2
CONCORD, ONTARIO, CANADA
e-mail: bolin...@dscltd.com
telephone: 905 760 3000 ext 2568
www.dscgrp.com


-Original Message-
From: geor...@lexmark.com [mailto:geor...@lexmark.com]
Sent: Wednesday, January 24, 2001 3:49 PM
To: emc-p...@majordomo.ieee.org
Subject: Product Marking



Courtland,

You raise a very interesting question, prompted by the usual "Dilbert"
marketing thinking.  Here are some comments, in no particular order,
nor do I draw a conclusion:

1.  As you know, OSHA has approved multiple NRTLs to issue certifications
to UL 1950 and other standards.  We were once acquiring a product which
used the CSA/NRTL mark, i.e. perfectly acceptable.  Marketing thought
the world would come to an end, as they would not be able to respond to
bids (particularly gov't bids) specifying "UL" approval. I personally
assured marketing that if a U.S. gov't bid held to the "UL" approval
requirement they would be at odds with OSHA, i.e. the Code of Federal
Regulations. We wrote a statement for them to the effect that the
product was tested as conforming to UL 1950 etc. without specifying
the agency.  They finally accepted our position, but we still get the
UL mark on most products.

2.  Similarly, Canada will accept a CSA or c-UL mark. However, it seems
that the Canadian gov't prefers the CSA mark when bidding for their use.
Hence, we normally require the CSA mark for models that would most likely
be candidates for gov't office use.

3.  It is my observation and position that customers buying off-the-
shelf or over the internet have no clue what a power rating label is nor
do they look at it after purchase.  Therefore, for the average consumer,
the particular marks or absence thereof matters little.

4.  Large customers of business products do often want know the details
of marks and approvals, but do not necessarily understand that UL =
CSA/NRTL = ITS = MET etc. if tested to the same UL/CSA standards.

5.  If you do NOT market to Canadian gov't, I suggest using any one of
the following, acceptable for other customers in both countries, assuming
your marketing can live with any of these:

-  c-UL-us
-  MET
-  ITS
-  TUVR


George Alspaugh
-- Forwarded by George Alspaugh/Lex/Lexmark on
01/24/2001
03:35 PM ---

cthomas%patton@interlock.lexmark.com on 01/24/2001 04:05:09 PM

Please respond to cthomas%patton@interlock.lexmark.com

To:   emc-pstc%majordomo.ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  Product Marking




Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics



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RE: Product Marking

[Constantin Bolintineanu]

Dear George,

Just a small clarification: in regard to item 5, "one of the following..",
are mixed-up TESTING AGENCIES(NRTLs) with MARKS. In Canada, are acceptable
the following MARKS:

CSA, cETL (issued by ITS - Intertek Testing Services, formerly Inchcape
T.S.), cUL and ULC. (for CERTIFICATION purposes.)  

Respectfully yours,
Constantin

Constantin Bolintineanu P.Eng.
DIGITAL SECURITY CONTROLS LTD.
3301 LANGSTAFF Road, L4K 4L2
CONCORD, ONTARIO, CANADA
e-mail: bolin...@dscltd.com
telephone: 905 760 3000 ext 2568
www.dscgrp.com


-Original Message-
From: geor...@lexmark.com [mailto:geor...@lexmark.com]
Sent: Wednesday, January 24, 2001 3:49 PM
To: emc-p...@majordomo.ieee.org
Subject: Product Marking



Courtland,

You raise a very interesting question, prompted by the usual "Dilbert"
marketing thinking.  Here are some comments, in no particular order,
nor do I draw a conclusion:

1.  As you know, OSHA has approved multiple NRTLs to issue certifications
to UL 1950 and other standards.  We were once acquiring a product which
used the CSA/NRTL mark, i.e. perfectly acceptable.  Marketing thought
the world would come to an end, as they would not be able to respond to
bids (particularly gov't bids) specifying "UL" approval. I personally
assured marketing that if a U.S. gov't bid held to the "UL" approval
requirement they would be at odds with OSHA, i.e. the Code of Federal
Regulations. We wrote a statement for them to the effect that the
product was tested as conforming to UL 1950 etc. without specifying
the agency.  They finally accepted our position, but we still get the
UL mark on most products.

