If I may hijack this thread, how are products handled that are not fully 
assembled until it reaches the customer site such as some industrial and 
Laboratory equipment? Can you even get an NRTL certification on such a product 
before it leaves the manufacturer? After the product is fully assembled by the 
manufacturer's trained installers, I assume someone of some authority, such as 
an NRTL, will need to go to the customer site and do a field evaluation 
including the hipot test.

How is this scenario generally handled in the US?

The Other Brian

-----Original Message-----
From: [email protected] [mailto:[email protected]] On Behalf Of Richard Nute
Sent: Monday, April 29, 2013 5:03 PM
To: Carl Newton
Cc: [email protected]
Subject: Re: NRTL requiring duplicate testing

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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