Hi Jim:
There are a number of ways to prove traceability
of "bulk-labelled" components, i.e., components
that are not indivually marked.
> - unmarked components - may not be able to tell mfr and cat. no, let alone
> agency status and ratings
These are really bulk-labelled components.
If you deliver the components to the production-
line in the original shipping container, then
there should be sufficient identification on the
shipping container label.
If you re-package the components, and discard
the original carton, then I take the inspector
to the re-package site so that he can see the
original shipping carton and its label.
If we don't happen be re-packaging at that time,
I determine when the next shipment will arrive
and invite the inspector to return at that time.
(There is no requirement to retain the original
shipping carton for the inspector. It certainly
doesn't make sense to warehouse used and empty
shipping cartons or even the labels cut from
those cartons as some folks have done. Inspectors
will sometimes "jawbone" such a requirement.)
> - wiring harnesses - agencies won't rely on surface markings - spool tags
> are at the harness mfr's plant not ours
If you are spec'ing and buying certified wiring
harnesses, then they are either individually
labelled or bulk labelled. If bulk labelled,
then I use the preceding process.
If you are not buying certified wiring harnesses,
then you're really non-compliant (at least for
UL). (Most wiring harness makers are in the UL
program -- all you have to do is include UL on
your harness diagram.)
(With regard to spool marking versus surface
marking... UL requires surface marking but does
not rely on it! @#$%!!!)
> - plastic parts - can't tell what the raw material was and whether or not
> it's approved without seeing the label on the bulk package of pellets -
> that's located an ocean away in the injection moulding vendor's plant
There are two ways of doing this.
1. Require your molder to provide parts under
the UL molder's program. This way you get a
UL certification on the plastic part itself,
or a bulk-label on the shipping carton, or a
cert sheet in the shipping carton. See UL
746D.
Most molders are in this program, or will
readily agree to join the program if that is
a contingency for getting your business. I've
done this a number of times, with little or
no resistance on the part of the molder.
(Some of our folks are engaged in this process
at this moment with molders in a country far,
far away, and are getting good cooperation.)
A molder in the UL program has a distinct
marketing advantage over a non-UL molder.
Sometimes the molder will ask us to pay for
the program. We agree, but he cannot use the
program for any other customer. So, we have
yet to pay the molder's UL program costs!
2. Set up a split inspection. UL will lift those
items that are to be inspected at a separate
site, and set up a procedure for that site.
You get to pay for two inspections instead of
one.
> - boards stuffed out-of-house by sub-contractors
I'm not sure what you mean by this. So, I'll
answer both possibilities:
1. Traceability of the board itself. This is done
by the UL mark on the board. In some cases, the
mark may be under a component, in which case you
will destroy a board to prove the board is UL.
2. Traceability of bulk-labelled components on the
board itself. One way to do this is the split
inspection. Another way is to set up an
Unlisted Component at the board manufacturer's
site. Both are simply "look for the mark" type
inspections.
> - transformers and other sub-assemblies where the material in question may
> be buried deep inside
Same as the above descriptions, as applicable to
your particular situation.
I've used all of these techniques -- successfully --
at one time or another in my career.
Your contract obligates you to prove that you are
using the components specified in the FUS Procedure
or equivalent.
Bulk-labelled parts present a real challenge,
especially if you don't have a bulk label to show
the inspector. In such a case, even if you invite
him back at a different time, he can write a
Variation Notice which will simply state that he
could not determine compliance of a specific part
or parts. If he does so, make sure he mentions
that you invited him back on a specific date to
perform that inspection. Then, you will probably
need to work out a plan with a cert house supervisor
so that you don't incur undue expense, and so that
the inspector will be satisfied that you are using
the correct parts. This is fully negotiable.
One item that you did not ask, and I have no answer
for: cut-to-shape sheet plastic insulating material.
It loses its traceability at the sheet-cutting shop,
and there is no specific program by UL that I know
of that addresses this situation. The only way out
is a split inspection.
UL now has a sub-assembly program that is modeled
after the UL molders program. If your sub-assembly
is made in one of these shops, then you will get a
bulk label or equivalent from that shop with their
shipment of sub-assemblies. The shop essentially
builds from your drawings/instructions/component
list, and you do not need to certify individual
sub-assemblies.
Good luck and best regards,
Rich
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