We'll agree to disagree on this one, Eng8492.
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Two folks, two opinions -- who'd a thunk it?
I stand by my opinion --
1) NRTLs are test labs, nothing more. They are not charged with determining what standards apply; they are only charged with testing to the standards that their client requests.
2) I have had ambiguous situations to deal with regarding FCC and a couple of UL standards in the past. It was my job, as the company's chief engineer, to make the determinations. I'm aware of the external interpretations of the written codes and regulations like the FCC Appliance rule you posted. It's my job to ferret them out, do the research, and come to a conclusion. Years ago when I first saw the appliance exception, my first question was, "What constitutes and appliance?" So I dealt with it.
The same thing happened often when I would design power and lighting for construction. As the specifier, I had to call out the appropriate standards for the equipment on the job. Once in a great while, there were conflicts. It was up to me to make the call, though -- and to take the heat if I messed up. If I couldn't get off the fence, I'd go straight to the person who would be making the end judgement (local authority having jurisdiction) and explain my dilemma.
Sorry, but I've been doing this nigh on 30 years. The folks at UL will often give a hint or a suggestion to save me time (METLAB was good about that too). I've never bothered to ask them for a decision, though.
I would still suggest finding the authority in Singapore whose job is to accept or reject certifications. His or her answer would be the only one that is definitive beyond doubt.
Best to you,
Goober Dave
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