Re: UL/ETL Choking the market
- From: "TKM" <nomail@xxxxxx>
- Date: Wed, 30 Jul 2008 20:42:08 GMT
"Thomas Paterson" <t_p_paterson@xxxxxxxxxxx> wrote in message
news:229621e1-323d-4c33-b12b-d775f31b1fbe@xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Dear All,
As a lighting designer with a lot of experience outside the US market
as well as within, I have a very low opinion of UL, not only its
implementation but also its fundamental logic for existence and
methods of development. I will refer to UL, but also mean its
competitors, ETL, etcetera.
In most of the world, standards are written to require manufacturers,
constructors, designers, all responsible parties, to meet minimum
standards ensuring real safety. The codes are written to restrict
design freedom the least possible, with descriptive, performance based
requirements. The codes enforced by UL, on the other hand, are highly
construction based, restrict potential design solutions to problems
and address perceived risk rather than real risk. One example of this
last point is the back housings on every US downlight. If a full back
housing was really necessary, Europe (which has nothing of the sort)
would have burned down many times over.
In practice, UL functions in a few ways. First, it restricts design
innovation. The cost of bringing a product to market, of having it
tested, prohibits manufacturers experimenting with new fixture
typologies, evolved aesthetics and innovative design solutions - an
assured market is required before it is worth the cost of testing.
This can be seen in the difference between Lightfair (one large
exhibition hall) and Light and Build, with over a dozen major halls.
It costs construction clients enormously. For example, where a
Lucifer Lighting downlight in the US costs (of order) US$200, its
European version (sans backbox, but with all required for safe and
functional installation) just under $100. So this is not something
without cost, this is costing the construction industry and their
clients massively.
It delays the development of custom luminaires, which is a huge issue
for fast-track projects, most notably retail, part of the market that
drives the economy.
It is supported by the electrical unions as their on-site electricians
refuse to install non-UL fixtures, to ensure that their union
colleagues retain their jobs in factories. I am a supporter of
unions, but I think that they would be better off in the long term
with a more dynamic, vibrant business environment with a growing
lighting export industry than a heavily defended industry hemorrhaging
jobs to the far east.
UL has become such a monster that they hired nothing less than the
entire facade of the Luxor hotel in Las Vegas for a sign stating that
"UL is... SAFETY".
What I want to do is start sounding out industry professionals to see
if there is enough interest in pushing for a restructuring of the
codes enforced by UL. A code which is based on international codes,
and reinforced where DEMONSTRABLE risks exist would be much more
sensible. But what would this mean for the US lighting manufacturing
industry?
Well, that's where things get complicated. UL also acts as a massive
trade barrier. A foreign manufacturer wanting to export to the US has
to re-engineer their products to meet UL requirements, pay for the re-
engineering, re-tooling, certification, etcetera and only then can it
start marketing its products. So dropping UL would drop a massive
protection for the US market. Of course, with the Dutch Philips
rapidly buying up the market, that might not appear to be an issue,
but of course, it is.
But. UL has also become a massive drag on the US market. Back boxes,
for example, require a lot of labor and materials in their
construction. We now see Chinese manufacturers who can carry out
these operations faster and far cheaper, can now amortize the costs of
UL across a container or two of commodity luminaires, and still sell
cheaper than anything built in the US. Now UL requires more labor,
more materials, more storage, in total, more costs and against Chinese
and other low cost manufacturing environments, the only way to compete
is to minimize these elements. So although in the short term, an
influx of European luminaires would be a blow to the industry, it
would be temporary adjustment pain, where maintaining existing codes
are leading to a long, drawn out struggle against a stronger
manufacturing environment. What could defend against low cost mass
production? Design innovation.
Also, once markets have come into conformance, innovative US products
would be able to compete in the wider market without the costs of
reengineering or the inability to innovate within the local market.
Imagine opening up the world market for the products that the US
excels at!
Risk assessment is always difficult. The temptation is always there
to restrict perceived risk, however, the lighting industry is a very
mature industry with massive exposure. The whole world is our
actuarial table, where people are dying or being hurt by a hole in
standards, it is visible with simple statistical analysis and it is
possible to tighten codes. Where there is no statistical issue
demonstrable, why should we have a code to restrict design? A little
analysis of the backbox issue, for example, would reveal that they are
not necessary, because we can look at a population of over 400m
people, totaling billions of luminaires, without a statistically
significant rate of death.
Ultimately, UL benefits a few, but hurts the majority of the market,
it reduces design innovation (a cost against quality of life as well
as the market), costs a vast amount of money, drags fast projects, and
contributes little.
Is there an appetite amongst design professionals to start a letter
writing campaign on this one? What is the feeling in the wider
community?
Thomas.
Thomas has given us a good bit to think about.
As part of a client consulting contract, I serve on three UL Standards
Technical Panels (STPs). The STPs are the committees that write the UL
standards. I've been part of the process for about 5 years now.
But, since I don't work for U.L., and STP membership is a non-paying
volunteer position, I am interested in how the system might work better,
take less time, cost less and better serve the needs of the lighting
industry as well as users of the products.
So, to add to the discussion, let me start with a few observations:
- Fire and electrical safety are the main objectives for U.L. lighting
standards. The sense (while not stated) is that you can't ever have enough
of either
- U.L. is a not-for-profit organization. In most other countries its
functions are handled by government departments.
- Product testing and standards development costs are paid virtually 100%
by customers, mostly manufacturers, via consulting and testing fees.
Luminaire
manufacturers, therefore, have a strong incentive to keep these costs low
and to react
promptly to any changes in standards which increase costs.
- Membership on the U.L. Standards Technical Panels is open and U.L., from
my experience, works to keep the STPs balanced and representative of
manufacturers, users and designers with a stake in the products involved.
The STP panel for UL1838 (Low Voltage Landscape Lighting Systems), for
example, has two of the top U.S. landscape lighting designers as members.
- The main lighting STPs (UL1598 - Luminaires and UL 153 - Portable
Electric
Luminaires) both have several manufacturers as members. Some are small
manufacturers; others represent the large consolidated brands. Usually the
committee members are technical or product engineering people, not luminaire
designers, and not from product management or marketing. In STP meetings or
discussions,
usually the cost and manufacturing viewpoints are front and center.
Sometimes design is brought in; but the discussions focus on products which
exist in physical form, not design or conceptual drawings.
-U.L. and CSA (Canadian Standards Association) are the two North American
organizations primarily involved in standards development. There are other
testing laboratories that test to U.L. or CSA standards and which can apply
their own marks to products; but which do not develop standards.
-Both U.L. and CSA have supported "harmonized" standards. UL1598, for
example, is virtually the same in the U.S. and Canada and efforts are
underway to make it a tri-national standard with Mexico. There's a gradual
movement to harmonize North American with European standards as well.
Thomas, It isn't clear to me that North American standards are more
restrictive than European standards. In fact, in a couple of specific
situations, I've found the reverse. But they are different and sometimes
the philosophy behind the standard is different too.
Your idea that "U.L. "restricts design" doesn't follow from what I see in
the U.L. STPs where the manufacturers themselves have the power to object
and vote on proposals that seem unfair, raise costs or call for unnecessary
overdesign.
Terry McGowan
.
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