Gregory, No one has tackled this yet so .
My experience is that anytime the product standard was updated the NRTL would call for a file review of all products certified under that standard. All the manufacturers using that certification would be notified and given a defined time period to open a review project to show compliance with the updated requirements. I would expect the addition or invocation of any -2 requirements to be included in this process; they are the same as revising the -1 standard except they are written up in separate documents to keep the main document from becoming hugemongous and hard to work thru to include or exclude any specific (-2) requirement. I believe that the cutoff date is set by the change date from the earlier requirements to the new requirements; that is now more complicated as the EU also sets hard specific change dates for the acceptance of various changes in the standards. For a worldwide harmonized standard, such as 61010 series, this is more of a fixed date than in other jurisdictions and seems to drive some of this work in an attempt to maintain the universality of the certification. Perhaps OSHA will respond directly as to their view of all of this. Concerning the additional work and the cost, this should not be a surprise to any manufacturer who is actively participating in the standards process either at the National level or the International level. The ongoing updating work should serve as a trigger for preparing the company for the additional cost in keeping the certification current. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 1067 Albany, Ore 97321-0413 503/452-1201 IEEE Life Fellow <mailto:[email protected]> [email protected] Entropy ain't what it used to be From: Popp, Gregory - Xylem <[email protected]> Sent: Wednesday, October 9, 2019 1:03 PM To: [email protected] Subject: [PSES] Question on 61010-2-081 particular requirement Hello Esteemed List Members, My company has a product that is 3rd party certified to UL 61010-1:2012 Ed. 3. I have been advised that a particular requirement -2-081 now applies to the product so it must be tested in order to maintain the authorization to mark. My questions are; 1. Does OHSA require NRTLs to expand the scope of a product's certification when a particular requirement is released that applies to that product? 2. If the answer to question 1 is yes, what time period must the testing be completed within? 3. What have others in the community done to budget for the unexpected testing? Thank you, Gregory Popp YSI Inc. CONFIDENTIALITY NOTICE: This e-mail, including any attachments and/or linked documents, is intended for the sole use of the intended addressee and may contain information that is privileged, confidential, proprietary, or otherwise protected by law. Any unauthorized review, dissemination, distribution, or copying is prohibited. If you have received this communication in error, please contact the original sender immediately by reply email and destroy all copies of the original message and any attachments. Please note that any views or opinions presented in this e-mail are solely those of the author and do not necessarily represent those of Xylem Inc. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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