Re: [PSES] Orgalime: UL an effective barrier to trade
This echoes the hue and cry based on ISO 9000 registration requirements in the early '90s. These requirements were placed on the purchasing side of businesses. There was quite a bit of noise emanating from the US and Canada that this was a de facto nontariff trade barrier erected by protectionists. Singling out UL infers customer requirements were probably at play. Regards, Peter L. Tarver - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Orgalime: UL an effective barrier to trade
Hi Peter: Hmm. What's the current status of the ISO 9000 game? Best wishes for the New Year! Rich -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Peter Tarver Sent: Thursday, December 29, 2011 4:10 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Orgalime: UL an effective barrier to trade This echoes the hue and cry based on ISO 9000 registration requirements in the early '90s. These requirements were placed on the purchasing side of businesses. There was quite a bit of noise emanating from the US and Canada that this was a de facto nontariff trade barrier erected by protectionists. Singling out UL infers customer requirements were probably at play. Regards, Peter L. Tarver - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Orgalime: UL an effective barrier to trade
In message F6AE313A8C2E4BBB853398779B4A47BE@RichardHPdv6, dated Thu, 22 Dec 2011, Richard Nute ri...@ieee.org writes: The answer to the Orgalime paper is to use a different certification house for both components and end-products. Competition determines who wins. I really wish these European bodies would do their homework properly when making a case, instead of attacking straw men. Best wishes for the holiday season, Your seasonal felicitations are cordially reciprocated. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Some people who are peeling the finch of the financial crisis are thinking of biting a rook. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Orgalime: UL an effective barrier to trade
Thank you Richard and Brian for the comments. As many will recall this issue was reviewed twice officially by OSHA and the results published in the Federal Registrar. Results of that time did not see a barrier to trade. One suggestion that continues to resonate is a common marking system for product safety. Such common marking systems can be found in USA (FCC), Germany (GS) and Brazil (INMETRO). This completely levels the field for competing Certification Bodies. CB's for FCC, GS and INMETRO compete on various levels of service and value. Unfortunately OSHA NRTL is underfunded and understaffed and will not take on this challenge. However if the Certification Bodies were to unite and develop a common marking system they could submit to OSHA NRTL the changes in their product mark(s) (final product and component). NRTL's routinely update the look of their product marking systems within the guidelines of the program. Possibly organizations like ACIL could unite the NRTL's towards a common marking system? Scott Griggs +55 (19) 8314 3822 mobile +1 (224) 999 0441 home griggs_sc...@yahoo.com From: Brian Oconnell oconne...@tamuracorp.com To: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Thursday, December 22, 2011 10:49 PM Subject: Re: [PSES] Orgalime: UL an effective barrier to trade As usual, Mr Nute finds the good stuff. The root problem may be in the historical process - back when FM and UL were explicitly stated in OSHA code. This is no longer the case, but continues when the phrase UL approval is used to indicate 'NRTL' approval. My employer has problems with this, but perhaps not at the same critical level as larger companies. As most of my employer's products are not catalog items (custom), we educate the customer about the NRTL system. We send people to some customers' end-users to gently explain that forcing products to bear the UL mark can be considered a trade restraint or illegal elimination of competition for most government projects. But the customer is always right, so if they insist, we submit to UL. As for test process, I see no significant difference among the four NRTL labs, including UL, that I use. Some test or construction data may be presented differently, but their reports all contain the same wondrous information. For critical components, UL response has been that they cannot, as a matter of internal policy, accept the factory audits for other NRTLs, so some components that do not bear the UL mark shall be subject to special factory audits. The bottom line is the bottom line - prove that if affects cost without affecting safety or reliability and it becomes a done deal. But when I defeat Palpatine and the sith lords and become emperor and control Google, this will all change... Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Richard Nute Sent: Thursday, December 22, 2011 3:23 PM To: emc-p...