Re: UL/ETL Choking the market
- From: Thomas Paterson <t_p_paterson@xxxxxxxxxxx>
- Date: Sun, 24 Aug 2008 22:53:56 -0700 (PDT)
On Aug 22, 7:33 pm, phil-news-nos...@xxxxxxxx wrote:
On Wed, 30 Jul 2008 13:10:34 -0700 (PDT) Thomas Paterson <t_p_pater...@xxxxxxxxxxx> wrote:
| 1. UL codes are too restrictive because:
| a) They are based on perceived risk, rather than on analysis
| of real world data.
| b) They are prescriptive rather than performance based, ie,
| they almost define design solutions, rather than mandating safety
| levels.
If they mandate safety levels, it will take a LOT longer to do the tests
properly, because they would have to run the product over time to see if
it actually performs.
That's not how it works, due diligence and proper design analysis
covers most of it, they don't need to do tests for a lamp with a new
lamp shade. If they were doing a whole new control system, they would
need to test it, but they'd need to test it for reliability and
operations as well as for safety and the two can be done at once,
rather than having to outsource half of it to UL. And it's not really
outsourcing half - it's doubling the work, since many of the tests
will be redundant.
| c) They accumulate and are not retired or reviewed and eased
| often enough.
They should be made publically available for universal review. But I
am not inclined to weaken them. I see an abundance of lighting fixture
design and some of them I might consider risky. If anything, I might
be inclined to strength the requirements.
They are available for universal review - the question is not one of
weakening, it's a question of getting rid of restrictive elements that
don't contribute to safety, or things which are outdated by current
technology. Some should be strengthened, without a doubt! If
something is risky, but meets the specific requirements of code
(irrespective of where you are in the world), then due diligence on
the part of the manufacturer should see the design revised. Actually,
doing it under outside testing can give a false sense of security, if
the testing agency responds that it meets the test criteria, the other
aspect that is risky, may go unnoticed, although I'd say this is less
likely than it being caught and commented on even if outside of code
scope.
| d) They protect the US market from foreign imports, but also
| prevent export by requiring over-engineering which makes the fixtures
| unappealing to foreign buyers.
False. Foreign manufacturers can have products tested, too. And US
manufacturers can make (overseas, where labor is dirt cheap) products
and sell overseas without concern from UL.
Yes, they can have them tested, but it is a huge cost when in their
first few years entering the US market, they will have no sales to
cover the cost of testing. The barrier is economic, rather than
anything else. Also, because the constructional requirements are
significantly different, they have to re-engineering their products,
retool their product lines, etcetera - it functions as a barrier.
| 2. UL as an organization is a business, not a government agency, as
| such, they make money from testing, the more rigorous the testing
| requirements, the more money they make. As such, they have a conflict
| of interests in reviewing, reducing, reforming codes in ways which
| reduce the UL burden.
They seem to be operating fine in my interests.
I'm glad you're happy.
Would you be willing to bet your life on your products' safety?
What I mean is, if your product is found to be unsafe after it is
on the market, we can come take all your finances and property,
fully immune from any bankruptcy protection, and throw you in jail
for the remainder of your life. If you can do that, I'd consider
your products without a UL test. Of course you have to remain in
the US for the rest of your life to ensure this can be enforced in
the future.
I would be willing to bet my life on product safety in many other
countries. Europe has no major problem with fires, electrocution or
other problems due to their code systems. Nor do Australia, New
Zealand, or many other countries. The point is not that some things
don't need to be tested, for example, I've attended Standards
Australia's testing labs in Adelaide to watch "critical short testing"
for distribution panel enclosures, but that a lot of things don't need
to be.
I'm not sure that I understand what you're saying about this
punishment business - what does UL have to do with business
liability? If I sell a dodgy product, I'm liable. That has nothing
to do with testing. If it fails and kills someone, irrespective of
the stickers on it, if it was a design or manufacturing fault, I'm
liable. Also, most product failures are manufacturing management
related rather than design related, statistically speaking, so testing
of the first run doesn't tell you anything about the performance of
later products if the fault is in its construction/assembly.
| 3. There are a range of international codes that could be adopted or
| borrowed. ISO standardizes many things, but is not complete. CE is
| Europe specific, but is much more sensible and there is no financial
| interest the codes, so they are rational. Historically, there were
| British Standards, which form the basis of Australian Standards, NZ
| Standards. BS is now absorbing CE and ISO, so everything is
| converging, except in the US.
A lot of these standards are not written for how the US does things,
for example the electrical voltage.
That's easy to change - that's just a performance criteria, but has
little to do with safety. To state that a system must operate fault
free at line voltage +_10% doesn't matter whether it is at 110V or
220V so long as it is built for the market it is sold in. I don't see
how this is relevant to the structure of the code system, it is merely
a matter of localization of code.
| 5. Most of the rest of the world does not require testing.
Third world countries?
