By Patrick Treadway, President, Syndesis LLC

“UL is a government agency” the supplier was trying to explain to me over the phone, “we don’t want to break a law,” he concluded. If anyone has been engaged in product development using offshore manufacturing long enough, he or she has likely heard similar remarks. Another comment heard is “Don’t worry, we’ll ship the product and rush the labels by air, you can just apply them there. This will save time”. Both of these comments, and others, represent at best huge misunderstandings about the role of safety testing and marking, especially for the North American market.

Underwriters Laboratory (UL) evolved from a need by insurance companies to have expert review of a site or product before agreeing to underwrite a policy. It is a private company, originally funded by an underwriter association and an insurance company. Over time it became increasingly self-funded through its project services and fees. UL representation on the Electrical Committee of the National Fire Protection Association (NFPA) lead to the writing of the National Electrical Code (NEC).

Today UL is a “defacto” standard for safety testing and compliance. Oversight of these companies, UL included, is performed by the Occupational Safety and Health Agency (OSHA). Competitors to UL such as Intertek and CSA, often refer to standards written by UL within their own services.

We know that inspectors in the field look for UL and other safety agency labels, but how did those labels get there? There are actually several paths to receiving authorization to mark, and it is important to understand them to gain the most value at the lowest cost while compressing your time to market. Rep Agencies, Builders, and owners should take equal interest as well since the path to marking can extend to and through the project site.

There are 4 basic UL marks typically seen on products. “RU” These are components that UL has reviewed and confirmed any criterial about their material composition and performance has been verified. Assembly line inspections often involve looking at the stock of parts to confirm they carry a RU mark. “Classified” This is usually a complete product, however UL has determined it can be used in very limited application, and under certain criteria or limitation. “Listed” These are products that are complete, and by “use” do not have any limitations. So an LED driver with certain voltage and output ratings can be used in a linear suspended fixture, or a High Bay. This use is up to the assembling factory. “Listed” devices or fixtures are not allowed for any and all possible uses in the field. Listed items must be used within ratings set by UL for location (wet, damp, dry…), heat and cold limits, electrical limits…etc. Inspectors on job sites are trained to look for changes or uses not written into fixture UL files.

Here are four paths toward proper UL completion labeling. They are:

• ODM > ML > to importer (traditional path)
• ODM> File Copy> OEM assy as ODM
• ODM> Location listing> OEM assy on behalf of ODM
• ODM> Partial Assy & inspect> Ship> OEM completes assy & inspect (split inspection)

In all of the above cases, it is important to keep the perspective of an extended assembly line, from inception thru final inspection. The goal of UL processes is to keep the end-to-end links documented and connected.

Among the more common paths by importers to getting a safety listing is to cooperate in what is called a “Multiple Listing” (ML) with the original design manufacturing factory (ODM) [See figure One below]. Manufacturing factories have their raw components and their assembly processes reviewed by UL, who then creates a Safety listing file for that location and product. An importer saves huge costs by creating their own model number and having it added to the factory UL file in an official cross-listing to the factory model. The pitfall here is the reliance on the original manufacturing company to not substitute components (and update the file) at their discretion. Costs, performance, supplier changes can all drive changes into the file and product. A company’s Product Development department, its Product Manager, or a third-party consultant can be very effective in documenting the approved components and features of newly listed products and thus help keep control through a product’s lifecycle.

Another path is referred to as “a file copy” [See figure two below]. In certain instances, factories and importers can agree for the factory to sell a copy of a portion, section, or entire UL file to an importer. This newly copied file becomes the importers UL file with their own unique file number, and the right to edit and update as needed. It is a fast way to get up to speed in manufacturing, build on the existing data, and shorten the amount of inspection a traditional factory setup requires. UL does send its team to these newly minted assembly sites and confirm all the appropriate mechanical and electrical tests needed are performed using qualified equipment and procedures. It is important to remember all the Safety Listing agencies do perform regular site inspections of assembly locations. It is very important to use experts who are knowledgeable in reading UL construction files and can confirm all the proper sub-sections needed for a complete file are identified ahead of file copy completion.

In some instances, there is a need to assemble production in a new location other than the original factory, however for various reasons, there may be no file copy or ML wanted [See figure three below]. An importer can arrange to be listed as a manufacturing site for an ODM who holds the original UL listing file. In this instance the concept is that this new location is treated as an extension of the ODM and subject to all the testing, labeling, and inspection criteria the ODM would have to perform as its original site. This can be an effective solution where companies agree to produce the same product in two locations to address a short-term need to build and assemble closer to a given market or project. Expert help can integrate the needs of the product assembly itself with the layout of the assembly sequence and physical line, as well as electrical tests to perform for final UL approval. Setting up an effective self-inspection record will save a lot of headaches during future UL site inspections.

 A last path to a complete UL listing is called “Split Inspection” [See figure four below]. It is somewhat similar in practice to the “assembly location” path, with key differences. The original factory assembles and tests a luminaire up to a certain point short of a completed and tested product. This partial assembly is safety inspected up to that point and it tagged as a partial assembly. These partial products are shipped to an importer who has a fully approved and inspected assembly line to take these partial products thru the final steps of assembly and testing. The result is that once completed, the product receives its final UL approval labels at the end of the importer’s production line. It can be advantageous to use this path for products that are exceptionally big or with multiple variations. Split inspected assembly can involve complicated packaging, labeling, test sequencing, ordering, kitting, and forecasting. Seeking expert help from consulting firms can smooth out product launches and head off any number of challenges.

About The Author

Pat Treadway is President of Syndesis LLC, a multi-dimensional business and product development consultancy for lighting, architecture, durable goods, and controls. More information is available at https://syndesis.net .

All images: Syndesis LLC

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