Tania, I don't think safety is a matter of pleasure and convenience. However, I do look for value in whatever product or service I purchase for myself and on my employers behalf.
If any supplier is going to cost our company more money and time to market, we need to know a sound engineering reason why. Labs are no exception. After all, if we don't make money on this product, how will we pay to safety test the next one? Actually, your reply sort helped me with my point. Even your reply notes that authorities will go after the manufacturer, not the NRTL. That's why manufacturers need to take responsibility (regardless of whether they use an NRTL mark or not). I believe that the option of self declaration (if it's available) should always be considered. I'm not against NRTL's. I think that their efforts have made our lives better and more safe. I just think that we can't give them carte blanch when it comes to turning down perfectly good data from other labs. We need to ask why and we need to be provided with a sound engineering reason. We also need to be informed of all of the other accreditation schemes out there for labs such as A2LA and NVLAP. As compliance engineers, we need to be informed consumers. It keeps us on our toes, keeps the NRTL's on their toes and pushes them to harmonize with one another so that we all spend more time finding real safety issues as opposed to getting into "I'm better than you are" contests between labs. Personally, I applaud Doug for taking his lab to task. Even though he found out that he indeed needs the fuse, he made a "learning mistake". The act of asking the question allowed him to learn the engineering reason why. It also may have taught other readers of the forum. It's a lesson he'll never forget and his future products will be safer because of it. I just wonder why he didn't find out sooner. It seemed like a fairly straightforward issue that his engineer would have been able to articulate to him before he came to the group with his "beef". I also applaude the NRTL that Doug used and their engineer. They did their homework, had a legitimate concern and stood firm. It always pays to ask why and what we might learn is worth risking some "egg on the face". Personally, I like mine scrambled with some chopped swiss chard, milk and corn meal. New potatoes, home fried in olive oil on the side don't hurt. The "conditions of acceptability" for scrambled eggs don't rule out a little hot sauce on the end product either. I'm getting hungry ... can't.......type......must.....get......... > -----Original Message----- > From: Grant, Tania (Tania) [SMTP:tgr...@lucent.com] > Sent: Tuesday, October 24, 2000 6:06 PM > To: 'Maxwell, Chris'; emc-p...@majordomo.ieee.org > Subject: RE: Got another beef about an NRTL.... > Importance: High > > Chris, > > The NRTL mark is not for your pleasure and convenience. It is for > consumers who don't want their Christmas lights to light up their whole > house. And it also is for whatever local authorities that want to go > after > the negligent manufacturer to recall product and/or bring him to justice. > > > Tania Grant, tgr...@lucent.com > Lucent Technologies, Switching Solutions Group > Intelligent Network and Messaging Solutions > > > -----Original Message----- > From: Maxwell, Chris [ mailto:chr...@gnlp.com <mailto:chr...@gnlp.com> ] > Sent: Tuesday, October 24, 2000 10:47 AM > To: emc-p...@majordomo.ieee.org > Subject: RE: Got another beef about an NRTL.... > > > > This argument highlights why I like the "self-declaration" route to > conformance. > > If I was NRTL A, I would be VERY cautious about accepting data from NRTL B > for a product that will be sold with my (NRTL A) mark on it. > > I beleive that the system is much more practical when self declaration is > used. Then, we as the manufacturer take responsibility for selecting an > approved part (approved by NRTL A). We then take responsibility for > either > selecting an accredited lab (for instance, NRTL B) to test the entire > product or we test the product in house using approved equipment and > methods. We then self declare our product based upon sound engineering > test > data, regardless of whether it's from NRTL A, NRTL B or Sam's Discount > Compliance Lab (assuming Sam is accredited). I don't even bother with > putting the NRTL's mark on the product. After all, if there is a problem, > the customer is coming after my company (maybe even me), not the NRTL. > Also, most NRTL's limit their liability by saying that they have only > performed a type test on a single unit, ... (insert lots of legal blah, > blah, blah here) > > So, why should I worry about an NRTL's legal anxiety about putting their > mark on my product? I'm not sure what protection it affords my company > (as > suming we already have test data from an accredited lab). > > In the end, Duncan. If I was in your position, I would ask your NRTL to > produce a sound ENGINEERING, not legal, not commercial reason that your > NRTL > should