2.  Similarly, Canada will accept a CSA or c-UL mark. However, it seems
that the Canadian gov't prefers the CSA mark when bidding for their use.
Hence, we normally require the CSA mark for models that would most likely
be candidates for gov't office use.

3.  It is my observation and position that customers buying off-the-
shelf or over the internet have no clue what a power rating label is nor
do they look at it after purchase.  Therefore, for the average consumer,
the particular marks or absence thereof matters little.

4.  Large customers of business products do often want know the details
of marks and approvals, but do not necessarily understand that UL =
CSA/NRTL = ITS = MET etc. if tested to the same UL/CSA standards.

5.  If you do NOT market to Canadian gov't, I suggest using any one of
the following, acceptable for other customers in both countries, assuming
your marketing can live with any of these:

-  c-UL-us
-  MET
-  ITS
-  TUVR


George Alspaugh
-- Forwarded by George Alspaugh/Lex/Lexmark on
01/24/2001
03:35 PM ---

cthomas%patton@interlock.lexmark.com on 01/24/2001 04:05:09 PM

Please respond to cthomas%patton@interlock.lexmark.com

To:   emc-pstc%majordomo.ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  Product Marking




Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics



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RE: Product Marking

[Clement Dave-LDC009]

From: Dick Grobner [mailto:dick.grob...@medgraph.com]
Sent: Wednesday, January 24, 2001 4:01 PM
>. I also know that the City of
>L.A. is a stickler for a third party mark on a medical device (and I would
>suspect other devices as will), if it isn't there you submit your device
>along with mounds of data to the cities electrical department, and pay the
>$2-3K for their inspection and sticker. 
>Overall, it makes good business sense to use a reputable third party NRTL
>when doing business.   

We ran into a situation in LA with a piece of recognized (back in the dys UL
resisted giving a listing to any piece of rack mount equipment) rack mount
equipment installed in a bank computer center. They would not issue the bank
an occupancy certificate unless the product was listed or there was field
evaluation of the installation by an NRTL and a listing is approved.

I have been following this thread and one comment that has not been made
that is quite relevant is; You do not want to be shopping around to NRTLs
for the best price all the time. Every NRTL is going to have yearly fees and
factory inspection fees not to mention the disruption of the factory during
the factory inspections (that could mean 4 x the number of NRTLs you have
product certified by).

If the goal is cost and cycletime reduction to certification setting up your
own safety lab and having it accredited ubder one of the client test data /
self certification programs such as ULs COMPASS, CSAs Category or TUVs ACT
will significantly reduce the cost of product certification and will cut the
cycltime in 1/2 or better. If your products are designed using approved
power supplies and you use certified components anywhere it has a safety
impact the lab you set up does not need to be very elaborate or take up much
space.

David Clement
Motorola Inc.
Global Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048

P: 508-261-4389
F: 508-261-4777
C: 508-725-9689
E: 



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RE: Product Marking

[Dick Grobner]

I agree, many years ago we did exactly that, labeled the product as
"conforms too _ _ _  _" before we started using an NRTL for product safety
testing. Eventually the larger medical institutions and corporations got
wise and started asking too see the third party NRTL mark on the product.
Sense, we have all of our devices tested for compliance by an NRTL for
product safety. We place this mark onto the product, our sales literature
and within our user manuals. Does this bring in additional sales - unknown
(not my expertise), but at least it shows due diligence on our part of
providing a safe product to our customers (and in a law suit if it ever came
to that). Some of our larger customers just look for this NRTL mark, and if
it is on the product it moves right through their bureaucracy, if not we
receive a phone call and we start to scramble. I also know that the City of
L.A. is a stickler for a third party mark on a medical device (and I would
suspect other devices as will), if it isn't there you submit your device
along with mounds of data to the cities electrical department, and pay the
$2-3K for their inspection and sticker. 
Overall, it makes good business sense to use a reputable third party NRTL
when doing business.   

Original Message-
From: kazimier_gawrzy...@dell.com [mailto:kazimier_gawrzy...@dell.com]
Sent: Wednesday, January 24, 2001 10:22 AM
To: ctho...@patton.com; emc-p...@majordomo.ieee.org
Subject: RE: Product Marking



Hi Courtland,

For an NRTL approved product, it's generally a requirement that's captured
in the agreement drawn between agency and client plus in their report for
the product.

