Hello Bill,
The following is part of the UL Variation Notice. I understand your comments, however, 'hold shipment' (Item 3) is a term that UL uses. Sylvia Underwriters Laboratories Inc. Information For Manufacturers Variation Notices GENERAL - If the UL Representative finds items (variations) which differ from the UL Procedure, he must complete a Variation Notice (VN). Some of the items may be minor changes needed in the UL Procedure, and these will be handled by UL without any further action on your part. Should these differences be significant, the manufacturer has three choices: 1). Rework the Product - Correct the variations to comply with the UL Procedure. 2). Remove All References to UL - Permanently remove or obliterate all UL Marks on, or associated with the product. These include UL references on the carton, packing materials and similar items accompanying the product. Also included is the UL Recognized Marking for Recognized Components. 3). Hold the Shipment - The manufacturer must agree to keep the products at the factory until a UL office has made a decision as to whether or not the variations (changes) are acceptable. If this situation is urgent, a copy of the Variation Notice should be sent, by fax, to the UL Reviewing Office and to the Applicant. If facsimile facilities are not available, use telex, telephone, or overnight mail. APPEALS PROCEDURE - If the manufacturer disagrees with our Field Representative, he may hold shipment as noted above and appeal to the UL conformity Assessment Services Reviewing Office. COMMUNICATIONS - The UL Representative will note on the Variation Notice which items require a response from the manufacturer. In all cases, information about the variations and the appeal, if any, can be sent to the UL office by the fastest means, including fax, telex, and telephone. If a telex is sent, a verbatim copy of the Variation Notice should be telexed along with the manufacturer's comments. A telephone call should be made while the UL Representative is at the factory. It is the manufacturer's responsibility to notify the Applicant, if other than the manufacturer, that a response to the VN is required. Even if the Conformity Assessment Services Reviewing Office determines the variation(s) to be acceptable, changes cannot be made to the Procedure until UL has received written authorization from the Applicant. From: FastWave [mailto:[email protected]] Sent: Tuesday, February 18, 2003 12:12 PM To: Sylvia Toma; Lay Siang Saw; [email protected] Subject: RE: product safety audit scenario The Certification laboratories such as UL, CSA, ETL, MET, etc. cannot hold a shipment. However, they can require that you stop shipping products with their certification mark = your choice, remove the certification mark or hold shipment until the lab allows you to use the certification label again). That is one of the basic elements of their "Follow Up Service Agreement". Be sure you understand what you are signing when you sign Follow Up Service agreements. In general, they authorize access to manufacturing facilities to inspect anything with their certification mark. NOTE - OSHA has authorized NRTL's to reduce the number of annual Follow Up Service inspections from 4 to 2 for most categories. I would anticipate that this soon will be one of your prime considerations on selecting a Certification Lab = how many FUS inspections they require per year. Bill Bisenius ED&D [email protected] www.productsafet.com -----Original Message----- From: Sylvia Toma [mailto:[email protected]] Sent: Tuesday, February 18, 2003 12:39 PM To: Lay Siang Saw; [email protected] Subject: RE: product safety audit scenario Hello Alice, One scenario that an auditor can hold shipment is the system under audit employs a different power supply (different manufacturer name and/or model number) than the one stated in the Procedure or Critical Component list of the Test Report. Power supply is a critical component (since it contains hazardous voltages) and one cannot substitute a different power supply into the system without first notifying the agencies. The agencies need to conduct evaluation and testing on the alternate power supply. Sylvia From: Lay Siang Saw [mailto:[email protected]] Sent: Tuesday, February 18, 2003 1:51 AM To: [email protected] Subject: product safety audit scenario Hi all, Can anyone share with me under what conditions an auditor is allowed to stop shipments ? Thanks,alice ---------------------- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 06:09 PM --------------------------- Lay Siang Saw 02/18/2003 10:50 AM This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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