Hi Carl:
I suggest you take it up a notch with NRTL2. Take it up
the management chain at NRTL2. NRTL managers tend to be
more open to issues of added cost to their client,
especially where the value of the requirement is
questionable.
At the same time, the manager has some duty to support
his engineers even though the imposed requirement may
not be clearly a good or logical one.
So, a high degree of finesse is necessary. Ideally,
you want the NRTL2 engineer to take it up the management
chain. You have to ask the NRTL2 engineer if he can
present your case without bias.
If this fails, you should be prepared to physically
visit the NRTL2 site and discuss it with their management.
This is an interesting requirement because there is no
money in it for NRTL2. Usually, not accepting NRTL1
involves re-testing the requires you to pay NRTL2 for
the same work as NRTL1. But, here, it appears that
NRTL2 gets no money by imposing testing on you.
Good luck!
Rich
On 4/29/2013 11:54 AM, Carl Newton wrote:
Customer has a medical wall-wort power supply that has the typical
NRTL (call them NRTL1) safety mark that you’d expect to see on a power
supply marketed within the USA. Customer’s entire device is located
within the secondary of that wall-wort power supply and includes no
connections to other mains connected devices.
Now another one of the large well-known NRTLs (I’ll call them NRTL2)
which is handling the AAMI 60601-1 project for customer’s end product
is requiring that 100% dielectric voltage withstand testing be
repeated on the power supplies. The power supply manufacturer has
provided sections of their NRTL1 File that details the requirement for
100% testing of their supply in manufacturing as well as the voltage
amplitude and duration required. Still, customer’s NRTL2 is demanding
that this test be repeated upon 100% of the power supplies at
customer’s premises. It appears that I have no choice but to agree to
repeat the additional testing. This adds cost to manufacturing and
flies in the face of great efforts on the part of American
manufacturers that try to keep their operations within the USA by
maximizing productivity. I’ve worked on many other projects with
wall-wort and external brick power supplies with other NRTLs and this
has never been a requirement.
I try to keep an open mind even when I’m disagreed with. But I think
that this is the first time in my 30ish years of compliance work that
I’ve seen engineering judgment _completely_ thrown out the window. I’m
interested in other points of view.
Carl
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