not accept the other NRTL's data. I would also consider reminding > them that their mark on your product is a form of free advertising for > them > and that your product would look just as good to a customer with the other > NRTL's mark on it. (Maybe that's a little harsh). I would also consider > the option of self declaration (if possible) it may lessen your NRTL's > anxiety enough that they would accept the other NRTL's data. I caution > that, if you consider self declaration, you really need to know that the > product is safe and the NRTL is only holding out to either protect their > name or jack up their invoice. This would be a hard call to make. My > experience is that the laboratory and its personnel that I have dealt with > are sincere when they have a concern about one of our products. > > Good luck > > Chris > > The views expressed here are mine alone, neither my employer or any NRTL > is > taking responsibility for them :-) > > > -----Original Message----- > > From:John Juhasz [SMTP:jjuh...@fiberoptions.com] > > Sent:Tuesday, October 24, 2000 9:58 AM > > To: 'duncan.ho...@snellwilcox.com'; emc-p...@majordomo.ieee.org > > Subject: RE: Got another beef about an NRTL.... > > > > Duncan, > > > > I've had the scenario with my end product (very simple product - metal > > enclosure, SELV printed circuit, > > 150W Recognized component Power Supply, Recognized Input module. That's > > it.) > > > > I had it listed with NRTL B. Market pressure forced me to get NRTL A's > > listing mark - > > to the same standard. NRTL A would not accept ANY data (not just test > > data, even part > > number info - I had to send the complete package again). > > > > While I don't like to pay twice for the same thing, and while I was > > exposed to > > what amounted to be different interpretations (between the NRTLs) of the > > specifications > > causing great frustration . . . I looked at it from a different point of > > view. > > > > Don't get me wrong, I do sympathize with you, and I wish they had an MRA > > between > > them - it would save a lot of time, money, and frustration . . . but I > can > > see > > NRTL A's point. > > > > If a customer came to me with a product and wanted it listed with my > mark, > > > > before I put MY mark on it (which, historically, most consumers consider > a > > quality > > indicator) I would make damn sure that the product was compliant, lest I > > incur > > the wrath if it fails. I wouldn't take anyone's word for it (report or > > not) > > and rubber stamp it. > > > > > > John Juhasz > > Fiber Options > > Bohemia, NY > > > > > > > > -----Original Message----- > > From: duncan.ho...@snellwilcox.com [ > > < mailto:duncan.ho...@snellwilcox.com > <mailto:duncan.ho...@snellwilcox.com> >] > > Sent: Tuesday, October 24, 2000 6:58 AM > > To: emc-p...@majordomo.ieee.org > > Subject: Got another beef about an NRTL.... > > > > > > > > Group, > > > > What about another scenario that I have been in with two NRTL's. > > For the sake of embarrassment,lets call them 'NRTL A' and 'NRTL B' > > > > Firstly any components or equipment recognised or listed by an NRTL are > > deemed > > 'acceptable' to OSHA so long as it is used as prescribed in its > conditions > > of > > acceptability or use. so can I presume that as OSHA accepts any NRTL > mark > > they > > are all of equal standing. > > > > Why is it then that NRTL A will not accept a power supply approved by > NRTL > > B. > > The latter is true for NRTL B who will accept NRTL A's mark with no > > problems (in > > all cases the conditions of acceptability are followed) > > > > So long as the conditions of acceptability are followed and there are no > > engineering reasons for NRTL A to reject NRTL B's approval then what > > happens > > next. Is there any recourse or would we have to go to one NRTL and get > the > > whole > > lot retested. If there is no engineering reason, can an NRTL reject > > anothers > > recognition just because it distlikes it or maybe sees it as > competition! > > > > Has anyone else had a similar experience, if so what did you do to > resolve > > it > > without paying out for more NRTL approvals on an already recognised > > component. > > > > Any comments would be greatly recieved. > > > > Regards, > > > > Duncan Hobbs, Product Safety Engineer > > Snell and Wilcox Ltd. > > > > > > > > ------------------------------------------- > > This message is from the IEEE EMC Society Product Safety > > Technical Committee emc-pstc discussion list. > > > > To cancel your subscription, send mail to: > > majord...@ieee.org > > with the single line: > > unsubscribe emc-pstc > > > > For help, send mail to the list administrators: > > Jim Bacher: jim_bac...@mail.monarch.com > > Michael Garretson: pstc_ad...@garretson.org > > > > For policy questions, send mail to: > > Richard Nute: ri...@ieee.org > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com > Michael Garretson: pstc_ad...@garretson.org > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
