Hi Courtland:
> 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?
The NRTL does not *require* you to use the mark. For most
NRTLs, if the specified mark is not on the product, then
the product is not certified -- even though it meets all of
the requirements.
The problem is that almost all USA jurisdictions require
safety certification by a lab acceptable to the jurisdiction.
Certification is demonstrated by the product bearing the mark
of an accepted lab.
Recall that there are two jurisdictions that apply: OSHA for
products used in the workplace, and the local version of the
NEC for products used in areas covered by the code. Both
OSHA and the NEC require third-party safety certification.
So, while the NRTL does not require use of the mark, OSHA
and the NEC *do* require use of the mark -- at least in those
areas subject to OSHA or NEC regulations (which is almost
everywhere in the USA).
Since, according to one management consultant, the purpose of
a business is to create a customer, it would seem prudent to
satisfy your marketing people.
In practice, however, it is my belief that customers simply
presume that products comply with OSHA and NEC requirements.
The choice of NRTL or consistency of NRTL from product-to-
product is inconsequential to customers. Diplomatically,
you could ask your marketing people to validate through a
customer survey the marketing position that your customers
want a single NRTL for all of your products. Of course,
such a survey is frought with the danger that one NRTL's
mark is well-known, while others are hardly known.
If marketing wants just one NRTL, and you are interested in
least cost, then you might want to consider entering into
an annual or product-by-product contract with your cert house
that results in costs acceptable to you.
Good luck, and best regards,
Rich
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