In my experience, the wording "...conforms with" won't mean much  and
would mean even less without the mark of an agency behind it and visible on
your product.  The NRTL's will generally insist on having their mark on a
product they approve unless it's too small physically.  In such an event,
they tend to allow the packaging to be marked but that's a case-by-case item
and fully at the discretion of the NRTL (for example some very small
conductors might nor necessarily have all the info on the conductor
insulation but it would likely be visible on the spool).

Usually, the visible mark of a safety agency on a given product enhances
marketing since it's the agency's declaration of their having deemed the
product safe (as opposed to the manufacturer).

My 2 cents and not that of my employer.
Regards,
Kaz Gawrzyjal
kazimier_gawrzy...@dell.com


-Original Message-
From: Courtland Thomas [mailto:ctho...@patton.com]
Sent: Wednesday, January 24, 2001 3:05 PM
To: emcpost
Subject: Product Marking



Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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RE: Product Marking

[Joe Finlayson]

My understanding of the NRTL marking is that if you don't mark it,
it is not considered Listed.  It doesn't matter if it has been tested or
not.  I believe the issue is that if the NRTL is performing a factory audit,
they will only review marked product.  Therefore, if you do not mark it, you
can not claim NRTL Listing.

-Original Message-
From: Courtland Thomas [mailto:ctho...@patton.com]
Sent: Wednesday, January 24, 2001 4:05 PM
To: emcpost
Subject: Product Marking



Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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RE: Product Marking

[John Juhasz]

Courtland,

There is nothing in UL1950 that says you MUST have an NRTL logo . . . 
there are requirements for ratings/safety markings, but not a logo.

NRTLs typically have specifications on their logos, and how they must
appear/be
used. I don't recall seeing that you MUST apply the mark . . . 

Simply put, the NEC dictates (I don't have the exact location handy) that an
electrical/electronic 
product must be evaluated by an NRTL against the standard that is applicable
to that product. Once you have permission to apply a mark from an NRTL, you 
demonstrate the 'listing' by application of the logo. Electricians
(competent ones)
look for a logo and act accordingly. If they don't see one they may not 
wire it up, or they can unplug it (they have that right through the NEC).

On another note, using one NRTL over another does have it's advantages
(evaluation
cost aside). Some NRTL logos are more readily recognizable than others by
consumers.
In many cases that I've directly experienced, market pressure forced my to
use
one NRTL logo over another. It depends on your customer base. 
If your customers are regulatory savy, and understand the NRTL program, it
doesn't
matter who you use . . . 
Unfortunately, the average person does not know about any other logo other
than one particular prominent one. That makes it difficult . . . 

It is wise to evaluate your customer base from this respect. . . . 

The opinions expressed here are solely my own, and do not necessarily
reflect those of
my employer . . . 

John Juhasz
Fiber Options
Bohemia, NY


-Original Message-
From: Courtland Thomas [mailto:ctho...@patton.com]
Sent: Wednesday, January 24, 2001 4:05 PM
To: emcpost
Subject: Product Marking



Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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RE: Product Marking

[Andrews, Kurt]

Cortland,

The three NRTLs that we have used require their mark to be on the product.
They even have very strict guidelines as to how it is to appear. We have
used TÜV Product Service, UL, and Intertek (ETL). In the case of UL if you
look at the product listing information on their web site it even
specifically says that the only proof that a product is listed is the UL
mark on the product itself. In most cases there also is a number that is
supposed to be used with the mark on the product. This number identifies the
manufacturer of the product and in some cases the actual production location
where there is more than one. NRTLs also have a big problem if you use their
mark on a product that they did not test or in advertising for a product
they did not test. UL especially protects their mark and will sue anyone
using it that is not authorized to do so. So you definitely should not put
the UL mark on a product that UL did not test even if it was tested to UL
standards. If you manufacture commercial/industrial equipment the NRTL mark
is what is checked by OSHA or the "Authority Having Jurisdiction" to ensure
that electrical equipment used in the workplace is safe as is required by
law. 

