Brian -
You've heard much of what I might have otherwise said from others. I will add: All NRTLs are not created equal. I've reviewed reports from several of them and found minor inadequacies and inaccuracies here in there in them, which are of little consequence. On the other hand, some NRTLs are consistent in misapplying requirements or not applying them where there's no evidence of engineering rationale to support that decision. There are, in fact no rules that require an NCB to accept a CB Scheme Certificate and Test Report that doesn't also allow an NCB to review the report and decide if additional testing or a more thorough retesting is necessary. You can read more on this by downloading the IECEE 01 and IECEE 02 documents that define operation and interoperation of NCBs under the CB Scheme. In fact, retesting and factory surveillance are criteria explicitly identified in IECEE 02 as an issue when an NCB considers acceptance of a CB Scheme Certificate and Test Report when applying for a national certification. Here's one to grab you: I've recently been involved with an CBTL where three iterative updates were required to a CB Scheme report to which one previous amendment was made. The CBTL had tested the product twice in the previous 18 months, one of which occurred in the previous 9 months (the original evaluation and the previous amendment). Yet, the self-same CBTL stated they "needed" to retest on the next report amendment, on the basis that their "accreditation" required it. No amount of rational discussion could sway them and no engineering rationale was forthcoming from them. In their favor, at least, that the next revision of the CB Scheme report would otherwise have been the fourth report amendment. The practice of limiting the number of report amendments is documented in IECEE02. However, neither IECEE 01 nor IECEE 02 stipulate retesting is necessary at this stage. To make matters more interesting, the update would only have corrected an omission of detail in the safety critical components list, that was need to support a GS License. When I related this story to management, their first conclusion was that the NCB didn't trust their own test data or they were putting the squeeze on us to wring a few more bucks out of us. It's hard to disagree. Regards, Peter L. Tarver, PE [email protected] > -----Original Message----- > From: Brian O'Connell > Sent: Friday, April 09, 2004 4:04 PM > > Good People > > Currently, my employer is attempting to go with a > single safety agency as both NCB and NRTL. We > submitted a "test case" project, but a customer > is having problems because the (different) NRTL > that the end-item was submitted to will not > accept components recognized by the NRTL (that > provided component-level recognition) because > "their follow-up service is not adequate". > > In the U.S., OSHA, (an agency of the federal > government) confers NRTL status; so what is the > basis of one NRTL not allowing the use of > components that were certified by another NRTL in > the end-product that is being evaluated ? > > The evaluating engineer required our customer to > perform additional testing and enter construction > data into the FUS report, on a component that the > customer does not manufactur. The engineer > evaluating the end-use product did not say that > the test reports or construction data in > component's CB report and FUS report were not > adequate, or that the data was incomplete. The > re-evaluation and additional test and data > requirements were based on the fact that the > agency that performed the evaluation does not > have "adequate" FUS audits. (And I personally > have not noticed any significant differences for > the three agencies that audit my factories.) > > I still do business with both of these agencies, > and want to remain on good terms with both; but I > am growing weary with NRTL and NCB "wars". I > understand that the IECEE requires all NCBs to > use each other's CB reports. Is there and > equivalent requirement by OSHA that all NRTLs use > others' FUS reports ? > > luck, > Brian This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ieee-pses.org/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
