CFL Use in hazardous rated incandescent fixtures

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from Appleton

"Hi Bill,

Thank you for contacting Appleton Technical Services.

We do not recommend replacing CFL bulbs on our Incandescent Type Fixtures. One reason is the fixtures are specifically designed to take the incandescent bulb and these fixtures are not tested to accommodate CFL.

Also you will void the UL Listing of the fixture once any of the components is altered.

We do offer CFL type Lighting Fixture, please click on the link I provided for your reference.

Mercmaster III Low Profile:

http://www.appletonelec.com/pdf/AEC_MC007_Mercmaster_III_Low_Profile_Compact_Fluorescent_Luminaires[1].pdf

Code Master PLT Factory Sealed Luminaires:

http://www.appletonelec.com/pdf/AEC...Emergency_PLT_Factory_Sealed_Luminaires_01-11[1].pdf

Code Master 2 Emergency PLT Factory Sealed Luminaires

http://www.appletonelec.com/pdf/AEC_MC007_Code_Master_2_Emergency_PLT_Factory_Sealed_Luminaires[1].pdf



If you have additional technical question, please feel free to contact us again and we will be glad to assist you.

Regards,

Ram Santiago | Technical Support Engineer | EGS - Electrical Construction Materials | Emerson Industrial Automation

Please use the following for future correspondence:

Toll-free: 1- 800-727-5102

Appleton: appleton.technicalservices@emerson.com

O-Z/Gedney: ozgedney.technicalservices@emerson.com

McGill: mcgill.technicalservices@emerson.com"
 
I thank all for their participation in this thread.

Natfuel was exceedingly brief in his post, and at first take it appeared that he was presenting himself as the UL person whose contact information was presented. I suggest that quotation marks and other conventions of grammar be used in the future. For example:

"Fourscore and seven years ago," (A Lincoln).

This differs somewhat from my ending this post with a simple listing of a name and contact information.

Requests have been made that I provide my source, and I shall look for a link.

Be Well.



Barak Obama
1600 Pennsylvania Ave.
Washington D.C.
 
This is what the current 2010 Whitebook says with reference to Category Code OOLR:

LAMPS, SELF-BALLASTED AND LAMP
ADAPTERS (OOLR)​

USE AND INSTALLATION
This category covers self-ballasted lamps consisting of a ballast, transformer
or power supply, and an integrated or replaceable lamp, for direct
connection to a lampholder. Products in this category employ various lamp
technologies including, but not limited to, fluorescent lamps and highintensity-
discharge (HID) lamps. Devices with an integral lamp are termed
‘‘self-ballasted’’; devices with a replaceable lamp are termed ‘‘adapters.’’
These products are intended for connection to lampholders for outlet
boxes and lampholders provided in luminaires, portable luminaires and
signs. The point-of-supply connection (the lamp base for these products) can
be an Edison screw-type, as well as GU24 and other ANSI lamp bases. The
base configurations are covered in ANSI_ANSLG C81.61, ‘‘American
National Standard for Electrical Lamp Bases – Specifications for Bases
(Caps) for Electric Lamps.’’ These products are intended for operation at the
voltage marked on the product.
These products are generally for use in indoor, dry locations unless additionally
investigated and marked for applications such as damp locations
(not directly exposed to water). Products investigated and marked for wet
locations may have additional restrictions regarding use or orientation.
These products have been investigated for use in the smaller of a 6- or
8-in. diameter recessed luminaire, if they will physically fit, and are
intended for use in totally enclosed, recessed luminaires unless marked and
stated not for such use.
These products are not intended for use in emergency lighting equipment
or exit fixtures where brightness is a factor
Click to expand...
The bold text is mine.

If you do not believe this is consistent with the document you cited, then I suggest this is the preferred reference and reflects the actual UL position.

However, if you believe this is consistent with the document you cited, then I point out neither citation grants a general replacement of incandescent lamps with CFLs - even if they fit. Both documents still require specific investigation and marking for any application other than “indoor, dry locations.”

