Re: UL/ETL Choking the market

On Aug 1, 10:19 am, "TKM" <nom...@xxxxxx> wrote:
"Jeff Engel" <searcher...@xxxxxxxxxxx> wrote in message

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Willy wrote:
"Jeff Engel" <searcher...@xxxxxxxxxxx> wrote in message
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Thomas Paterson wrote:
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.
UL has outlived its usefulness.  When factory production of electrical
products was in its infancy, the casualty insurance underwriters found
cause to come together in establishing safety standards.  UL protected
insurers from faulty and risky products.  Now the concerns for fault and
risk have evolved toward product liability.  So essentially,
manufacturers pay twice: once to UL for a certification of compliance,
and second for liability legalities, and tort claims.  Liability
exposure alone would serve as a deterrent against inherently dangerous
products. Underwriters Laboratories would disagree on a philosophical
basis, but it seems that the issue of risk management is now in the
hands of liability lawyers, not white lab coat guys.  Large
manufacturers can afford to continue to pay tribute to the
"not-for-profit" UL juggernaut, and it might be a fairly cheap
reassurance that safety is certified.  But in reality it is vigilance
against liability that drives safety implementation.  If there was a
continuing viable function for Underwriters Laboratories, the costs
would still be absorbed by insurance companies who would be the direct
beneficiaries.  UL is currently in the business of being UL.  The best
recent evidence of their need to promote themselves came when LED
technology first got hot in the market.  UL went from a "no need to
regulate" stance to a "we gotta get in the game" stance real suddenly..
What would happen if LEDs came into the country before UL had a chance
to pontificate? Free, unhindered enterprise?  Not too likely with UL on
watch!

AS an outsider that has been reading this thread since Tom started it, I
have one question.

As I understand it, UL is completely voluntary.

If that is actually true, why wouldn't a manufacturer choose to step away
from UL approval?  Is it purely a liability issue?

Willy
Commercial building projects are inspected during construction for safety,
and UL is the de facto mandatory standard.  Some inspectors will not
approve ETL rated fixtures without a big brouhaha about equivalence.
So UL/ETL listing is not really optional.  Without ETL, UL would almost be
a monopoly, and a "not-for-profit" monopoly at that!  The status quo is so
long established that the lighting and electrical products industry can
only pay homage to the Elephant in the room. What Mr. Patterson and i are
pointing out is that UL is expensive and inflexible.
For example: a desirable designed wall scone that is UL approved is needed
with a switch on the body rather than being hard wired. Can the
manufacturer make a batch with this very simple starightforward
modification? NO! UL approval will be needed for the variation. And what
will that add to the cost of the fixture? WAY TOO MUCH, forcing the
specifier to re-select a less desirable fixture.  Do the mega-major
industrial conglomerates worry about this?  No need to, since they have
the UL process running "in-house".  But for a small innovator to get the
approval needed for a one time sale, the waiting and cost are prohibitive.

This last comment sounds like an opportunty for the small labs to provide
"in-house services" to the smaller manufacturers.  It's puzzling that the
smaller labs also seem to charge the same as U.L. or ETL for testing
services.  Since they don't develop standards and have that additional staff
cost overhead, why aren't their rates substantially less?

One thing that has happened in recent years is that U.L. has increased
competition.  CSA and ETL plus other smaller labs advertise themselves
(correctly) as being able to test and mark lighting equipment to the same
standards as U.L. Obviously, U.L. is not going to promote this; but why
don't the others?  I agree that many local building/electrical inspectors
still think that U.L. has some kind of singular or official standing; but
that notion is changing too according to the manufacturers that I talk with.

Terry McGowan- Hide quoted text -

- Show quoted text -

Your earlier comments on the start of UL reminded me of another force
for them. Insurance companies! I have heard some policies have some
pretty forcefull language. Unfortunately I don't have any examples to
quote. Anyone else?

-------
RickR
.

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