Yes, my experiences are similar. Inspectors do not want to approve any equipment which is not NRTL approved, even though they are given this latitude in OSHA, in 1910.399, definition: "acceptable", and the NEC in 110-3.a.1.FPN:( "Suitibility of equipment MAY be evidenced by listing or labeling".) It is simpler for them to say "no label, no way." (Especially L.A., which really has their own universe in these matters) But that was not the issue as I saw it in the hypothetical example given by Greg Hansen. There, he had a Listed and Labeled machine, and something happened to the Label during shipping. His assertion was that UL would require the whole thing go back to the factory for relabeling. I think that it would be OK to relabel it in the field if the machine was undamaged and unmodified. Hey, Paul Grabowski! What does UL say? Keith Gershon, Electrical Safety Engineer Lawrence Berkeley Lab [email protected]
-------------------------------------- List-Post: [email protected] Date: 2/20/97 2:10 PM To: Keith Gershon From: Rich Nute Hi Keith: > So here is what you do: 1. Verify > with the engineer that the machine shows no signs of damage. 2. FAX him a > letter telling him to hook it up and that the home office takes responsibility > for any Code violation incurred by hooking up the machine with a questionable > label. 3. Call UL & explain the situation, and get permission to affix a Label > in the field, with the understanding that NO field modifications or damage to > the equipment occurred. 4. Send a factory rep out to the site & slap a label > on it. Sorry, Keith, but it doesn't work like that in Oregon. In Oregon, no mark, no hookup. Period. I can tell you lots of stories (my personal involvement) about printing presses, commercial laundry machines, microwave relays, TV film processing equipment, semiconductor processing equipment, none of which are normally certified by UL or anyone else. Each of these has been red-tagged until UL, ETL, FM, or equivalent, has been brought to the site (at the expense of the equipment owner), investigated and tested the equipment, and placed a label on it. (In the case of the printing press -- made in Germany with VDE- certified components -- the control panel had to be re-built with UL-certified components!) Same situation in the State of Washington. Production-line electric and electronic control equipment certified in place by UL or ETL prior to acceptance by the local electrical code inspector. Similar situation in the City of Los Angeles. The City sends inspectors to trade shows where they look for the mark. If they don't find the mark, they send a letter to the manufacturer informing him of the City regulations (a mark is required for a sale to take place), and the consequences of violating the regulation. The letter also offers the services of the City's own testing laboratory and labelling service. Best regards, Rich ------------------------------------------------------------- Richard Nute Quality Department Hewlett-Packard Company Product Regulations Group San Diego Division (SDD) Tel : 619 655 3329 16399 West Bernardo Drive FAX : 619 655 4979 San Diego, California 92127 e-mail: [email protected] -------------------------------------------------------------