Kurt Andrews
Compliance Engineer

Tracewell Systems, Inc.
567 Enterprise Drive
Westerville, Ohio 43081
voice:  614.846.6175
toll free:  800.848.4525
fax: 614.846.7791

http://www.tracewellsystems.com/  


-Original Message-
From:   Courtland Thomas [SMTP:ctho...@patton.com]
Sent:   Wednesday, January 24, 2001 4:05 PM
To: emcpost
Subject:Product Marking


Hello group,

I have a question concerning labeling a product. If we go to a NRTL
and get
Safety testing performed, we typically put the Safety logo (UL for
example)
on the product label. Our marketing people have a problem with
having
different logo's. They would like to standarize on a single logo
such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which
doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and
CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to
have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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Re: Product Marking

[Rich Nute]

Hi Courtland:


>   I have a question concerning labeling a product. If we go to a NRTL and get
>   Safety testing performed, we typically put the Safety logo (UL for example)
>   on the product label. Our marketing people have a problem with having
>   different logo's. They would like to standarize on a single logo such as UL.
>   This kind of thinking hinders the process of getting the best price
>   possible. I would like to get the testing performed at a lab which doesn't
>   use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
>   1950" on the label and forget the logo? Or is there a requirement to have a
>   logo?

The NRTL does not *require* you to use the mark.  For most 
NRTLs, if the specified mark is not on the product, then 
the product is not certified -- even though it meets all of 
the requirements.  

The problem is that almost all USA jurisdictions require
safety certification by a lab acceptable to the jurisdiction.  
Certification is demonstrated by the product bearing the mark 
of an accepted lab.

Recall that there are two jurisdictions that apply:  OSHA for
products used in the workplace, and the local version of the
NEC for products used in areas covered by the code.  Both 
OSHA and the NEC require third-party safety certification.

So, while the NRTL does not require use of the mark, OSHA 
and the NEC *do* require use of the mark -- at least in those
areas subject to OSHA or NEC regulations (which is almost
everywhere in the USA).

Since, according to one management consultant, the purpose of
a business is to create a customer, it would seem prudent to
satisfy your marketing people.

In practice, however, it is my belief that customers simply
presume that products comply with OSHA and NEC requirements.
The choice of NRTL or consistency of NRTL from product-to-
product is inconsequential to customers.  Diplomatically,
you could ask your marketing people to validate through a
customer survey the marketing position that your customers 
want a single NRTL for all of your products.  Of course,
such a survey is frought with the danger that one NRTL's
mark is well-known, while others are hardly known.

If marketing wants just one NRTL, and you are interested in
least cost, then you might want to consider entering into 
an annual or product-by-product contract with your cert house
that results in costs acceptable to you.


Good luck, and best regards,
Rich





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RE: Product Marking

[WOODS]

The US National Electrical Code and many local ordinances require equipment
to be "Listed". Most, if not all, of the Canadian Provinces require
equipment to be "Certified" (except for equipment powered by Class 2
sources). 

Richard Woods

--
From:  Courtland Thomas [SMTP:ctho...@patton.com]
Sent:  Wednesday, January 24, 2001 4:05 PM
To:  emcpost
Subject:  Product Marking


Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


---
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RE: Product Marking

[Kazimier_Gawrzyjal]

Hi Courtland,

For an NRTL approved product, it's generally a requirement that's captured
in the agreement drawn between agency and client plus in their report for
the product.

In my experience, the wording "...conforms with" won't mean much  and
would mean even less without the mark of an agency behind it and visible on
your product.  The NRTL's will generally insist on having their mark on a
product they approve unless it's too small physically.  In such an event,
they tend to allow the packaging to be marked but that's a case-by-case item
and fully at the discretion of the NRTL (for example some very small
conductors might nor necessarily have all the info on the conductor
insulation but it would likely be visible on the spool).

Usually, the visible mark of a safety agency on a given product enhances
marketing since it's the agency's declaration of their having deemed the
product safe (as opposed to the manufacturer).

My 2 cents and not that of my employer.
Regards,
Kaz Gawrzyjal
kazimier_gawrzy...@dell.com


-Original Message-
From: Courtland Thomas [mailto:ctho...@patton.com]
Sent: Wednesday, January 24, 2001 3:05 PM
To: emcpost
Subject: Product Marking



Hello group,

I have a question concerning labeling a product. If we go to a NRTL and get
Safety testing performed, we typically put the Safety logo (UL for example)
on the product label. Our marketing people have a problem with having
different logo's. They would like to standarize on a single logo such as UL.
This kind of thinking hinders the process of getting the best price
possible. I would like to get the testing performed at a lab which doesn't
use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
1950" on the label and forget the logo? Or is there a requirement to have a
logo?

Thanks,

Courtland Thomas
Patton Electronics


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