You can draw whatever conclusion you wish about hazardous location applications.

BTW, I didn't and wouldn't accuse you making anything up. I do believe you may have misunderstood your source.
 
It's fair to ask someone to substantiate their position, especially when another source is referred to.

I also suspect that this may be one of those areas where different folks may reach different positions with the best of intentions.

If the inside of a sealed fixture isn't 'indoor' and 'dry,' I know not what is.

I maintain that it is unrealistic to expect every fixture to be separately tested with every possible variation of replacement bulb. The CFL's are designed / intended to replace type-A incandescents (which, btw, includes several types of bulbs, including the much hotter halogen). As I see it, a suitable replacement is but a suitable replacement.

Just what is a 'type A' bulb? As best I can tell, the designation depicts a more-or-less balloon shape with an Edison base. I don't see any specification as to how the light gets bright. The only question is whether a 'spring-shape' CFL is close enough to a 'balloon shape' to comply.

I'll also repeat my earlier point: what's the worst that can happen? What can possibly go wrong? Knowing just what is involved in the testing of these fixtures, I cannot see any possible increase in risk. After all, the fixture is specifically designed to contain the worst possible explosion.

Likewise, I categorically reject any assertion that screwing in a light bulb is 'modifying' a fixture. Those lovely manufacturer statements were just fancy ways to not answer the question.

To be fair, I am personally aware of the extensive amount of debate this topic has caused within the halls of UL. It is my observation that there is a fair amount of internal politicing within UL as to WHO can speak on the issue- far more than what the technical answer might be. The institution, for all its' virtues, is notably ill-suited to stating any general principles derived from their own data.

Make your own inferences? Absolutely .... at some point the buck can no longer be passed around, and we cannot hide behind the skirts of "UL," or "the Code," or anything else.
 
Let me clarify something – Division 1, explosionproof luminaires are NOT sealed. Some Division 2 luminaires ARE sealed but they are NOT explosionproof.
 
I understand your point: "Explosion proof" devices often are designed for the controlled venting of the high pressures that result from an internal explosion.

It's really not an issue, though. If the fixture is listed for use in a wet location, within the fixture can't help but be a dry location. You're sure not going to see the "NEMA 3R" rating maintained by the use of drain holes, are you?

If it's not listed for a wet location, it's a problem regardless of what bulb you use.
 
Before 2004, the Whitebook was laid out under three ?super? Category Codes: Electrical Equipment for Use in Ordinary Locations (AALZ), Equipment for Use in and Relating to Class I, II and III, Division 1 and 2 Hazardous Locations (AAIZ) and Equipment for Use in and Relating to Class I, Zone 0, 1 and 2 Hazardous Locations (AANZ).

The three ?super? Category Codes still exist, but it is more difficult to recognize it since the Whitebook is now laid out in strict Category Code, alphabetical order; however, with rare exception, subsequent Category Codes in their Section ADDITIONAL INFORMATION, will refer back to one of the ?super? Category Codes; e.g., Category Code OOLR refers back to AALZ. Also note the ?super? Category Codes do not refer to each other, so none is subordinate to another.

By UL usage, ordinary locations are ?dry,? ?damp? and ?wet.? (See Section INSTALLATION REQUIREMENTS IN Category Code AALZ) The OP references ?Hazardous Locations,? which is neither covered by Category Codes OOLR nor AALZ.

The question is not whether CFLs should be permitted as universal replacements for incandescent lamps or not, rather it is are they permitted to under current UL primary documents? Without simply asserting they should be, the answer is ?No.?

You have not even made the case yet that they can be used as direct replacements in ?wet locations? let alone ?hazardous ones? an entirely different class of Category Codes.
 
Bob - you are my hero!

Does UL only act inspecting equipment submitted by manufacturers? If I were (I'm not) a manufacturer the very last thing I would do is request an UL evaluation of a CFL (or LED) lamp in my labeled incandescent fixture. To do so would be akin to driving demand for replacement fixtures down. This especially true with the GWBush law outlawing incandescents in 2012.

