My understanding is that "manufacturer" is defined as the company in
whose name the product safety certification is registered.

Jim Eichner, P.Eng.
Compliance Engineering Manager
Xantrex Technology Inc.
e-mail: [email protected]
web: www.xantrex.com  

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From: [email protected] [mailto:[email protected]] On Behalf Of Brian
O'Connell
Sent: Thursday, May 14, 2009 4:18 PM
To: [email protected]
Subject: Ontario Regulation 438/07 (again)

Good People,

The text of the regulation does not specify if the manufacturer must
register, or if the company that is on the safety label and name plate
must register.

The 'FAQ' published by the ESA states that only the manufacturer can
register - but if the mfr's name is not on the name-plate, there is no
basis for tracibility by the local government - which fails to comply
with the code.

Also, where is the hierarchical structure statute text defined for
Canadian law ? It is not clear where each clause/subsection/section
subtends another.

I have sent two emails to the ESA requesting clarification; none were
answered (probably their site problems - at least one seems to have
bounced).

Thanks much,
Brian

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