UL or ETL certification help 3

[Reifleman2]

I am in a bit of a pickle, frustrated and ill-equipped with UL and ETL standard knowledge to deal with this situation. I am hoping someone here has a deeper understanding of these certifying bodies and can help explain some things to me.

Back story: Small repair shop start-up, part of a larger company, in Alaska and therefore under UL certification requirements.

Our city UL inspector came in and has taken issue with 4 pieces of our equipment. His primary concern is the (in his words) "lack of a UL Assembly certification sticker. Individual UL recognized parts are unacceptable."

Breakdown of our equipment:

1) Large piece of polishing equipment. It is very old, from Europe, but has UL stickers within the control box. But none of the stickers say UL Assembly certified. Since it is so old, I can understand it might need some extra attention and a new 3rd party certification.

2) Polishing lathe with speed control (part # 1F800 from Grainger). I contacted Dayton and got UL certification numbers for the motor and the speed controller, and was even told it was undergoing inspection from UL to be certified as a whole assembly. He does not accept the UL numbers for each component, even though it is sold as a bundle through Grainger and Dayton.

Link to Grainger:

http://www.grainger.com/Grainger/ww...ch&Ntt=1f800&N=0&GlobalSearch=true&sst=subset

3) Downdraft bench with a single phase UL recognized motor. Again, the motor is the only piece of "electrical" equipment on the entire item, but because the entire assembly doesn't have a UL Assembly certification, he will not accept it.

4) Quincy 5 hp air compressor with attached tank. It has a UL Controller certification, but again, not an entire assembly certification. I contacted Quincy, and they laughed at the request from the inspector, saying that no organization is capable of UL certifying an entire compressor (tank, pistons, controllers etc.) and that it would be far too expensive and time consuming.

The inspector is telling us we must have all 4 pieces of equipment 3rd party assembly certified, and even recommended us going through ETL because it may be cheaper. I know very little about UL or ETL certifications, but it seems like this inspector is really trying to screw us over. None of our suppliers seem to understand why he is going into so much depth, especially from standard suppliers like Quincy and Dayton. I'm also concerned from an ethical standpoint, ie: is he getting kick backs from the 3rd party certifier's and forcing us to do something we shouldn't have to?

Any thoughts or advice?

 

[jraef]

He's right, it's the law in Alaska (and a lot of other states). Any assembly of electrical equipment with 4 or more components in a box (actually 5 including the box itself) must have an "NRTL" listing as a completed assembly, not just the components inside. The components inside must then be listed in order to attain this, but that's the business of the shop that is building / listing the panel. NRTL is an acronym for Nationally Recognized Testing Lab, of which UL is the most famous and widely known, ETL (no called Intek) is another, there are about a dozen, maybe more, around the country. You can see a list of them on OSHA's website.

http://www.osha.gov/dts/otpca/nrtl/

Getting your one one-off panel UL listed will cost you about $20K, maybe more in Alaska because you will have to pay for a UL or ETL inspector to fly in and eat steak at the local hangout. What you want to do it take your parts to a local UL-508A listed control panel assembly shop and have them do it for you, it's a service they can perform and they are certified by UL to do it. They will likely have to change out some of your parts, most of them will not do it with used junk because as part of the process, they have to determine what is called an SCCR, Short Circuit Current Rating, for the assembly and that value must be applied to the outside of the box. The code then says that you cannot connect that assembly to a power system that is capable of delivering more than that number. UL: allows them to apply a "courtesy" number on un-tested components at 5,000A, but that is all but useless because most industrial and even commercial installations are going to be 25kA, 35kA, even up to 65kA available fault current in Alaska. So to attain that high of a rating, they will have to use parts that have been pre-tested in series combinations by the component mfrs. If you do a Google search of "UL 508 panel shops Alaska" you should be able to find some. A lot of industrial electrical contractors have made the investment in getting certified, but ask, don't assume.

