George - While I have not found myself in quite the same predicament as you describe, I have had good success with your Option D. This quite often clarifies the applicable requirements for a product's audit and has also quite often exposes misunderstanding on the part of the inspector as to what they're supposed to audit and where they can be less uptight (as in defining "adjacent"). This will also lead to fixing of the inspection document(s) to better align with product build.
I assume you reviewed the audit documents as they rolled in, to make any needed corrections, etc. [As an example of misunderstanding, one inspector wanted to require we use a program offered by the NRTL for printed wiring assemblies and went so far as to write a VN item to that effect. It was as simple as a phone call and a follow-up fax to clear that up, since that program was purely voluntary. I was left to wonder, though, if this relatively inexperienced inspector (on the job less than a year) was trained to specifically to act as he did. A bad business practice.] That failing, Option C seems appropriate, if product audits on behalf of one NRTL focus too heavily on things insubstantial to safety. (This is not to say one way or another about the specifics of your VNs.) Your Options A and B will not likely lead to any useful result, other than venting frustration. The BBB is an effete organization that has little power and has subscription based membership (but you know that already). OSHA probably won't care that an NRTL is being "rigorous in their enforcement." Regards, Peter L. Tarver Nortel [email protected] > ---------- > From: [email protected][SMTP:[email protected]] > Sent: Monday, April 27, 1998 1:14 PM > > 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 > >
