geerhed said:
1.) Safety-critical components in a UL-Listed product must be UR. You can't get away from that.
Depends on how you look at it, but the answer to your comment is yes and no. Do some components need to be Recognized? Yes. Do these components have to be Recognized from their manufacurers? No. I can't speak for every piece of equipment out there, but in general, those which require R/C components, all that means is if the component is not R/C, you now have to test the component and it has to meet its individual component requirements (found in its own standards). Just because the component is not R/C by its manufacturer doesn't mean you can't use it, it just means you have to test it (in addition to your product). Now here's the kicker - the component has to pass these tests - since its manufacurer did not test it, you might want to do a little digging around between you and the component manufacturer to see if there's a chance it will pass, otherwise, you're wasting your time, because some components which are not designed to pass safety testing will require design changes in order to pass. It's also not just testing that needs to pass, but also a construction evaluation (think materials, dimensions, etc.). In essence, what you are doing is making the component R/C for use with your product (and paying for it). As you can see, it's always beneficial to you if certain components are already R/C from their manufacturers.
geerhed said:
3.) There is no standard which states this. This is a policy of UL. Another example would be CSA, who does not recognize UR parts - each part must be CSA-tested if not marked as such. Their stamp, their rules. UL originally existed for the insurance companies. Keep that in mind.
CSA and UL often have MOUs in place, which are mutual agreements that say one recognizes the testing of the other. Check with your test lab engineer if his testing can be accepted for the other country's Mark with regards to your piece of equipment or a component, if that's what you're looking at. Also, these days, UL/CSA/FM offer approvals for both the US and Canada, so if one of these labs is testing your product, it can test and certify for both countries, with no need to go to some other lab.
But yes, you will find that typically, the big three (CSA, UL and FM) will not recognize each other's "stuff". Business is business, and greed will always hinder progress and technology. Aren't we humans beautiful? Look for Recognized Components with approvals in both the US and Canada. Some manufacturers are good enough to do this, which will save you many headaches when seeking approvals for your own product in both countries.
Today, it's FM that apparently has a monopoly in insurance. Keep that in mind
geerhed said:
4.) Some things are under engineer discretion. If you think something is totally outrageous, work up a good argument and present it to your handler. Be reasonable. If that's no good and you truly think he's wrong, take the argument to his Reviewer. Just make sure it's worth it; this may cause him to view you somewhat negatively.
Absolutely. Always double check your test lab engineer. You'd be amazed at how much I've been able to eliminate from projects, everything from non-necessary testing to non-applicable Sections/requirements within standards. When in doubt, always ask (and study the requirements well).