This is not a scam, this is about safety. A lot of people THINK they know how to cobble random stuff together and end up starting fires. The states that have adopted this tactic are trying to curb the proliferation of this sort of thing. I happen to know that Alaska was notorious for that 25 years ago when this took effect, a lot of fish processing plants and mining operations were killing people right and left with electrical fires, but the inspectors don't have the time or expertise to know the ins and outs of panel building.

"Will work for (the memory of) salami"

 

[dpc]

Just one minor clarification on Jeff's excellent response - ETL is now Intertek.

 

[Reifleman2]

Very interesting response, thank you very much for the information.

My next question is this: How do large suppliers like Grainger and Quincy get away with selling equipment not UL certified as an assembly? It absolutely blows my mind, and I would never have expected to have this set of issues. I went through national and well known suppliers when ordering my equipment, I would think certifications would be well observed and followed from these suppliers.

What about the Quincy compressor? Why did they laugh about any additional UL requirements? In their minds, the UL cert was all done during manufacturing, and does not apply to the tank or other components.

Also, why doesn't UL's site have a specific marking for an entire assembly? The primary forms of marking seem to be UL or UR, but neither seem to apply to an entire system. Our compressor sticker specifically says "US UL Listed, Encolsed Industrial Control Panel." Why is this not enough?

I agree there HAVE to be safety regulations, and Alaska was bad for a long time. But it is frustrating that I cant seem to find a set of rules and regulations to go by. I do not like simply going by what someone says, especially when they cant give me straight answers when I ask an engineers favorite question: "Why?"

 

[LionelHutz]

First off, cities don't have UL Inspectors.

FYI, there is no such thing as UL Assembly Certified or any kind of UL label that says something is certified. There are different UL Listing labels depending on the part or assembly. There also isn't a single UL label that would cover every part of a multi-disciplined piece of equipment.

I'm going to base these comments on the belief this guy was a city electrical inspector so my comments will address the electrical suitability of the parts.

#1 - I wouldn't mind seeing some pictures of the control panel and the UL labels inside the box. It sounds like a control panel so it does need a listing on it. However, if it's older and used then there might be some ability to get the inspector to OK it in the field.

#2 - If that motor and controller are both separately UL listed then the inspector is being overzealous asking for any further UL listings. It'd be hard to call this an open control panel because the parts are not mounted on a panel but some people might argue it is one. The parts are a separate motor and controller with some wire going between them. If you bought them separately, you'd get 2 parts with a listing on each part and you'd have to mount the 2 parts in 2 different locations and wire them. So, if the supplied wire is UL listed then what's the difference if you install it or it was already installed? Also, You don't need to be worrying about fault currents above 5kA on a piece of equipment you plug in.

#3 - The motor is good so what's the issue? This one definitely isn't a control panel unless you left out details about components that switches the motor on and off also being installed on this equipment. People build all kinds of assemblies they install a motor on without the whole assembly having a "UL certification". Think say a crusher or a conveyer belt or say a base holding a water pump and a motor. None of these have a UL listing on the whole assembly yet no right minded inspector has an issue with the installation. If this is just a motor then the inspector has gone past overzealous straight to being ridiculous.

#4 - I personally think the inspector is being ridiculous in this case too. I'm sure Quincy sells compressors with that electrical setup by the thousands and I highly doubt they all get returned because inspectors won't accept them. If you can show the UL listings for each electrical component then he shouldn't have an issue accepting it.

 

[Reifleman2]

This is a city inspector, and the municipality of Anchorage (and the whole state of Alaska) require UL certified equipment within a commercial business.

I agree, he seems to be going out of his way to be overly critical. His answers and justifications are all very vague and crappy, but at the end of the day he will not sign off on any of our equipment.

It looks like we are going to have to have someone come in and certify things for us, which is an unfortunate expense. Im frustrated, but there doesn't seem to be a whole lot I can do about it.

 

[jraef]

Another issue that yopu may not realize.