Or am I green behind the ears of the UL/manufacturer relationship?

Please comment.
 
The motto of UL is "Testing For Public Safety." I do not see in that motto any consideration of whatever 'business model' a manufacturer might have. I'm certainly not going to infer any collusion between UL and manufacturers to 'drive up the demand for replacement fixtures.'

Supercategory? What silliness is that? An explosion-proof fixture has to meet requirements for the environment - and those go beyond simply whether it's rated for the hazardous location. That is, an outdoor fixture also has to meet outdoor requirements, in addition to haz loc requirements. Having a haz. loc. rating has zero relevance as to the weather rating.

The UL statement clearly says CFL's are fine for use in totally enclosed fixtures unless marked otherwise. It's safe to say that every haz. loc. fixture is totally enclosed. Wet locations? The inside of an enclosed fixture is by definition a dry location; even an ordinary light bulb will not fare well in a 'wet' location.

Again, the UL statement I linked to clearly states that the CFL can be used, provided markings on the CFL are complied with. I'll restate that in different words: regardless of what the sticker in the fixture says about "type A" bulbs, you can use a CFL- inless the CFL (not the fixture) says differently. I'd say the UL statement 'made the case' quite well.

There's a spider in this woodpile, though. Notice the statements about markings on CFL's? This ought to alert you to the fact that not all CFL's are the same. One can use the 'wrong' CFL. Note that such use is determined by the bulb, though, and not the fixture.

Issue settled? Even if it were- so what? We get to do it all over again next week with LED's. :)
 
renosteinke said:
The motto of UL is "Testing For Public Safety." I do not see in that motto any consideration of whatever 'business model' a manufacturer might have. I'm certainly not going to infer any collusion between UL and manufacturers to 'drive up the demand for replacement fixtures.'
Click to expand...

I agree that no one is trying to infer collusion. That would be iNsAnE!!

Your missing my point.
I believe that UL does not go out on their own to test equipment that has not otherwise been submitted to UL.

I understand the process is only:
Manufacturers submit to UL
UL inspects and test
UL passes or fails the test
Manufacturer can enjoy the benifits of a UL labeled device
right?
 
I never worked for a testing laboratory but did work at a company that obtained listings for equipment that was intended to be used in hazardous locations. Listing is time consuming and expensive. Product liability drives many listing decisions, so the testing labs tend to be conservative.

To get a product listed by any recognized testing laboratory, you must submit the product as well as a listing of all components, and specify what standard(s), and there are always many to choose from, that the product will be tested to. Testing to a standard usually involves a number of separate tests that address multiple scenarios of component failure and operating conditions. Apparently "trivial" changes can affect the outcome. You typically must demonstrate adequate quality control to be certain that what is listed is exactly what gets sold.

If a product successfully passes all of the applicable test(s), it can be listed. Change any component and the listing is void. The tests may be extensive, take significant time to schedule and complete, and are ALWAYS expensive. All testing costs are paid by the manufacturer. It is simple economics...every variation to be considered will add cost - likely a lot. Worse, if any of the tests are failed, you start again after redesign, etc. Manufacturers do not casually submit every conceivable combination unless they perceive a large enough market to justify the expense.
 
renosteinke said:
The motto of UL is "Testing For Public Safety." I do not see in that motto any consideration of whatever 'business model' a manufacturer might have. I'm certainly not going to infer any collusion between UL and manufacturers to 'drive up the demand for replacement fixtures.'

Supercategory? What silliness is that? An explosion-proof fixture has to meet requirements for the environment - and those go beyond simply whether it's rated for the hazardous location. That is, an outdoor fixture also has to meet outdoor requirements, in addition to haz loc requirements. Having a haz. loc. rating has zero relevance as to the weather rating.

The UL statement clearly says CFL's are fine for use in totally enclosed fixtures unless marked otherwise. It's safe to say that every haz. loc. fixture is totally enclosed. Wet locations? The inside of an enclosed fixture is by definition a dry location; even an ordinary light bulb will not fare well in a 'wet' location.

