Hi Ken,

My concern is with the specific requirement of UL 969 when the standard doesn’t 
require that.  I don’t have an issue with the labels being in the critical 
component list.  I have always put them in.

Thanks
-Dave

From: IBM Ken [mailto:[email protected]]
Sent: Saturday, June 01, 2019 6:37 PM
To: Nyffenegger, Dave
Cc: [email protected]
Subject: Re: [PSES] Labeling material recognition to UL 969

Hi Dave!

Is your issue with the UL 969 requirement? Or being forced to list the label in 
your report's List of Critical Components?  (Or both?)

 I have kind of the opposite problem- I don't have an issue with using UL 969 
label stock and listing it in the List of Critical Components.  The NRTLs let 
me list an alternate line item with "Various" for the manufacturer and label 
type.  My issue is with the CB report; they will not allow a "various" 
alternate to be listed, because of the (IEC-based) requirement to perform a 
marking permanence test.   Doing this test isn't even a problem, since I run a 
17025-compliant lab, own reagent-grade hexane, and have the test in my scope.  
My issue is that some of my products have labels that are subcontracted to 
label printers who change materials without letting us know.  They will pick 
label material per my print (which states UL 969 is required).  They would even 
subcontract with a local lab to perform the permanence of marking test if it 
was on the print.  But I can't get the NRTL to allow me to create a critical 
component entry that allows for "any label that is UL 969 and passes a rub 
test"...

So to answer your 2nd question- I have found one NRTL in particular will NOT 
allow UL 969 to satisfy the Durability of Marking test.  Others do.

-Ken


On Sat, Jun 1, 2019 at 3:15 PM Nyffenegger, Dave 
<[email protected]<mailto:[email protected]>> wrote:
Hi Folks,

A few NRTLS are requiring labeling material to be recognized to UL 969 and be 
included in the critical component list.  Anyone running into this?  Anyone 
know the justification for doing this for product to be Listed to IEC based 
standards such as UL 60950-1 and UL 62368-1?  Durability is a requirement with 
specific test criteria in UL 60950-1 and 62368-1 but not that is specifically 
be recognized to UL 969.

Can durability of marking test called out in ICT standards such as IEC/CSA/UL 
60950-1 and IEC/CSA/UL 62368-1 be waived for UL 969 recognized material?

Thanks
-Dave

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