Agency approval only becomes a big deal if there is a lawsuit and the attorneys 
are trying to find negligence.  

In business purchases, many larger companies demand agency approvals by policy. 
 The company I am working with manufactures a device for field testing of 
thermal conductivity, which involves large heaters.  Selling into the European 
block requires the CE approval process, which is a self-administered and 
documented testing.  While it is demanded by many customers, the self-test and 
approval process leaves a tremendous amount of leeway and flexibility.  We do 
have CE markings.  As NeonJohn implied, there is not always a black and white 
answer but you should make the effort to eliminate known hazards.

In a legal contest, if you do something that can be shown to be a willful "bad" 
engineering practice and is found as negligence, you lose.  A clock burning up 
is probably not going to trigger a lawsuit - unless it kills someone.  At that 
point, the outcome depends on how good your legal representation is. 

Beyond the input isolation and materials used to build the clock, there 
probably isn't much to be worried about from a strictly legal standpoint.  Over 
the years, I've lost a few projects to transformer and other line-connected 
component failure and have come to love a well designed, agency-tested power 
brick on the front end of anything that stays plugged in and runs unattended. 
They aren't perfect either...

I had a small fire from a nixie clock I designed in the late 60's, which ran 
just fine for over 30 years until a cap failure in the voltage doubler caused 
overheating, followed by a short, and caught the wood/plexiglass housing on 
fire.  For some reason, the fuse did not fail soon enough.  The insurance 
company paid the claim with no problems.  Fortunately, smoke damage only and no 
one hurt.

Jeff 

-----Original Message-----
From: [email protected] [mailto:[email protected]] On 
Behalf Of NeonJohn
Sent: Friday, October 02, 2015 7:38 PM
To: [email protected]
Subject: Re: [neonixie-l] Re: Linear power supplies for nixies



On 10/02/2015 03:07 AM, Dekatron42 wrote:
> Can anyone direct me to a document that says that it is allowed to 
> sell an electronic apparatus that uses a primary winding as a 
> secondary winding - I spent a lot of time Googling this and I can't find 
> anything.

I'm truly amazed that anyone would think that this sort of triviality would be 
written down somewhere.  Just as you wouldn't find, for example, an official 
document saying that one can use a 2n3904 as a very fast avalanche pulse 
generator. Or any of the millions of other techniques engineers use to 
accomplish the job.

If you pay close attention to the NEC, you'll see that most requirements can be 
modified or over-ridden by "good engineering judgement".  That is, a competent 
engineer can look at a specific situation, determine that the cook-book 
requirement doesn't fit and design a solution specific to the situation.

Of course, the engineer assumes liability for any subsequent malfunctions, just 
as an architect does for new building techniques.

I can assume with reasonable certainty that you don't know how the agency 
approval (UL, ETL, etc) works.  There's no massive tome on high that is 
consulted to determine if a given gadget works.

If you take your new design for a transformer-based wall-wart to ETL, they will 
consult their files to see if there is a testing procedure already on record.  
If so, you pay them about $2500 and they test your gadget against the procedure.

If your gadget covers new area, then you pay them something starting at about 
$10k for them to develop the testing procedure.  THEIR engineers use good 
engineering judgement based on experience when determining the testing 
procedure.  "Is 2500 VDC for 1 minute enough of an interwinding potential or 
should it be 4500?"  Based on their collected body of experience and data, as 
well as any applicable standards, they'll select an appropriate value.

Contrary to popular belief, at least here in the US, a product does NOT have to 
have agency approval to be marketed and used, except for a few malignant 
jurisdictions such as NYC.

At Fluxeon, we decided at start-up not to waste the money on agency approvals 
for our portable induction heaters.  We lose a sale here and there but all in 
all, that has turned out to be the correct decision.

As Chief Engineer and as a member of the Board, the onus for product safety 
falls on my shoulders.  My qualification requirements are vastly tougher than 
any agency would require.

A prime example is the output transformer.  It has about 1200 VAC on the 
primary and about 60 VAC on the other.  It is also the life safety barrier 
separating line voltage from the user.  An agency might require a safety factor 
of 5 and require a HiPot test of perhaps 6kVDC for a minute.

Every transformer is tested at 8kVDC for one minute primary to secondary.  The 
prototypes and random samples pulled from production are tested at 12KV high 
frequency AC for 12 hours.  High frequency AC is a much tougher test than DC 
because the HF generates dielectric losses and other effects not seen with DC.


> I am also
> concerned about safety and what an insurance company would have to say 
> if a fire breaks out and the culprit is the home built equipment which 
> uses a primary winding as a secondary winding.

I don't know where this widely believed fiction originated from but at least in 
every state I've lived in, homeowner's insurance doesn't look any further than 
whether arson was involved.

When I place burned after a computer monitor caught fire in the night, the 
adjuster made a copy of the fire marshal’s report, cut me a check for the 
policy limit, wished me good luck and left.  All over with in 30 minutes.

John


--
John DeArmond
Tellico Plains, Occupied TN
http://www.fluxeon.com      <-- THE source for induction heaters
http://www.neon-john.com    <-- email from here
http://www.johndearmond.com <-- Best damned Blog on the net 
https://www.etsy.com/shop/BarbraJoanOriginals  <-- please visit PGP key: 
wwwkeys.pgp.net: BCB68D77

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