Keeping UL certificaton 4

[MacGyverS2000]

I didn't see a forum specifically for UL/CE certification questions, so I'll stick it here...

A client has requested an LED retrofit of some currently existing lighting units (here's a quick example I dug up on Lowe's site, similar to what I'm working with...

http://www.lowes.com/lowes/lkn?action=productDetail&productId=39608-290-SV185R&lpage=none

).

Does the UL registration tie to the lighting unit as a whole, just the case, etc.? Essentially, can I replace the bulb with an LED board while still retaining the UL's idea of this being a safe item, if I don't modify the casing itself? Can I modify it so far as stringing extra cable pairs (e.g., low-voltage signaling) out of the current holes and still retain UL's marking?

If the UL registratio goes "poof" the moment I change anything about the product, I need to look at other methods. Obviously the user is able to open up the case and replace the bulb while still retaining the UL registration, so common sense tells me replacing the bulb with an LED board would be acceptable. Unfortunately, we all know government regulations don't always use common sense.

Thanks!


Dan
Owner

http://www.Hi-TecDesigns.com

 

[MacGyverS2000]

Oh, I'd also like to add some of the fixtures are designed for being placed under water (low-voltage), same question as above.

Dan
Owner

http://www.Hi-TecDesigns.com

 

[itsmoked]

Good question Dan..
I think though that you'd be considered toast if you made that change. Here's my thinking; That fixture is UL'd with specific bulbs and the unit mounted just so..

Like: mounted horizontal, external only , no insulation, in a free space, etc, etc.

Looked into a typical fixture lately? They tend to even note which bulbs are allowed.

Now sometimes the fixtures are listed "not to exceed 80W".
This would help your situation because remember UL really only gives a rip about fire, and nothing else. So if you are putting in a lower power lite then it may be okay. IF, however you are putting in a non-UL listed electronic device I think this would reopen the whole hair ball.

This would be counter to forcing everything thru the process, (you know... How much money do you have? Send it all in.)

So again if you have a customer who needs/demands UL stuff you can't really hand him anything for use in his facility that isn't UL listed. Just because you plan to mount it in a UL box doesn't make the end result UL.

Do keep in mind that if he is really deadset on this you may be able to get the UL listing out of him. It would probably be about $5-7k thru an agency (not directly UL). You may also get him to take another listing like FM instead of UL they all mean the same thing. Or you could wing it if it's the guy's house and you can assure yourself that no possible fault could possibly torch anything.

If you get your lamp UL'd though, that could be a nice product lock.

Well that's my two-bits someone else may have a more direct read.

Keith Cress
Flamin Systems, Inc.-

http://www.flaminsystems.com

- kcress@<solve this puzzle>

 

[MacGyverS2000]

Keith,

Thanks for the feedback... experience leads me to believe you may be right on the UL listing for the entire unit, bulb included, but I'm still naive enough to be hopeful Definitely lower power units, just giving them the option of a wider color gamut than their current system (UV and IR are now required in some spaces, possibly requiring a change in glass faceplates, no clue how that might affect UL listings, but that's a battle for another day).


Dan
Owner

http://www.Hi-TecDesigns.com

 

[itsmoked]

Why on earth would anyone demand UV and IR in a space? Interesting...

In my experience most people requesting a change like yours wouldn't actually care about UL recognizing whatever "electronics" you put into that Luminaire, since you are replacing an astoundingly hot quartz tube with something else that could not possibly cause an enclosure breaching fire.

 

[MacGyverS2000]

The UV and IR are somewhat of a side project for them, so it's something for me to tackle another day. I believe those will be used for security purposes (but I don't have the "need to know").

I suppose my first question should have been, "Is a UL listing absolutely necessary, and if not, in what cases?" I would like to market my modifications to companies in the landscaping and architectural markets, so I'm questioning what effects the loss of a UL registration due to modification would have on marketability.

Can you point me to the proper UL (NEC?) codes I should be looking at? Is a UL listing absolutely necessary for products that will be used in landscaping, or am I perfectly fine so long as my product continues to fit within NEC guidelines?

In case it isn't obvious, I don't know if a UL listing is even required...

