Installation instructions are considered to be a part of the UL Listing.

[iwire]

A member sent me this document from UL and it seems ULs position is all instructions are part of the listing of the product.

Think about that, all instructions.

So when I buy a dishwasher and the instructions tell me to always use "Brand X soap" I must use that soap or be in violation of 110.3(B).

IMO they are overstepping their boundaries and I wonder how you all think?

Q Are the installation instructions
part of the UL Listing?
Are all Listed products required
to have installation instructions?
Are installation instructions
reviewed by UL?



A Installation instructions
are considered to be a
part of the UL Listing.
The UL Standards for Safety used
to investigate products contain
specific requirements regarding
the content and appearance of the
instructions. Installation instructions
are not required to be
marked with the UL Mark, but
they are required to be provided
with the product bearing the UL
Mark. Some products are not required
to have installation instructions
when the National
Electrical Code contains all the
necessary installation requirements,
such as outlet boxes.
UL staff reviews the instructions,
both during the initial evaluation of
the product, as well as during the
continual Follow-Up Service at the
factories. The clarity of the instructions
is also reviewed.
The special UL meetings for government inspectors

 

[iwire]

OK, maybe the soap example is stretching things, but here is a randomly chosen dishwasher instruction manual.

http://www.geappliances.ca/images/english/pdfs/206c1559p101en.pdf


Here is just a sampling from that.

Check that door spring does not contact water
line, fill hose, wiring or other components. See
Step 13.

Verify water supply and drain lines are not kinked
or in contact with other components. Contact with
motor or dishwasher frame could cause noise. See
Steps 6 and 8.

Turn on the sink hot water faucet and verify water
temperature. Incoming water temperature must
be between 120?F and 150?F. A minimum of 120?F
temperature is required for best wash performance.
See “Prepare Hot Water Line,” page 5.

Add 2 quarts of water to the bottom of the
dishwasher to lubricate the pump seal.

Turn on water supply. Check for leaks. Tighten
connections if needed.

Remove protective film if present from the control
panel and door.

No Mr inspector, I did not add 2 quarts of water to the bottom of the
dishwasher to lubricate the pump seal, I will try to be better next time.

 

[cpal]

good morning Bob

where you going here?

 

[mcclary's electrical]

A member sent me this document from UL and it seems ULs position is all instructions are part of the listing of the product.

Think about that, all instructions.

So when I buy a dishwasher and the instructions tell me to always use "Brand X soap" I must use that soap or be in violation of 110.3(B).

IMO they are overstepping their boundaries and I wonder how you all think?

They are a little too strict on installation instructions. One example is on a container on noalox. It says to work the nolox in with emory cloth. How many people do that? I try to when I have time, but admittingly, I have skipped that step before. So what I do is tear the labels off my nolox, so an inspector won't pick it up and read it and then question if I did that, and secondly, don't leave any packing instructions laying around that someone could pick up and read.

 

[Volta]

Difficult for us as installers to tell if the instructions included in the packaging match precisely the "instructions included in the listing and labeling".

IMO, if the packaged instructions differ, 110.3(B) does not require us to follow them, but how could we tell?

And who installed that DW anyway? The appliance tech.? The plumber?

 

[RICK NAPIER]

Here we try to enforce requirements listed iin the installation quides and not enforce the sections of the quides that say recommended.

 

[don_resqcapt19]

I have seen that document before and I will say what I always say about this issue. As long as UL has classified breakers that they say can be used in violation of the panel manufacturers instructions, I do not accept their statement.

I have a P&S receptacle in front of me that has the following included in the installation instructions that are printed on the side of the box:
"Install device in a wall box using mounting screws provided". If we apply the UL statement then this receptacle can only be installed in a wall box. Does UL and the manufacturer really intend to prohibit all other installations of this receptacle?

It is my opinion that the only enforceable 110.3(B) instructions are those found in the White Book. If the rule is not in the White Book, it was not part of the listing and labeling.

 

[jimport]

I think Don's approach is much more reasonable. I don't really think it is practical, nor should it be necessary for someone to have to read an instruction manual that describes the testing procedure.

In the example given by Don I could not use longer screws than the ones provided to adjust for using a box extender.

In a very literal example, a HI on another forum, states that no splices can be made in a panel. His take is that unless the space is designated by the manufacturer as for splices it is not for that purpose and results in a listing violation.

 

[LJSMITH1]

My position has always been that *if* manufacturer's instructions are not meant to be followed to help assure safety, then what is the purpose of an NRTL listing? Forget the fact that some NEC sections require a listed product, understand that UL is only talking about those products that the manufacturer supplies instructions for. There are no instructions for 1900 boxes, general raceways, most fittings, and certainly most wire. The NEC pretty much covers what you need to do with those items.

The UL whitebook is nothing more than a basic summary of NEC requirements which are then related to some of the applicable specifications. It is not a product specific installation guide. Period.

Think about this, can you make a generic installation instruction for every make/model/brand of product? Of course not. Each product comes with certain features or design differences that may require a slight difference in installation procedure.

Also, the end result of ANY NRTL listing process is to validate the product performance, design and materials meet the requirements. If the product is tested when assembled one way, and then fails in the field because someone decided that they wanted to assemble it another way...whose fault is it?

