Hello George. Technically speaking, an inspector is not in a position to dictate constructional changes. The inspector is further not supposed to interpret or apply requirements during inspection. In short, the inspector's job is to read and follow the descriptive report of a product. Unless what is being built is different than what is being described, no variation notice should be written.
In your case, it appears that the inspector may be familiar with the standard that covers your product lines. It is possible that the inspector has noted mistakes made by the NRTL engineering department, and the inspector is using the VN as a communication vehicle to request Engineering Department to review the product. This may work well for the NRTL, but that's not fair. If a product's construction feature pose an imminent hazard, such observation must be communicated to the Engineering Department, but not via VN. Usually, this is accomplished by a phone call to the nearest engineering office. If you feel that you have a case, I would contact the inspector and request a contact name from the NRTL Follow-Up Service Department having jurisdiction over that inspection center. I would ask to talk to a FUS engineer to settle the VN's. The FUS engineer will be responsible to contact the appropriate engineering department to asssist in the resolution of your inquiry. You will have a chance to state your case to the engineering department, that in effect, has the ability to overrule the VN. At the very least, the engineering department is obligated to give you a grace period to make the necessary changes. If you have had a good working relationship with the NRTL, there is no reason to change them at this time. Just talk to their FUS department, and I believe you can clear up the problem. Good luck. Best regards. Jim. Jim To Force Computers,Inc. Email: [email protected] At 04:14 PM 4/27/98 -0400, you wrote: > >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 > > >
