Marketing a product in conflict with its UL status

[SaintSwiven]

First, some background: UL-1598 covers lighting fixtures that use "traditional" light sources (incandescent, fluorescent, metal halide...). UL-8750 is a completely different standard that covers fixtures that use LED light sources. UL-1598 does allow the manufacture of a narrow range of products under "general coverage", meaning that as long as the product is manufactured to those specifications, the product will be Listed under the manufacturer's existing file without additional testing. However, many product features do not allow general coverage and would require specific testing in order to be listed. Metal halide fixtures, fixtures for wet locations, and LED fixtures are such products that do not fall under UL-1598 general coverage.

We are a lighting manufacturer with UL files for surface mounted incandescent fixtures, and surface mounted fluorescent fixtures (both of which fall under UL-1598). We do not have a file for LED fixtures (which would fall under UL-8750). However, we have a single employee who is pushing the idea of manufacturing incandescent fixtures and then marketing them as LED fixtures, when the consumer uses retail-purchased LED replacement lamps. He wants to print catalogs, promotional brochures and product literature that markets the fixtures as LED.

My objection to this employee's idea is that UL goes out of its way to categorize products in a certain way. If we have a product that is marked for use in dry locations only, we cannot suggest that it be used in a wet location. If we have a product that is Listed as a 25 watt incandescent fixture with an E26 socket, then we cannot suggest that a customer install a 24 watt self-ballasted metal halide lamp. And likewise, we cannot suggest that the consumer install an LED lamp, because LED fixtures are listed under a different file, with different standards.

We all know that a consumer *can* do all of these things. I can't stop a homeowner from installing a bathroom fixture outside over his garage, or from sticking that metal halide lamp into the sealed fixture on his bedroom ceiling - and certainly nobody can stop me from installing all of those LED replacement lamps that I have operating all over my own house. Hey, that's why they sell them at Lowe's. My point is that, as a manufacturer of lighting fixtures, we are not allowed to sell a UL Listed product as something that UL's definitions say it is not.

So the question is, am I right? And if so, does OSHA (or UL, or some other governing body) have a document or publication saying as much? Surely UL has some kind of rule that prohibits the marking or promoting of a product in a manner that is inconsistent with it's Listing. Does anyone know where I can find such a rule spelled out?

I know that rambled on a bit - thanks for your time, and thanks for any helpful guidance.

- S.S.

 

[stevenal]

http://www.ul.com/global/documents/...s/regulators/technical/ul_LEDRetrofitKits.pdf

"Self-ballasted LED lamps
Self-ballasted LED lamps intended to be installed in
Edison screw-type, GU24 and other ANSI lamp bases and
connected directly to line voltage supplies are Listed under
the Self-ballasted LED Type Lamp category (OOLV). These
products may be used in Listed permanently connected and
portable luminaires and electric signs. Unlike LED retrofit
kits, the Listed self-ballasted LED lamps are intended for
use only in luminaires that do not need to be modified or
rewired to accommodate Listed self-ballasted LED lamps.
Self-ballasted LED lamps are generally for use in dry, indoor
locations unless additionally investigated and marked for
applications such as damp locations (not directly exposed to
water). Products investigated and marked for wet locations
may have additional restrictions regarding use or orientation.
Self-ballasted LED lamps have been investigated for use in the
smaller of a 6- or 8-inch diameter totally enclosed recessed
luminaire if they will physically fit, unless marked as not for
use in a totally-enclosed luminaire. Products marked “Suitable
for Use in Open Luminaires” are intended to replace tungstenhalogen
lamps in applications where the luminaire is open and
does not require an additional lamp containment barrier."

 

[zappedagain]

To answer this more generically, if you are UL approved to sell 'Product A' you could sell them as 'Product B' with LEDs AS LONG AS you don't put a UL label on 'Product B'. Caveat Emptor to your customer. Your UL green book for 'Product A' should describe what bulb 'Product A' is certified to work with; any other bulb CCN and UL will revoke your right to use the UL mark on 'Product A'.

Z