Warren,

John stated that Products A and B are sold independent of each other. Only
product A has Listing Marks and is the one that gets inspected by the
Follow-Up inspector. Follow-up inspector never sees Product B unless he's
very smart and gathers from the Product A's manual that it is an optional
board. Remember that follow-up inspectors are taught to inspect only
products that have the NRTL mark.

However, the problem is in the field. Someone who opens up Product A in the
field and adds a non-Listed accessory board has violated the Listing Mark on
that product.

Product A's Listing is not valid unless the NRTL has evaluated the
combination of Product A and Product B together and has covered both under
their Listing program. 

Some examples of products that are accessory Listed are: optional cards that
can be fitted on the equipment; optional fan tray, optional mouse, etc.




PETER S. MERGUERIAN
Technical Director
I.T.L. (Product Testing) Ltd.
26 Hacharoshet St., POB 211
Or Yehuda 60251, Israel
Tel: + 972-(0)3-5339022  Fax: + 972-(0)3-5339019
Mobile: + 972-(0)54-838175
http://www.itl.co.il
http://www.i-spec.com





-----Original Message-----
From: Warren Birmingham [mailto:war...@comfortjets.com]
Sent: Monday, September 16, 2002 10:21 PM
To: John Juhasz
Cc: emc-p...@ieee.org
Subject: Re: Add-On Printed Circuit



You don't say to which standard UL has investigated the Product A 
device or whether is is a listed product or a Recognized Component.

The listed product A must conform to the was it was built by the 
manufacturer.  Changes/options to it must be shown in the Followup 
Services Books, otherwise the product is not covered and UL may force 
the shipments to be held for conformance or the listing mark removed.

RCs are evaluated for use in the end product according to UL's 
conditions.

Warren Birmingham
Epsilon-Mu Consultants

On Monday, Sep 16, 2002, at 08:25 US/Pacific, John Juhasz wrote:

>
> Colleagues,
>
> I am seeking your input.
>
> Manufacturer A sells a complete, fully approved  (CE, FCC Part 15, UL, 
> etc)
> product (product A)
> Manufacturer B makes a device (product B) that will plug into a 
> connector in
> product A
> (actually inside product A's enclosure - like a 'daughter' module) as a
> value added feature.
> There are no external interfaces on product B, and it is not accessible
> unless product A is totally dismantled. Product B is intended/sold 
> only for
> use with product A,
> and is otherwise useless.
> The two products are sold independent of each other by the 
> manufacturers to
> 'dealer/installers'.
> When the dealer/installer sells/installs product A, he can offer 
> product B
> as an option.
>
> What are the regulatory requirements/manufacturer's responsibilities 
> for
> product B?
> (est. 2-3 inches square, UL 94V-0 printed circuit board, tens of mA 
> 12V DC,
> no external interfaces.
> On-board clock).
>
> Thoughts?
>
> John A. Juhasz
>
> GE Interlogix
> Fiber Options Div.
> Bohemia, NY
>
>
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