Again, the UL statement I linked to clearly states that the CFL can be used, provided markings on the CFL are complied with. I'll restate that in different words: regardless of what the sticker in the fixture says about "type A" bulbs, you can use a CFL- inless the CFL (not the fixture) says differently. I'd say the UL statement 'made the case' quite well.

There's a spider in this woodpile, though. Notice the statements about markings on CFL's? This ought to alert you to the fact that not all CFL's are the same. One can use the 'wrong' CFL. Note that such use is determined by the bulb, though, and not the fixture.

Issue settled? Even if it were- so what? We get to do it all over again next week with LED's. :)
Click to expand...

OK game is over. You have taken to present arguments - and ignoring comments - that I am now convinced to be the evidence that this was just a silly rouse by you, and you're just yanking everybody's chain. I am surprised you were able to drag us so far....;)
 
Though testing of customer-provided samples is the 'meat and potatoes' of UL, the firm does do a fair amount of 'other' testing.

Some of this testing is funded by various trade groups and government programs. For example, not very long ago UL participated in a study of the performance of old electrical equipment in old homes.

Other testing is performed as their own 'research,' and is done in furtherance of their own standards, test procedures, etc. Many of the 'industry standard' tests were developed within UL, and only later recognized as ANSI or ASTM methods. A classic example of this was Mr. Ufer's work on the concrete-encased electrode.

Apart from listing complete products, UL lists, classifies, and recognizes various components intended for use together with other listed products. To remain on-point with this topic, it would be unrealistic to expect exery fixture to be tested with every possiblelight bulb - despite possible assertions by Sylvania that their bulb is somehow different from GE's. Etc.

This whole dispute arose because we found a newway to make a light bulb. The question UL had to addresswas whether this new bulb was acceptable as a replacement for the old bulb- taking into consideration whatever differences there might be. Most obvious was that this new bulb sure doesn't look likea 'type A' bulb. Indeed, in many cases the CFL is a lot larger than the bulb it's replacing.

UL had to address that question. I have posted UL's response. In simple terms, if it fits, it's fine. [Return to the link if you wish to examine the various qualifiers].

As for the statements from the various fixture manufacturers: This is not the first time that there has been a difference of opinion between UL and manufacturers. Remember the stink Square D raised when UL 'classified' other manufacturers' breakers for use in Square D panels?

Given a difference of opinion between UL and a manufacturer, I am personally biased in favor of UL. Others are free to form thier opinions. As for some idea that I have been dishonest in my arguments, I can only point out that every statement of mine goes right back to that UL "Question Corner" article. Anyone who has a problem with UL's opinion is encouraged to 'go to the source' and take it up with UL. [Let us know how that turns out].

Everyone is free -even expected- to make their own judgement calls. Those in 'AHJ' positions have the further restrictions of law to contend with. In this instance, common law would restrain them from taking anything but the most accomodating position. "Benefit of the doubt" and all that.
 
renosteinke said:
To remain on-point with this topic, it would be unrealistic to expect exery fixture to be tested with every possiblelight bulb - despite possible assertions by Sylvania that their bulb is somehow different from GE's. Etc.

This whole dispute arose because we found a newway to make a light bulb.
Click to expand...

Trying to say that the difference between a CFL and a incandescent it replaces is not greater than the difference between two 60 watt A-19s of different brands is ridiculous.

So far I have seen very little to support your view other than your own opinion.
 
Negative personal experience isn't much to go by. You can ask a question about anything safety related (GFCI, AFCI, grounding conductors, and so on) and before you ask more than two people, someone is likely to say "That is all BS and absolutely not required - I never saw/heard of..."

And the use of CFLs in any quantity is fairly recent. I've used them since they became available and am pretty satisfied so far, except for what early on looked like a LOT of infant mortality.

I would be surprised if there is an issue substituting CFLs for incandescents in a hazardous area fixture, but I have been surprised before.
 
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