I think the bottom line is the liability as lawyers see it. Common sense and
truth often have little or nothing to do with torts. When somebody gets hurt
you're going to pay. The question is how much. Even the NRTL's won't say
that your product is safe, only that it meets the standards for safety, and
they won't even do that much in court. The main benefit for the NRTL stamp
is to provide some external evidence that you took the issue of safety into
consideration and at least had somebody else do some minimal cross checking.
Don't know if the term is still around but it used to be called "Reasonable
Manufactures Doctrine" or something similar to that.
If you can feel comfortable in court when the opposing counsel argues that
you didn't even do the minimal to protect your customers, then I wouldn't
worry about it as long as you can get the customer to accept it and to get
it installed somewhere.
A company I worked for ended up paying for a fire that was started by a bank
employee leaving a Holiday candle burning all night. The candle burned into
a wreath that spread the flame to the monitor and while in direct flame from
below the plastic (UL94V0) would sustain the flame. Remove the flame the
fire extinguished. That didn't happen until after the fire spread to the
counter backdrop. We even demonstrated the flame extinguishing on a piece of
the carcass.
Why we had to pay for the bank's negligence is beyond me but there you have
it. Look up attractive nuisance for even more fun lawyer stuff.
So I would make the decision on not just customer acceptance but what it
would cost you to go to court without any back-up testing.
I'm certainly not a lawyer, so I won't be going straight to hell, and this
isn't legal advice. Its just a point for consideration.
Gary
-----Original Message-----
From: [email protected] [SMTP:[email protected]]
Sent: Tuesday, June 29, 1999 11:26 AM
To: [email protected]; WOODS, RICHARD
Subject: RE: NRTL Listing
Richard and Rich,
Many persons think of not Listing a product which is powered by a
Class 2 source of supply. I would say this:
1. What is the product? For example: if product is a medical
product, the system must be assessed to the UL2601-1 and CSA
C22.2 601-1 standard; if product has a telecom interface (TNVs)
then system must be assessed to UL1950/CSA C22.2 950 3rd
Edition; if product is audio/video, then system must be assessed
to the applicable audio/video standards (I recently answered a
thread on audio video product standards); if product is used around
swimming pools, it must be assessed to the applicable
US/Canadian Standards depending on the product function.
Generally a Class 2 power supply is good for ITE but is not good
enough for medical or audio/video applications where additional
construction and/or testing is required.
Also, if power supply is Class 2 and supplies an outdoor unit,
unless the outdoor unit meets the required NEMA designation for
enclosures (refer to UL50) and the circuits are not accessible, the
Class 2 output should be below 21.2 V peak to be considered safe
for wet locations.
Based on the above variables, I would strongly suggest you obtain
NRTL Listing for your product. I have a client with a battery
operated product (2 AA alkaline batteries) who obtained Listing on
their portable electronic dictionary; they not only spent money on
the Listing process (which was mostly paperwork) but also on the
flame rated plastics and PWBs and quarterly inspections required
by the NRTL test house and OSHA. Their sales have been
oustanding!
Good luck with the inspectors out there whatever you do. But most
importantly, build your product to meet the applicable
safety/emc/etc. standards to minimize lawsuits.
>
> I am in basic agreement with Rich. My company makes two types of
low voltage
> products. One type is permanently installed and one is movable. We
always
> use a certified Class 2 or Limited Power Source. Normally we do
not obtain
> certifications for our moveable devices since they are not
normally subject
> to inspection by an electrical inspector. However, experience has
shown that
> the electrical inspectors do ask a lot of questions about the
permanetly
> installed devices, so to prevent the hassle, we do obtain certs on
those.
> However, my understanding of the US and Canadian Electrical codes
is that
> certification is not required for devices powered by a Class 2
source. I
> once asked the leading manufacture of home intercom/radio
equipment is they
> obtain UL Listing and they said they have never obtained Listing
for their
> Class 2 powered equipment.
>
> ----------
> From: Rich Nute [SMTP:[email protected]]
> Sent: Friday, June 25, 1999 8:03 PM
> To: [email protected]
> Cc: [email protected]
> Subject: Re: NRTL Listing
>
>
>
>
> Hi Joe:
>
>
> > liability and such. Can anyone share some more info as
to their
> reasons for
> > listing or not listing such a product which is well
below
> hazardous limits.
>
> There are two schools of thought:
>
> 1. Because of its low-voltage supply, the unit is exempt
from
> most safety certifications throughout the world.
Therefore,
> there is no need to obtain any safety certifications.
>
> 2. Regardless of being exempt, customers expect most
electrical
> products to bear safety certification marks. Indeed,
OSHA
> and NEC electrical inspectors (and customs inspectors)
cannot
> make field judgements as to whether an electrical
product is
> exempt from safety certification. The presence of the
marks
> assure acceptance without your intervention.
>
> I suggest that the decision should be based on your customer
base,
> where the product is used, your company, the product, and
the
> possible difficulties you might encounter without the marks.
Any
> difficulties will have a cost in (1) delaying the product to
the
> customer, and (2) your time to resolve, for the various
inspectors,
> the fact that the product does not require the safety
certification.
>
> For example, low-voltage products going into the home are
not
> likely to be subject to discrimination due to safety
certification
> marks.
>
> On the other hand, products going into the workplace, being
part
> of an electrical installation, or going across borders may
very
> well be subject to inspection for certification marks.
>
>
> Have fun!
> Rich
>
>
>
>
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>
PETER S. MERGUERIAN
MANAGING DIRECTOR
PRODUCT TESTING DIVISION
I.T.L. (PRODUCT TESTING) LTD.
HACHAROSHET 26, P.O.B. 211
OR YEHUDA 60251, ISRAEL
TEL: 972-3-5339022
FAX: 972-3-5339019
E-MAIL: [email protected]
Visit our Website: http://www.itl.co.il
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