Hi Ron,
The requirement for most customers, especially telecommunications providers,
is that the product be LISTED or RECOGNIZED to comply with the safety
standards of concern.  The most important being UL1950 and NEBS.  To be
listed and participate in continuing compliance (required) you must use the
logo of the certification laboratory, such as ETL, MET, UL, etc.  The
listing number is also required in close proximity to the logo. (Since this
is a legal requirement with the lab, it is a "badge of quality" on the
product, which should be appreciated by your marketing department!) 

I am told that there are changes "afoot" to allow manufacturers to self
certify to these requirements, however my experience shows that most of our
customers will not accept self certification.

Regards,
Don

Don Robert House, SMTS
Product Certification & Regulatory Compliance
Excelsus Technologies, Inc.
2875 Loker Avenue East
Carlsbad, CA 92008-6626  USA
(760) 918-2552 Office/Lab
(760) 476-1519 FAX
URL: http://www.excelsus-tech.com


-----Original Message-----
From: Ron Pickard [mailto:rpick...@hypercom.com]
Sent: Wednesday, January 24, 2001 11:52 AM
To: Courtland Thomas
Cc: emc-p...@majordomo.ieee.org; owner-emc-p...@ieee.org
Subject: Re: Product Marking




Hi Courtland,

You asked:

>I have a question concerning labeling a product. If we go to a NRTL and get
>Safety testing performed, we typically put the Safety logo (UL for example)
>on the product label. Our marketing people have a problem with having
>different logo's. They would like to standarize on a single logo such as
UL.
>This kind of thinking hinders the process of getting the best price
>possible. I would like to get the testing performed at a lab which doesn't
>use UL. Would it be possible to just put "Conforms to UL 1950 and CAN/CSA
>1950" on the label and forget the logo? Or is there a requirement to have a
>logo?

Exactly what will "Conforms to UL1950 and CSA 1950" mean to your customers,
given that they are
unfamiliar with your products and knowers of the law? Personally, I would
not believe it since a
NRTL mark is not present (not legal in the workplace environment) and
especially since I believe you
were referring CSA C22.2 No. 950-95.

I'm curious, do you switch NRTLs because one is cheaper (um, less expensive)
than another? In my
experience, I like to stick with a single NRTL. They get to know me, I get
to know them, and we both
get a good working relationship and respect out of the deal. This is worth
far more than a few bucks
saved by switching NRTLs.

Here in the US, such practice is mandated by US law in the Code of Federal
Regulations (CFR),
specifically 29 CFR Part 2910 Subpart S. These federal regulations come from
OSHA and the US Dept.
of Labor and can be viewed on-line at:

http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910_SUBPART_S.html

BTW, 1910.399(a) gives 3 routes to compliance:
1. Listing by a NRTL,
2. Inspection by a local municipal inspector of every installation*, or
3. For custom-made equipment, test data must be made available for
inspection by the Asst. Secretary
of Labor.

* will likely fall back to a NRTL anyway due to the inspector's lack of
technical expertise.

IMHO, I do believe that choice #1 would be the path of least resistance.
And, why would anyone
willingly invite the government into their organization? (rhetorical
question here)

Also, the US National Electric Code (NEC) requires NRTL listing of products.

I am very sure that Canada has a similar system in place requiring product
certification.

>Thanks,

No problem. I hope this helps.

Best regards,

Ron Pickard
rpick...@hypercom.com



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