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 =productDe tail&p roductId=3 9608-290-S V185R& 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!
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://
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
Dan
Owner
http://www.Hi-TecDesigns.com
RE: Keeping UL certificaton
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
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
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
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
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
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
Dan
Owner
http://www.Hi-TecDesigns.com
RE: Keeping UL certificaton
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
Keith Cress
RE: Keeping UL certificaton
yours
RE: Keeping UL certificaton
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
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
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
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
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
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
Keith Cress
Flamin Systems, Inc.- http://www.flaminsystems.com
RE: Keeping UL certificaton
RE: Keeping UL certificaton
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
Regards, Tom
RE: Keeping UL certificaton
RE: Keeping UL certificaton
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
RE: Keeping UL certificaton
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
RE: Keeping UL certificaton
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
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
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
RE: Keeping UL certificaton
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 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.