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,  [email protected]
Lucent Technologies, Switching Solutions Group
Intelligent Network and Messaging Solutions


-----Original Message-----
From: Maxwell, Chris [ mailto:[email protected] <mailto:[email protected]> ]
Sent: Tuesday, October 24, 2000 10:47 AM
To: [email protected]
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:[email protected]]
> Sent:Tuesday, October 24, 2000 9:58 AM
> To:   '[email protected]'; [email protected]
> 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: [email protected] [
> < mailto:[email protected]
<mailto:[email protected]> >]
> Sent: Tuesday, October 24, 2000 6:58 AM
> To: [email protected]
> 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.
>    
>
>
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