@ieee.org Subject: Orgalime: UL an effective barrier to trade Orgalime position paper: EU manufacturers suffer from malfunctioning of the US certification market: potential abuse of dominant position http://www.orgalime.org/Pdf/PP_possible_abuse_of_dominant_position_in_US_cer tification_market_oct11.pdf This practice of denying recognition of component certificates delivered by other NRTL's causes de facto a quasi monopoly situation from the component manufacturers' viewpoint. In practical terms, all products need to be re-evaluated by UL or a UL-certified supply must be sourced and incorporated. The result is that all products within the electrical component market must be certified by UL and UL's share of the component market is ever increasing. This behaviour not only restricts the freedom of choice of manufacturers, but also proves to be expensive and causes delays in the development process of a machine. ...the current [OSHA] rules governing the market have one fundamental shortcoming, namely the lack of obligatory recognition among the NRTLs of component certificates. Orgalime suggests that the European Commission encourages the US authorities to study the facts and correct the malfunctioning of their certification market. My comment: OSHA rules do not govern the product safety certification market in the U.S.A. U.S.A. certification houses are private entities subject to the usual business rules. How they conduct product certifications is not regulated -- by OSHA or any other regulatory body. Indeed, here is OSHA's statement on certification house function: . . . while the record indicates that current safety testing standards and practices may vary slightly among the third party safety testing organizations, the testing laboratories themselves indicate that they have compensating mechanisms and controls built into their particular systems which are intended to assure that the ultimate result will fall within an acceptable range http://www.osha.gov/pls/oshaweb
Re: [PSES] Orgalime: UL an effective barrier to trade
One quick point for our non-EU friends is to point out that Orgalime are a trade body who, in theory at least, represent European manufacturers. They have no official legal status as arbiters of trade agreements (or anything else for that matter). That's not to say they do not have a point in this case, but they should only be seen as once voice in the discussion, and a partial one at that. Nick. Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: nick.willi...@conformance.co.uk - Conformance Ltd - Product safety, approvals and CE-marking consultants The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk Registered in England, Company No. 3478646 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Orgalime: UL an effective barrier to trade
In all fairness to Orgalime, the answer that Rich gives doesn't really provide a practical solution for component manufacturers. As long as all the agencies accept UL certification of components as valid and UL is reluctant to accept component certifications from other agencies, this will drive component manufacturers to always go to UL for certification, though they may get other certifications in addition to UL depending on perceived market advantages of doing so. An end product manufacturer is certainly free to go to another NRTL rather than UL, but the component manufacturers aren't going to go away from UL unless and until the advantage UL has here is eliminated - which is unlikely to be driven by the market without some form of outside intervention or collaboration among competing entities. Even if all of a sudden UL were to lose most of its market share for end products, as long as their component certification is the only one that is universally accepted by all NRTLs, the situation will not change. Historical considerations have created a situation where competition alone doesn't truly determine who wins. Scott Aldous Compliance Engineer AE Solar Energy +1.970.492.2065 Direct +1.970.214.9427 Mobile +1.970.407.5872 Fax +1.541.312.3832 Main scott.ald...@aei.com 1625 Sharp Point Drive Fort Collins, CO 80525 www.advanced-energy.com/solarenergy -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Friday, December 23, 2011 1:31 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Orgalime: UL an effective barrier to trade In message F6AE313A8C2E4BBB853398779B4A47BE@RichardHPdv6, dated Thu, 22 Dec 2011, Richard Nute ri...@ieee.org writes: The answer to the Orgalime paper is to use a different certification house for both components and end-products. Competition determines who wins. I really wish these European bodies would do their homework properly when making a case, instead of attacking straw men. Best wishes for the holiday season, Your seasonal felicitations are cordially reciprocated. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Some people who are peeling the finch of the financial crisis are thinking of biting a rook. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com This message, including any attachments, may contain information that is confidential and proprietary information of Advanced Energy Industries, Inc. The dissemination, distribution, use or copying of this message or any of its attachments is strictly prohibited without the express written consent of Advanced Energy Industries, Inc. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Orgalime: UL an effective barrier to trade
