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]

Tom, EXCELLENT info there, a star from me, as well

The UL508A shop sounds like the perfect way to go in this regard. Swinging a few hundred dollars for a large batch of these sounds quite reasonable, but would kill the project if that's a per-unit fee. Obviously my modification would be significantly smaller in scope than your panels, so hopefully the per-unit fee would also be considerably smaller.

Are these shops able to offer a design-based sticker (one sticker for a specific, non-changing design), or must everything be checked on a per-unit basis?

It sounds like I'll be fine from an NEC standpoint if I don't modify the external wiring (though I may still need to do so for comm purposes), and UL508A inspection of each board/connection should be a breeze due to their simplicity.

I'm feeling a bit more confident about this one...


Dan
Owner

http://www.Hi-TecDesigns.com

 

[TParkhill]

Dan: Thanks. I am happy if I can help. As to your questions, all I can say is that UL gives very great freedom and latitude to their 508A certified shops. You should probably start negotiating locally, and you may have to go out of town to find the right contract. Each 508A license holder is fully responsible for everything that wears their signed label, so it would be well not to ask for blind, unquestioning rubber stamping. I know you didnt mean to, but I felt I should mention it for others who are reading this. Good luck.
Regards, Tom

 

[TParkhill]

Dan and others with this problem: I dont know why I did not think of this before, but it just occurred to me you may want to sign up with UL for your own 508A certification. I spent a day at a UL seminar for $100 and got all the dope plus free lunch. I did not follow through myself, but I understand the program may initially cost $3500 or so, and then there is a "circuit rider" inspection every 6 months by the UL field engineer which you share with other local 508A shops. UL is very helpful by phone and with certifying non-UL parts to go into your products, according to my 508A contractor. Also, expanding your business opportunities is not a bad idea. Call the UL field office in your state for more information. Regards, Tom. (honestly, I promise to stop writing to this thread, right now!)

 

[felixc]

I'll ask my UL inspector about the 508A program. I wonder if it is available in Canada.

Dan, this may not let you avoid submittal your LED circuit for a UL listing. Your customer would use the 508A for his fixture though.

 

[lrob]

If you are considering Canada also you may want to check into CSA certification. Both CSA and UL have US and Canadian dual certifications. I had a product that was onsite inspected by CSA. I was informed that I could have had the product sent to them for certification. They informed me they would do multiple certification if I sent the product to them. I know the cost of shipping the product maybe high but it would be a way to start producing the product while you get certified yourself. The cost to become CSA shop is similar to that of UL.

 

[LionelHutz]

Tom;

UL508A is for industrial control panels. Your description of the heater controls is exactly that so that work was not pushing the limits. The part I don't understand is how they could do the work in your plant and affix the UL508A labels there. Was the UL inspector present when they applied the labels? If not, then it was not properly done since the labels can only be affixed in the listed manufacturing plant of the company holding the UL508A listing, unless it is witnessed by a UL inspector. The manufacturer can't add any new labels, as called out by UL508A, to a panel in the field.

UL508A has a standard, which you should have received at the course, that lists all the possible components you can use and for what purpose. It requires everything to be listed and if it's not then you need to take the component to UL and get it approved for use in your panel. This adds a procedure to your UL508A file allowing you to use the component. This approval is basically equivalent to fully listing the component, except you list it just for yourself for use in panels you build as opposed to it being listed for use by anyone who buys it. Typically, it a $1k bill minimum any time you do this.

Now, the use of UL508A for "listing" a light fixture with an unapproved LED board is far outside of the scope of UL508A. UL508A is not to give manufactures the ability to circumvent UL testing and "print" their own listings. I wouldn't even consider doing it for you Dan under our UL508A listing.

 

[TParkhill]

Thanks for your clarifications, Lionel. Clearly, before anyone begins down this path, you have to talk to UL and the 508A contractor to see what is permitted. Yes, the work was done in our plant by the 508A contractor, and the 508A records on this project were inspected by the UL field engineer on his last trip. Also, our UL Field Engineer has permitted in-field modifications and relabeling by the 508A contractor, which do not require returning the panel to its point of origin for the modifications. Yes, UL has allowed non-UL components to be placed in a 508A panel under certain conditions, but it is up to the 508A licencee to coordinate this and get approval from the field engineer. Commenting on another response, CSA is also an approved NRTL, along with UL, FM and two pages of others. I think this thread has been beaten to death. Intertested parties, please do your own research. Regards, Tom

 

[felixc]

Tom and Lionel,
it looks like you have been in contact for a very long time with the approval processes. Although the topic might look trivial to an experienced mind, I will just point out that for the everyday designer in a small shop, getting a good perspective of what these approvals involve is a sort of nightmare, as in so many cases the products are already designed when the approval cycle begins.
To reduce the shock, are you aware of any kind of book, website, or other documentation that could help people in their first encounter with this world that nobody teaches about in schools?
Felixc

 

[itsmoked]

Get it from the horse's mouth..

Go to the UL and FM (Factory Mutual) websites. They both give regular courses you can take too.

Keith Cress
Flamin Systems, Inc.- <

http://www.flaminsystems.com>

 

[MacGyverS2000]

My feelings exactly, felix... to this day, I've yet to find any specific mention of when/where a UL certification is required and on which products. Sure, I can make some educated guesses based upon what's currently out there, but so far not even a mention if it's voluntary for certain markets or mandatory.

A book I can read in my spare time, a course I'm forced to dole out much larger sums of money, take time off of work to attend (i.e., lose vacation time or pay), etc. Had they offered this in school, I most likely wouldn't have signed up thinking it would never be necessary in my career (someone ELSE takes care of those details, right?)... and regretted that decision now.


Dan
Owner

http://www.Hi-TecDesigns.com

 

[felixc]

For having gone through a approval cycle on my own products, I know that the processs is costly, timely, and painful. If a certification for a specific type of product is not required, don't do it. This is certainly not what they will teach you in their courses. Then the costly, timely and painful continues when the inspections begin. This is from the point of view of a small company with just a few products. This is different in a large place, where they can afford full-time people on these aspects.

 

[LionelHutz]

I don't know of any books or other resources to help understand the UL approval process.

If you are talking about a low voltage lighting product then you really need to look at it's UL file. It is possible that there is no requirement for the bulb itself and if there is you need to know exactly what the requirements are. Basically, a UL file will list all the important components and the restrictions on what they can be.

For example, a printed circuit board will have no requirements for the low voltage logic components but will have requirements for any 120VAC connected components as well as spacing requirements for the board around these components.

 

[felixc]

For my customers to have a UL logo on their box, they needed that my board has a UR file (since it is a component).

For me to have this UR file, all the connectors, the pcb itself, and the whole schematic has been analysed for security issues, current vs connector capabilities, short-circuit protection of the I/Os, lithium battery protection. Even the stickers used to identify the board had to be made from a UL approved place. The board is powered from 5V and + - 12 volts.

Dan my feeling is that if you ask to a UL guy if you board needs approval, the answer will be yes whatever your board does. In your specific case I don't think you'll be able to avoid it. Moreover if your circuit has something that oscillates over 10KHz, you will probably need an FCC approval cycle too.

It is tougher than it used to be for small companies to grow up. On top of that, add RoHS and ISO9000.

Wanted: a person with an expertise to interpret the rules for a given application, before going to the approval agencies.