Very well stated Rich,

(see below)
It puts the finger on the real problem with what i call
"testimonial certification"  . It's the process were manufacturers
stop thinking about safety as soon as the UL (or other respected
test house) has allowed to use their safety mark.

The test house however is hired to perform the certification process
test according to applicable standards which as result of
international standardization process must cover a very wide range
of products in one manuscript.

Therefore i want to draw your attention again to the European system
of Safety Directives,  specifying safety in terms of generic safety
requirements (so-called essential requirements) and make the
manufacturer sign for it's liability using the DoC.

The safety of the product has to be proved to the manufacturer
in such a way that he can feel confidant about it's declaration.
Therefore he will need to actively seek an suitable standard or
any other test suite that covers his liability, and this
change of what manufacturers ask a test house stimulate test houses
to research beyond the strict letter of the standard.

The process shown in the ce marking system has the best of two worlds:

- direct liability of the manufacturer by signing DoC
- usage of international standards not to prove but give assumption of
safety only (this requires the manufacturer to go beyond standards if he can
suspect additional dangers such as food stucking into toasters)
- self certification to reduce the costs of the approval process.


That this process is more stringent then UL VDE or KEMA SEMCO etc testing is
shown by f.a. filter manufacturers grouping together in searching to exclude
their components from electrical safety  ce marking, and preferring the
route to hire many international test houses (including annual payments)
above the free process of self certification but with inceased liability.

Regards,

Gert Gremmen Ing.

== Ce-test, Qualified testing ==
Consultants in EMC, Electrical safety and Telecommunication
Compliance tests for European standards and ce-marking
Member of NEC/IEC voting committee for EMC.
Our Web presence: http://www.cetest.nl
List of current harmonized standards http://www.cetest.nl/emc-harm.htm

-----Original Message-----
From:   [email protected] [mailto:[email protected]] On Behalf Of
Rich Nute
Sent:   woensdag 24 november 1999 20:43
To:     [email protected]
Cc:     [email protected]
Subject:        Re: UL in Washington Post




Hello from San Diego:


Many thanks to Sean for posting the URL for the
Washington Post article on UL.

While I am notorious as a "UL-basher," I think
the focus of this article is misplaced.

This article presumes that UL puts the safety
into products.  Unfortunately, many manufacturers
also believe that UL puts the safety into their
products.

Manufacturers, not UL, are responsible for the
safety of their products.

UL is a certifier.  UL certifies that the product
complies with the requirements published in a
standard.


Best regards, and for my USA colleagues, west wishes
for the Thanksgiving Holiday,
Rich





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