Dan
Owner

http://www.Hi-TecDesigns.com

 

[Noway2]

The UL inspector makes a visits our facility about every six months to verify that what we are manufacturing matches what is in the UL proceedure, which includes a bill of materials. Aside from the obvious part about revision levels on build drawings, if we change a part we are technically required to update the UL documentation. If the change is small enough, though, that it isn't obviously different then we sometimes can get away with out it, though it isn't technically correct. Often times the issue comes down to one of "Form, Fit, and Function". If these three are the same you can probably avoid a re-certification.

So in answer to your question:

When the user changes a light bulb, presumably they are replacing it with one that is equivalent to the one that came out of it. Consequently, the Form, Fit, and Function are all identical.

In your case, you would be replacing the buib with an LED board. While the function would be identical, the fit may be the same, but the form would be different. In my experience, and opinion, this means that the certification would likely be void.

I would suggest that you can start by finding out what is in the UL documents as far as what is controlled. If there is a question, you could also run it past one of UL's certification engineers.

 

[IRstuff]

Mac,

Your description leaves out what the certified configuration is. A UL cert of the fixture would allow you to change the bulb type without altering the cert on the fixture, but the unit as a whole would not have certs. You may need to query UL as to what would constitute a "Class I" change in military parlance, e.g., something that does not alter form, fit, or function.

I would think that if this is a big deal, you'd at least need to get a UL cert on your device.


TTFN

 

[MacGyverS2000]

Okay, I'll grab the cert numbers and look them up... wish me luck


Dan
Owner

http://www.Hi-TecDesigns.com

 

[waross]

Check the index of the NEC; Approvals, Approved, Identified, Listed, Labled.
NEC seems to leave approvals up to the local authority. As in "Acceptable to the authority having jurisdiction."
It's probably up to your individual inspector. For one off's some AHJ's will inspect and certify. The last time I had this done, the cost was $25 for the first unit, and $5 for every other device on the application. It was reasonable at the time for a small number of devices, but the cost would be onerous for production runs. That was in the late 70's so add a factor for inflation. Check the current NEC, Check any local Regulations, and have a visit with your local AHJ (Authority Having Jurisdiction).
yours

 

[itsmoked]

Good idea waross! Do you need to include a 20 rolled up in your hand when you shake with the inspector?

Keith Cress

 

[waross]

Actually no. The inspectors were pretty good. Most of the equipment was small plug-in devices that already had a cerification but from the wrong jurisdiction. Occasionally we would be asked to make a modification or change a component to a locally recognized component. One fairly large oven came in from Germany. The inspector could not find any certification on the main supply cable and we were unsure of the equivalent AWG size. (We didn't know the Din size either.) All the other major components had Din certification. We changed the supply cable to a CSA approved cable of the proper size and the unit was approved. That was the most serious problem we had and it wasn't much of a problem.
yours

 

[felixc]

Talking about UL is tricky on this forum. One of my threads has been removed as some of the comments were becoming too emotional about the inspectors. (shut it up Keith!)

If your LED bulb is UL listed, it is a good start. Then it depends on what is in the UL file that concerns the light fixture itself. It will list a series of specific things to watch. If the light bulb itself is in the list, or specific requirements are in there, you may be forced to a file revision if you want to keep the approval. Don't expect a quick answer.

Fire being the main concern, the standard power dissipation is one area where an LED bulb has good arguments. In the failure modes, it has to be demonstrated. A failing lightbulb will typically open circuit in quite a safe mode. Will your LED bulb have any chance to catch fire when it fails? That sort of questions.

 

[MacGyverS2000]

Let me simplify things a bit first... do all lights need a UL certification? Or is it always necessary for interior lighting, but not necessarily exterior lighting?

I will assume that any installation must fit the local NEC codes, and since these will only be installed by professionals, that part is out of my hands.


Dan
Owner

http://www.Hi-TecDesigns.com

 

[felixc]

Whatever connects to the mains will usually mean that you need a UL cert. UL is a creature for the insurance companies, who want to reduce the statistical risks of fire.

But I don't think there's a law that forces people to get everything UL approved. Having somethng UL approved will be useful if your customer's appliance catches fire and that they get sued. Your product being UL cert is a sort of liability guarantee saying that it's not your fault.

I do have customers who don't give a dime about UL.

 

[MacGyverS2000]

felix,

If the control box (which would include a low-voltage transformer) is UL-approved, and that's the only connection to mains, would the insurance company care if the lights themselves are approved? These are low-voltage lights where I am replacing the low-wattage/low-voltage bulbs (10-20W incandescents running at 11-15V) with LED bulbs. I would imagine the major fire hazard is at the mains connection, but again, beng a government-controlled thing I don't feel comfortable making that assumption without assurance from those working in the field.