You indicated that some of your components are UL "Recognized", and you seemed to think that this is the same as being UL "Listed"; it is not. A "Recognized Component" cannot be used stand-alone, it can ONLY be used as a component part of another factory assembled, tested and listed assembly. Most people do not realize this, but most likely your inspector does. When you see the "backward UR" symbol, that means it is a Recognized Component only.

UL Recognized Component mark

UL Listed mark.

So for example your Grainger item is NOT currently UL listed as an assembly, only the speed controller is. The motor is UR and until Grainger completes their process with UL to list the assembly, he is right, it is not listed and you are not supposed to use it that way. Why can Grainger sell it? Because that's not THEIR problem since not all states require NRTL listings.

Re: the compressor, your compressor supplier is blowing smoke up your you-know-what... (pun intended). UL DOES indeed list air compressors, and they know it.
UL 1450 is strictly for the air compressor assembly itself, i.e. the pistons, tank, receiver etc.. The control panel for it would have to be separately listed under UL 508.

http://ulstandardsinfonet.ul.com/scopes/scopes.asp?fn=1450.html

"Will work for (the memory of) salami"

 

[LionelHutz]

You need to get your definitions straight.

UL Certified - does not exist.
UL Listed - the inspector should accept.
UL Recognized - OK when used as part of a bigger UL listed assembly.

You also need to get clarified what the inspector needs exactly.

You will not get an overall listing on a panel and the motor. A control panel can be listed under UL508A. UL508A does not include motors, unless used for fans or the AC unit applied to the control panel. So, using UL508A to cover all the electrical parts of that buffer or compressor is not possible.

You will not get a field UL Listed label. The UL inspector by themselves do not provide UL Listed labels. They will provide UL Field Inspected labels. If this isn't acceptable then it doesn't help you. See page 2 for an example.

http://www.ul.com/global/documents/...rvices/Field_Services_Brochure_final_2012.pdf

UL would certainly want to know about any company that would put a UL Listed 508A panel sticker onto a piece of equipment they did not build. UL would send them a cease and desist type letter since that type of action directly violates the UL Listing and UL Mark user agreement the company has with UL. UL can also simply pull the UL listing from the company if they decide to.

A UL panel shop can only place a UL label on panels they build. A piece of pre-built equipment does not apply. Same as above, it violates the agreement with UL.

Basically, if you need UL Listed equipment then you need to purchase it with the UL Listed mark.

 

[lightmedic]

Some Background-
I am the electrical foreman (read design engineer, fabricator and singular solution to OMG it uses electricity - panic) for a UL authorized Control Panel (UL 508a) and Sign (UL 48) shop. I have been through the UL 508a class on how to and not to do it. By no means does this make me an expert, just less ignorant than I was before I sat through the class. For what it was worth, just about everybody taking the class had an oops moment about what they knew they had been doing wrong... The course can be found by following the link and directions below:

http://lms.ulknowledgeservices.com/home.aspx

Click on Public Workshops on the left
Click on "Power and Controls" in the bottom right of the page

There have been a couple of details above that I feel the need to clarify.
-First, a control panel is evaluated under 508a. The components that go into the panel had to meet the standards of 508 before that got rolled into UL 60947. I do not have to go there so I don't know more about that.

-Second, UL Listing and Recognition are both two different things and DO NOT mean they can be used in a control panel. There is a magic list in the back of UL 508a that tells you what can be used. There are of course exceptions, specifically (and as best I can tell) any low voltage device used as it is intended down stream of a class 2 power supply. Just because a piece is recognized does not mean it can be included in a control panel.

-Third, a device will not have a sticker from the manufacture if the manufacture date predates the applicable standard. A product can be field evaluated, by a UL field inspector. It is not cheap and may not pass. I joke that UL exists only in multiples of $4k. There are exceptions, they are few.