Europe, Australia, New Zealand, plus many others.
| Manufacturers assume liability for compliance when they put the
| stickers on their products. If their product breaches code
| requirements or is otherwise a safety hazard (a breach of the legal
| principle of due diligence), they are liable for the products.
In a lot of those countries, their legal system is not slanted in
favor of corporations. In the USA it is, so this would not be a
suitable protection.
I'm not sure that Ford would agree with you after their little pinto
mistake, etc. Design faults are traceable and demonstrable. Anyway,
the legal system would take the same view whether a product obeyed CE
or UL, irrespective of the testing procedures - if the product caused
a foreseeable or preventable danger and the corporation failed to act,
they would be liable. If the corporation self certifies under CE, it
still can test if it needs to have the assurance, it can just do it
under any appropriate testing regime to answer their specific doubts,
rather than through a small group of agencies that apply all tests,
irrespective of whether they are necessary (and charge accordingly).
The US is considered particularly litigious and most people consider
it to favor the little guy, irrespective of the rationality - most
famous is the Liebeck Vs McDonalds case, and while most judges aren't
so silly, there is a lot of successful legal action in the States.
| As such, they don't spend time engineering to jump through other
| people's hoops, but engineer the best product and are responsible for
| quality. This works just fine for most of the rest of the world.
| And, if they want to have the device or item tested, that's their
| prerogative and it's encouraged. There are plenty of labs out there.
Do you have specific examples?
Specific examples of what? Testing laboratories? Products that are
self certified? Damn near everything on the European market, most
downlights, most table lamps, most floor lamps, etcetera. The wiring
meets code requirements, the electronics has been tested, if you
change the reflector, do you really need to test tha the wiring meets
code? In the States, yes! Sure, it can be a variation of a standard
product, but you still have to have design analysis and some testing
done by UL!
As to the labs, my mother works in certifying Australian laboratories
as meeting international standards, so yes, I'm aware of lots of good
labs or could find out where they are.
| I agree with your point about the question of how much safety is
| enough safety, but when it comes to electrical devices, the public
| don't need to see it, don't need to know. The advantage of UL or CE
| is that if it has that stamp, the client assumes it is ok. We need
Without the stamp, I won't know if it is OK. That applies to UL but
not to CE.
Why not? Because you doubt the force of law in Europe? Because you
think that European companies sell lights they don't feel are safe?
Because you think that people put CE stamps on lights that don't meet
CE? They'd be doubly vulnerable if they did that - to be sued and to
be criminally liable! What are you saying?
I don't trust you. So if you self-stamp, no trust is established.
That's fine, I don't sell products, but you could always contact a
manufacturer's references, check legal databases etc, if you really
need to. CE is a good certification scheme that most lighting
professionals around Europe wouldn't question because it is highly
reliable. Breaches are published, so it's easy to find out which
companies don't meet the requirements but claim to. Assuming they're
still in business after being fined and the directors potentially
jailed for fraud.
| France has particularly tough material safety requirements with regard
| to fire. However, to pass them, you need to be able to demonstrate
| that your product won't combust when touched with a 960?C hot wire for
| a given period of time. It's performance based, doesn't define
| acceptable materials, etcetera. That's how to write codes.
That's an overly simplistic test. One specific temperature is not good
enough. A wide range of temperatures with corresponding times would be
needed. The list of materials are materials that have already been
tested and are well understood. If you have a new material, submit it
for classification.
Actually, that's the highest temperature that products are likely to
meet and if it doesn't ignite after a certain period of time, it won't
at lower temperatures within normal fire conditions - ie, it meets a
90 minute rule or whatever it is required to meet to ensure that the
light will continue to function until the building is evacuated.
France doesn't have a problem with luminaires igniting, so it seems to
be a good enough test.
| The other point I'd make is simply to look at the anecdotal evidence -
| look at the number of US lighting products used outside of the States
| (virtually none other than lamps) and the relative scale, variation
| and creativity of Lightfair relative to Light and Build. It's 1:10
| difference in number of manufacturers, etc, in a market which is only
| slightly larger.
Lights in the USA seem to be mostly safe. I've seen a few questionable lights.
I'd worry more outside the USA.
Have you actually worked in a CE, AS or NZS certified country? Does
it seem that these countries are suffering a lot of fires,
electrocutions or other problems?
I've answered your responses, but to be honest, I get the impression
that your response is emotional more than technical. I'm glad you
feel safe in the US with UL certified products, but it's a matter of
actually working in other standards systems to understand what is
involved before you can write them off - the fact is that they work,
and work well. Ideas on how a system might work are one thing, but
the outputs of a system are the best measure of whether it works. The
systems you're criticizing do work, so the question is, do they work
better, worse, or what are their strengths or weaknesses - I'd contend
that the UL system works, but its weaknesses are substantial, costly
and unnecessary. That's my point. I think the US system could work
so much better and I'm agitating a little for consideration of the
possibilities.
Thomas
.
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