George, I can understand your frustration in this situation. What I would suggest is that if the changes that the inspector is requiring is not a safety hazard and is mainly to comply with the intent of the requirements then it is best to try to follow through with these changes. However, you may need to let the NRTL know that you need additional time to make these changes and they will usually honor these types of situations. For example, let your incorrect label to deplete or allow you to change your documentation processes and mechanical drawing through an Engineering Change Order (ECO). I know most NRTLs have no idea how long it usually takes for making changes even to a simple label.
For those of you working in a NRTL, I would like to share the following so you may understand George's frustration. In a midsize to a large company, a simple change to a label will require to red mark the existing CAD drawing, approval from the mechanical design engineer so that the change does not impact any thing else. Once you have obtain all of the informal agreements then you need to write an ECO, required if the organization is an ISO 9000 certified, and then formally submit this ECO. An ECO usually requires signature from number of cross functional departments in the organization. I think at one time, couple of years ago someone did an analysis and came up with a rough estimate of $5000 to write and implement an ECO. I personally think $5000 is a very low estimate considering all the paper work, time it takes to generate it, revise and file it. After all the signatures are sought then the design is sent out to the label vendor for camera ready film and final approval, this process alone takes about two weeks. surely, you can rush all this, however, if your rush a project in a NRTL it cost more money. The same thing is true for dealing with outside vendors. Hopefully, this will shed some light for those of you working in a NRTL. George, if the change is significant and it requires considerable amount of money to implement it then I would suggest you contact the project engineer and reason with him/her. Sometimes the engineer has a better insight into a product than a FUS inspector. I would like to add that no engineer that is working for an NRTL is perfect just like you and me are not perfect. Therefore, oversights are made occasionally due to number of reasons. I believe as regulatory engineers we need to make sure that our design complies with the intent/requirements of the standard and consequently we are responsible for the design of a product and not the NRTL. By the way my multiple choice answer to your question is "None of the above". Best regards, Kamran Mohajer, M.Sc. Staff Engineer NeTpower Inc., 545 Oakmead Parkway Sunnyvale, CA 94086 Tel:408-522-5185 Fax:408-522-4135 [email protected] > -----Original Message----- > From: [email protected] [SMTP:[email protected]] > Sent: Monday, April 27, 1998 12:14 PM > To: [email protected] > Subject: NRTL Value > > > Here's a situation that I find very frustrating. > > Suppose a (leading) National Recognized Test Laboratory (NRTL) > assesses a product and issues an authorization letter for the > use of their "mark". > > Suppose a year or so later, during a routine follow up service > inspection, a dozen or so "variation notices" are generated by > the NRTL inspector. > > Suppose that many of the VN's state that changes to the design > are required, although it is the same design approved by the > NRTL in the first place. > > Suppose that the VN's include changing the power rating label > to "Listed Accesory", which is exactly opposite the labelling > requirement as described in the NRTL's own guidelines. > > Suppose one VN requires moving the power rating label, or adding > a new label, nearer the convenience outlet. A reasonable request, > but never raised during the approval process or prior FUS visits. > > Do you: > > A. Register a complaint with the Better Business Bureau (ha) > B. Notify OSHA, who authorizes all U.S. NRTLs > C. Take future business to an alternate NRTL > D. Argue each point in a reasonable manner with the inspecting > engineer > E. All of the above > > Has anyone had a similar experience with a U.S. NRTL? > > George Alspaugh > Lexmark International >