I think a UL or CSA or VDE, etc recognized part should be acceptable by any and all agencies. At least safety-critical aspects of its construction are controlled by 3rd party and therefore subject to regular audit. _ Ralph McDiarmid | Schneider Electric | Renewable Energies Business | CANADA | Regulatory Compliance Engineering From: Aldous, Scott scott.ald...@aei.com To: EMC-PSTC@LISTSERV.IEEE.ORG Date: 12/23/2011 08:29 AM Subject: Re: [PSES] Orgalime: UL an effective barrier to trade In all fairness to Orgalime, the answer that Rich gives doesn't really provide a practical solution for component manufacturers. As long as all the agencies accept UL certification of components as valid and UL is reluctant to accept component certifications from other agencies, this will drive component manufacturers to always go to UL for certification, though they may get other certifications in addition to UL depending on perceived market advantages of doing so. An end product manufacturer is certainly free to go to another NRTL rather than UL, but the component manufacturers aren't going to go away from UL unless and until the advantage UL has here is eliminated - which is unlikely to be driven by the market without some form of outside intervention or collaboration among competing entities. Even if all of a sudden UL were to lose most of its market share for end products, as long as their component certification is the only one that is universally accepted by all NRTLs, the situation will not change. Historical considerations have created a situation where competition alone doesn't truly determine who wins. Scott Aldous Compliance Engineer AE Solar Energy +1.970.492.2065 Direct +1.970.214.9427 Mobile +1.970.407.5872 Fax +1.541.312.3832 Main scott.ald...@aei.com 1625 Sharp Point Drive Fort Collins, CO 80525 www.advanced-energy.com/solarenergy -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Friday, December 23, 2011 1:31 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Orgalime: UL an effective barrier to trade In message F6AE313A8C2E4BBB853398779B4A47BE@RichardHPdv6, dated Thu, 22 Dec 2011, Richard Nute ri...@ieee.org writes: The answer to the Orgalime paper is to use a different certification house for both components and end-products. Competition determines who wins. I really wish these European bodies would do their homework properly when making a case, instead of attacking straw men. Best wishes for the holiday season, Your seasonal felicitations are cordially reciprocated. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Some people who are peeling the finch of the financial crisis are thinking of biting a rook. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com This message, including any attachments, may contain information that is confidential and proprietary information of Advanced Energy Industries, Inc. The dissemination, distribution, use or copying of this message or any of its attachments is strictly prohibited without the express written consent of Advanced Energy Industries, Inc. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy
Re: [PSES] Orgalime: UL an effective barrier to trade
PSNet, Altho many good points have been made, UL (the 800 lb gorilla in all of this) has an established position in the component business. Having worked with many component mfgrs over the years, this is not lost on these mfgrs (incuding their marketing folks). Component mfgrs have no control over who takes their products to which lab so must be prepared for it all. So, in spite of all the grumbling, component mfgrs will continue to use UL for the foreseeable future. That's easy for me, I've worked with UL for a long time. :) br, Pete Peter E Perkins, PE Principal Product Safety Engineer PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 fone/fax p.perk...@ieee.org - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Orgalime: UL an effective barrier to trade
I think a UL or CSA or VDE, etc recognized part should be acceptable by any and all agencies. At least safety-critical aspects of its construction are controlled by 3rd party and therefore subject to regular audit. UL, CSA, and VDE each have their own component standards -- which are not necessarily harmonized. So, they will not accept each others safety determinations. I don't think this will happen until we come up with a CB scheme for components. Best wishes for the holiday season, Rich - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Orgalime: UL an effective barrier to trade
Rich and All, We already have CB on components such as component ITE power supplies. Since CB does not involve factory audits, the end product certification body requires the component be subjected to it's follow-up audits. So yes we need components covered under CB but better yet is we can harmonize the factory audits so they do not get inspected again and again. Happy Holidays Peter Merguerian pe...@goglobalcompliance.com Go Global Compliance Inc. www.goglobalcompliance.com (408) 931-3303 Sent from my iPhone On Dec 23, 2011, at 2:00 PM, Richard Nute ri...@ieee.org wrote: I think a UL or CSA or VDE, etc recognized part should be acceptable by any and all agencies. At least safety-critical aspects of its construction are controlled by 3rd party and therefore subject to regular audit. UL, CSA, and VDE each have their own component standards -- which are not necessarily harmonized. So, they will not accept each others safety determinations. I don't think this will happen until we come up with a CB scheme for components. Best wishes for the holiday season, Rich - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Orgalime: UL an effective barrier to trade
