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Keeping UL certificaton
4

Keeping UL certificaton

Keeping UL certificaton

(OP)
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

RE: Keeping UL certificaton

(OP)
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

RE: Keeping UL certificaton

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>

RE: Keeping UL certificaton

(OP)
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

RE: Keeping UL certificaton

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.

RE: Keeping UL certificaton

(OP)
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

RE: Keeping UL certificaton

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.

RE: Keeping UL certificaton

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



RE: Keeping UL certificaton

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

RE: Keeping UL certificaton

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

Keith Cress

RE: Keeping UL certificaton

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

RE: Keeping UL certificaton

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.

RE: Keeping UL certificaton

(OP)
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

RE: Keeping UL certificaton

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.

RE: Keeping UL certificaton

(OP)
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

RE: Keeping UL certificaton

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.

RE: Keeping UL certificaton

4
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

RE: Keeping UL certificaton

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

Keith Cress
Flamin Systems, Inc.- http://www.flaminsystems.com

RE: Keeping UL certificaton

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

RE: Keeping UL certificaton

(OP)
Tom, EXCELLENT info there, a star from me, as well smile

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

RE: Keeping UL certificaton

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

RE: Keeping UL certificaton

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!)

RE: Keeping UL certificaton

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.

RE: Keeping UL certificaton

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.

RE: Keeping UL certificaton

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.

RE: Keeping UL certificaton

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

RE: Keeping UL certificaton

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

RE: Keeping UL certificaton

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>

RE: Keeping UL certificaton

(OP)
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

RE: Keeping UL certificaton

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.

RE: Keeping UL certificaton

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.


RE: Keeping UL certificaton

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.

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