Dan
Owner

http://www.Hi-TecDesigns.com

 

[felixc]

Well, compact fluorescent lamps do have a UL logo on, in addition to an FCC logo. (Because whatever has something oscillating at a frequency higher than some 10KHz needs an FCC test too.) I remember countrywide recalls of a chinese florescent compact lamp because they've been caught using fake UL listings. My tungsten light bulbs do have a CSA logo on the box.

Regulations can make nice ideas become a nightmare. (not without reasons) I remember a customer who wanted to use RF emittors and detectors on chothes to catch shoplifters. Between a working prototype and an approved product, the project died big time.

Tough decision. Of course if you ask them they will say yes it is a must. $6K and four months of delay. Plus inspections and yearly annual maintenance fees.

 

[TParkhill]

The UL versus non-UL question has been answered so many times in the above link, but we all tend to forget how it applies unless we use it every day. Please forgive me if I say something you have heard before:
1-The NEC requires electrical apparatus to be "listed" by an approved Nationally Recognized Testing Laboratory (NRTL). That means the design has been inspected for electrical safety and PROBABLY has been tested. Since the listing is for a type, not for individual items, manufacturers receive inspections from UL if their products are "UL Listed."
2- OSHA (29CFR 1910) publishes a list of OSHA approved NRTLs. You do not have to use UL if your electrical safety testing is done by others. This has made UL more competitive, more customer friendly and more responsive.
3-Almost anything you do to a UL listed product violates the UL certification, except changing bulbs for the same type.
4-Electrical Inspection departments (and inspectors)have no choice but to enforce the "Listing" requiremnts of the NEC. To do otherwise might expose the enforcement agency to a lawsuit if someone is injured and if the inspector gave a pass" to a modified piece of electrical apparatus which had not been re-inspected by the original listing agency.
5-Several firms previously listed in the OSHA NRTL list have been decertified in recent years. One wonders why.
6-UL has a program called UL508A, which allows a small firm (which has been initially inspected, and receives regular re-certification inspections) to build, re-build or modify electrical apparatus. The UL508A firms are usually called "panel shops". The intention is to allow a shop to assemble an electrical control or power panel from UL listed (not always, sometimes UL allows non-UL components) components, meeting certain minimum UL wiring standards, and certify the entire panel as a UL508A product. Most UL508A panel shops are comfortable working on almost anything electrical even if it is not an actual "panel", and UL does not seem to hold the 508A program to a strict interpretation of "panel."
7- Theoretically, a NEC inspector is stopped from looking inside or going beyond the UL508A sticker on a product. This is important, because UL wiring standards inside the panel are less stringent than NEC standards outside the panel. Unfortunately, not all NEC inspectors agree.
8-If I were going to make a light for sale using a UL listed fixture designed for 60 watts incandescent, by replacing with an LED lamp, I would buy the extra protection by contracting with a UL508A shop to approve the product and provide the UL508A sticker. Insurance companies respect the UL508A sticker, even if some NEC inspectors are not in agreement. A UL508A sticker can cost a few hundred dollars, depending on the location and competition.
I could go on for days on this subject. If you wish to follow up, get on the UL website, the OSHA website, and c all a few Ul508A shops and explore all the options. Tom

 

[itsmoked]

Ah, a nice concise answer Tom. A star for you. Thanks.

Keith Cress
Flamin Systems, Inc.-

http://www.flaminsystems.com

 

[TParkhill]

Thanks for the kind words, Keith. It occurs to me I should have expanded a little more about just how far a UL508A shop is permitted to go. We built in our plant 27 each 237 KW heater controllers. Each was built with a single Motor Control Center bare cabinet, a 600 amp breaker, a 300 amp zero crossing burst mode SCR switch, and a handful of fuses and fuseholders. The feedback from the 237 KW immersion heaters was by a Watlow 4-20 ma temp controller to the Watlow SCR switch. All work was done by a UL508A certified panel shop on our premises. All internal wiring met the UL508A requirements, all external wiring met the NEC requirements. We paid the UL508A panel shop $250 each for the final UL508A inspection/label and the work was inspected at least once by the UL field engineer at no charge to us. The total power controlled was about 6.4 MW. The external wiring was inspected by the local NEC inspector. A harmonious marriage. But it does not always go so smooth. Regards, Tom