As usual, Mr Nute finds the good stuff. The root problem may be in the historical process - back when FM and UL were explicitly stated in OSHA code. This is no longer the case, but continues when the phrase UL approval is used to indicate 'NRTL' approval. My employer has problems with this, but perhaps not at the same critical level as larger companies. As most of my employer's products are not catalog items (custom), we educate the customer about the NRTL system. We send people to some customers' end-users to gently explain that forcing products to bear the UL mark can be considered a trade restraint or illegal elimination of competition for most government projects. But the customer is always right, so if they insist, we submit to UL. As for test process, I see no significant difference among the four NRTL labs, including UL, that I use. Some test or construction data may be presented differently, but their reports all contain the same wondrous information. For critical components, UL response has been that they cannot, as a matter of internal policy, accept the factory audits for other NRTLs, so some components that do not bear the UL mark shall be subject to special factory audits. The bottom line is the bottom line - prove that if affects cost without affecting safety or reliability and it becomes a done deal. But when I defeat Palpatine and the sith lords and become emperor and control Google, this will all change... Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Richard Nute Sent: Thursday, December 22, 2011 3:23 PM To: emc-p...@ieee.org Subject: Orgalime: UL an effective barrier to trade Orgalime position paper: EU manufacturers suffer from malfunctioning of the US certification market: potential abuse of dominant position http://www.orgalime.org/Pdf/PP_possible_abuse_of_dominant_position_in_US_cer tification_market_oct11.pdf This practice of denying recognition of component certificates delivered by other NRTL's causes de facto a quasi monopoly situation from the component manufacturers' viewpoint. In practical terms, all products need to be re-evaluated by UL or a UL-certified supply must be sourced and incorporated. The result is that all products within the electrical component market must be certified by UL and UL's share of the component market is ever increasing. This behaviour not only restricts the freedom of choice of manufacturers, but also proves to be expensive and causes delays in the development process of a machine. ...the current [OSHA] rules governing the market have one fundamental shortcoming, namely the lack of obligatory recognition among the NRTLs of component certificates. Orgalime suggests that the European Commission encourages the US authorities to study the facts and correct the malfunctioning of their certification market. My comment: OSHA rules do not govern the product safety certification market in the U.S.A. U.S.A. certification houses are private entities subject to the usual business rules. How they conduct product certifications is not regulated -- by OSHA or any other regulatory body. Indeed, here is OSHA's statement on certification house function: . . . while the record indicates that current safety testing standards and practices may vary slightly among the third party safety testing organizations, the testing laboratories themselves indicate that they have compensating mechanisms and controls built into their particular systems which are intended to assure that the ultimate result will fall within an acceptable range http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGIST ERp_id=13454 With respect to a component, testing by one party may be different than that of another party. Such differences may result in different testing of the end-product but result in the same end-point. Here is OSHA's statement on an NRTL accepting data from another NRTL: The first or basic program stipulates that the NRTL that will certify the product must perform all product testing and evaluation itself. An NRTL's initial recognition will always include this first program. The other eight, called supplemental programs, involve the NRTL's acceptance of testing and evaluation data or services, or certain contract services, from outside parties. An NRTL must apply for recognition to use any of the supplemental programs. OSHA will grant the request if the NRTL has met the criteria for the specific program. One issue that often surfaces is whether an NRTL must accept the product testing, certifications, or approvals of another NRTL. OSHA has no authority to require such acceptance. An NRTL may accept the work output of another NRTL. However, this is solely a business decision of each NRTL. See: www.osha.gov/dts/otpca/nrtl/faq_nrtl.html Also: OSHA ...has previously determined that an NRTL may, but is not obligated to, accept test data, component or product approvals, or other information
