George, You hit a nerve here. I could tell you a story about a certain NRTL (remaining nameless here). I have had my go rounds with them and have taken all but Step A below. I have had un-realistic tests performed, been told to make inappropriate design changes, have had their own reports conflict with their own procedures. I once came to the point of telling one to leave before I physically removed him from the premises.
I had a report that was written five years earlier and one day was told that I could not do what the report said I could. When asked to explain, I was told that it was an internal interpretation letter that I was violating. I appealed and ended up losing that round. I wrote a 180 line Engineering Change Order, created 10 new parts, and re-arranged the manner in which we sold product. It was a major upheaval. I made it my solemn vow to rid us of that NRTL. It took me three years and customer contract negotiations to do it. But that NRTL is no longer here. I am not surprised by VN's on a follow-up inspection. Component manufacturers are notorious for changing things like part numbers or even making them obsolete. Purchasing people are good at finding another part to replace the old. So to have to make a report correction, is no big deal. I have also had the experience (more than once) in the past ten years where an inspector finds things that the original engineer missed. It is very frustrating for us on the line to deal with. Engineers are people and we do make mistakes or miss things. If the inspector/engineer can show me in black and white where the thing was missed and what it must look like, I can deal with that. But when it comes to this or that interpretation, you may get an argument from me. One thing all us us, from engineers to inspectors, must keep in mind is the spirit and intent. It is the spirit and intent of compliance standards to keep people, animals, the environment and other equipment from harm or interference. This sometimes gets lost in the translation The more ambiguous the requirement, the more room there needs to be to allow alternative methods, as long as the spirit and intent is met. Maybe we all should push for a new paragraph to be at the top of every standard or regulation, one that describes in plain language what the spirit and intent of the document is. To those in the world that try hard to do a good job, hats off to you. To those who believe their way is the only way, look out. End soap box. Regards, Scott [email protected] [email protected],Internet writes: > >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 > >
