George,
My deepest sympathies.
It seems as if the NRTL inspection authorities are second guessing
the
original engineering evaluation. And that is something that they
should resolve between themselves. I don't believe that ANY
factory
inspection can propose that changes to the design are to be
required.
However, let us assume that the original evaluation missed some
requirements which the factory inspector picked up. If it's wrong,
it's wrong, and the product should be corrected. Make sure,
though,
that the non-compliance is a reality and not just a "nice to have"
item. I believe that in this case, the NRTL should reevaluate the
product (not just the field inspector) write a report, and not
charge
you any additional costs, unless those were for tests that were not
performed in the first place.
I would not bother with A.
I would definitely lay out the whole scenario with OSHA. It
probably
will not help you in this particular case, but it will serve to
clean
up this particular NRTL's act.
I would strongly consider taking my business to another NRTL.
I would not bother arguing each point with the inspecting engineer,
but deal directly with the home office.
For your information, I have presented my case to the UL field
inspector's manager (when UL was the only NRTL) and have gotten
a successful resolution each time. Other times, I have written
to both UL's evaluation engineering and field inspection managers
and presented my grievances. I have found that UL has come round
and changed their operating procedures. However, I never had any
issues where we had to change our design, unless it was a part
of a major UL "File review" due to changes in the standard.
Good luck to you.
Tania Grant, Lucent Technologies, Octel Messaging Division
[email protected]
______________________________ Reply Separator
_________________________________
Subject: NRTL Value
Author: "[email protected]" [SMTP:[email protected]] at CORP
List-Post: [email protected]
Date: 4/27/98 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