-I suspect that a control panel that is a portion of a device covered by its own standard is evaluated under that standard and would NOT need to be labeled under UL 508a. Now, in all likelihood, the product standard will defer to UL 508a, but the evaluation would be under the product standard not 508a unless it is a remote control panel, then I have no idea, could be either. For instance, I know that there is not a UL 508a sticker on the controls for my kitchen oven, but the controls for an industrial oven with a remote panel may very well be, I just don't know, I don't make anything close to this example.

-UL 508a covers the control panel ONLY. There are two options, two stickers, enclosed and open. An enclosed control panel includes the enclosure, its type, penetration information, blah blah blah. Open panels may be enclosed, but the listing then covers only the panel and may not be delivered in the enclosure. It is handy if the shop is retrofitting and old control cabinet. New back plane, new parts all wired up, an open sticker and it gets field integrated. Any device connected electrically, but not mechanically, to the panel is NOT covered under the 508a listing. The items not covered would include just about every conceivable configuration of stuff being controlled. To be fair, I am not sure if a 10 HP motor is allowed to be part of a control panel...

-Regarding a third party panel shop. Yes, they have to do the final assembly to sticker. If you come in with all the pieces 95% put together and I, for example, pop in the circuit breaker and complete the wiring, I have done the final assembly and I can sticker it. You will have to find a willing shop and do ALL the legwork on parts and pieces because I would want to verify I am comfortable putting my name on the line. This is confusing as all get out, bouncing between cut-sheets, UL, and manufacture tech support. Some vendors are great at supporting this, Automation Direct puts all the compliance information available for every piece in an available popup window. McMaster, on the other hand, doesn't even list the manufacture. Depending on who picks up (yup, you have to call), they are either forthcoming or al you have to do is ask for the UL file number for the item and you can back channel determine these details through UL.

-Component selection and acceptability determination is a process. ID a part, get the UL File #, go to UL.com and at the bottom on the right (in the grey) Tools - Online Certifications Directory. Play with the search options, but generally using the file number is the fastest. This brings up the manufacture, a short description, the appropriate four letter code and the file number. ABCD is Listed, ABCD2 is Recognized, ABCD7 is Canada Listed, ABCD8 is Canada Recognized. Guess correctly, search that document for the part number (if you are lucky, skipping the sucky options for now) print it as a pdf and save it for your records. Save a cut sheet of the piece as well. Then, go search the UL 508a standard in SA1 to make sure that the recognized part is acceptable to be used in a control panel. Yup, yet another UL document that is highly protected, you're going to have to buy it.

- Your local inspector does sound like he is being a pill, possibly due to a lack of knowledge on his part. It can work both for or against you and you seem to be on the short end of that stick.

I would recommend:
Obtaining a copy of your local codes. Read them. Read them again. Ask for interpretations until you are comfortable with your understanding.
Call UL, figure out who your field inspector is and talk to them. Despite running a racket and being bloody expensive, they are in the business of safety. Part of that is education both you and the inspector. Being in AK, I'm not sure you will get a visit out of them, but you might.

Be aware, you can always petition to the higher authority in the inspection office. This takes time and may not pay off, be sure you are right if you play that card.

Best of luck.
Dan

 

[itsmoked]

Nice!

And welcome to Eng-Tips lightmedic.

Keith Cress
kcress -

http://www.flaminsystems.com

 

[LionelHutz]

To be fair, I am not sure if a 10 HP motor is allowed to be part of a control panel...

It's not. Control panels don't include anything connected externally to them and the "magic list" you described only lists ventilation fan and AC units as items that can be included in a control panel. So, no motors unless they're part of the cabinet cooling system.

-Regarding a third party panel shop. Yes, they have to do the final assembly to sticker. If you come in with all the pieces 95% put together and I, for example, pop in the circuit breaker and complete the wiring, I have done the final assembly and I can sticker it.

Yes, you can technically do that but not so easily for used equipment, such as the old polishing equipment being described. All the parts need to be first labeled as reconditioned before you can do that and I think there is some UL file or special UL requirements to do that reconditioning.