Hi George:
With respect to the VN issued by the NRTL...
The inspection process is to compare the product to
the report.
Following this comparison, the "inspector" simply
reports any discrepancies. By reference to page and
paragraph of the product report. Black and white.
Then, the manufacturer must resolve the discrepancies.
Either the product is wrong or the report is wrong.
If the product is wrong, then the manufacturer must
"fix" the product so that it complies with the report.
If the report is wrong, then the manufacturer must
apply to the NRTL to fix the report.
In this scenario, the manufacturer is not required to
do anything that is not in the product descriptive
report. You need not take any action at the whim of
the inspector. Easy.
If you are dealing with a NRTL that has a minimum
report, and handles all other matters by reference to
the standard, then the process is quite different. It
appears as though this scenario is your situation.
The inspector now operates as a reviewing engineer.
As a reviewing engineer, the inspector gets to operate
both as a product inspector as well as an engineer. He
can make judgements whether the current product meets
whatever requirements. And interpretations.
Capricious.
Suggestions:
1. Argue each point with the inspecting engineer.
Document in a letter to the engineer.
2. If the situation is still capricious, take the
matter to the NRTL management. Document in a
letter to the manager.
3. If you still get no satisfaction, remove the
mark and take your business to another NRTL.
4. Send a letter and your documentation to the
OSHA accreditation folks.
If you win at steps 1 or 2, then write a report covering
your product and send it to the NRTL as your part of the
certification contract (your company's statement of your
product's compliance). This will prevent recurrence of
the problem.
Best regards,
Rich