One analogy could be the use of a generic car. The warranty and safety guarantees are only in play when the car is used in a manner for which it is designed and tested. Let's say, you purchased the car, and instead of driving your kids to soccer practice, you used it to race in the Daytona 500, or the Baja 1000. The car falls apart and/or hurts you within the warranty period. Who is to blame? You? The manufacturer? The NRTL? :roll:

Just because you don't agree with UL's statement on CB's, why is that a blanket statement for everything else? Unless specifically requested by the manufacturer, GE would not ask the NRTL to test its CB's in a Murray, SquareD, or other non-GE panel. Why would they? The listing services they pay for can be directed to only test their product with their accessories.

Unless there is a larger collaboration of like manufacturers products to be fully interchangeable, I don't see any reason why that should be a negative. Yes, it is protectionist, and like P&S, they certainly can make their listing used only for their products. In actuality, all you would need to do in that instance is to contact P&S and ask if you are violating a listing by using longer commercial screws. I don't know, but I would ask.

I hope my rambling made some sense...

 

[renosteinke]

This matter first came up it the "Great Replacement Breaker Debate." Let me recap.

It all started when a Taiwanese manufacturer got a bunch of breakers listed for use in GE panels. That's right, 'listed,' not 'classified.' Panel manufacturers, Square D in particular, became quite upset.

One of the attacks Square D made was based upon 110.3, which requires products to be used according to the labeling. Square D adopted the position that, "classification" aside, if there was a label thet said "Use only our breakers," then the use of someone else's breaker violated the requirement to follow the label.

UL said then, and continues to say now: No Dice. UL considers the 'instructions' to be only those relevant to the testing of the product. Since the Square D label was not part of the evaluation of the product by UL, was not required by standard or code, and possible conflicted with other laws, and contradicted UL's evaluation of other products, there was no way that UL would agree to that stretching of the grammar.

There are two major legal issues with Square D's position.
The first is a law that came about as the result of the abuse -in some peoples' opinion- of warranty conditions by car manufacturers. Now, as a matter of Federal Law, a manufacturer cannot demand that you have work done, or parts supplied, by him unless the parts and services are free to you. Replace a breaker? Square D can insist on using theirs, but only if it is done at their expense.

The second is a direct extension of "Hydrolevel vs. ASME." In this Supreme Court case, Hydrolevel was able to prove the abuse of the code-making by various firms (all associated with ITT at the time) to manipulate the code-interpretation process to the harm of Hydrolevel.

In that case, every ITT salesman suddenly got an ASME letter, that had actually been written by ITT, that mis-represented the code in a way that declared the competing product to be dangerous and illegal.

These days, amazingly enough, every Square D salesman just happens to have that UL "Code Corner" response, which is then used to misrepresent UL's position.

You're dealing with a mentality that would consider painting the panel cover to be a violation of listing and labeling- yet daily has no trouble making engineering decisions on the equivalence of various items. This sort of feigned ignorance is simply dishonest - and destroys their credibility in my eyes.

 

[don_resqcapt19]

...
Just because you don't agree with UL's statement on CB's, why is that a blanket statement for everything else? Unless specifically requested by the manufacturer, GE would not ask the NRTL to test its CB's in a Murray, SquareD, or other non-GE panel. Why would they? The listing services they pay for can be directed to only test their product with their accessories.

They tell me that I can install classified breakers in any panel they are classified for use in, but the instructions that are provided instructions say I can't and UL says I have to comply with the panel instructions. UL can't have it both ways...either the supplied instructions apply or they don't. As long as they continue to classify breakers, I will only follow the instructions that are an acutal part of the listing and labeling as specified in the White Book...anything else is just a manufacturer's reccomendation and not a 110.3(B) instruction.

... and like P&S, they certainly can make their listing used only for their products. In actuality, all you would need to do in that instance is to contact P&S and ask if you are violating a listing by using longer commercial screws. I don't know, but I would ask.

I would be willing to bet that P&S has no intent to limit the use of their product to wall boxes only. As far as calling then and asking them, that would not change anything...UL says I have to follow the supplied instructions. Them telling me it is not a listing violation does not change the supplied instructions.

 

[LarryFine]

Now, as a matter of Federal Law, a manufacturer cannot demand that you have work done, or parts supplied, by him unless the parts and services are free to you. Replace a breaker? Square D can insist on using theirs, but only if it is done at their expense.

It sound like you're saying that SqD must provide free replacement breakers to enforce the warranty requirement of using their breakers.

If a SqD panel with classified breakers malfunctioned, then they're only on the hook if they refused to provide free replacement breakers?

That means they could get off the hook for a claim merely by stating we failed to request that they provide free replacement equipment.

Would we have to provide a letter from SqD specifically denying our request for free replacements? What about labor costs for installation?

 

[renosteinke]

Larry, not to 'talk down' or sound condescending - I know you too well for that - but we've already settled that issue.

In short form, you make a warranty claim, they deny it because you used a classified breaker, you sue, the judge gets pissed off and sanctions Square D for wasting their time over a matter of settled law.

In such a suit, you can be sure that the other manufacturer and UL would be there, on your side.

It's like changing oil in your car - any brand of the appropriate ASE oil, done by any licensed shop by industry-rated help, and you've met the warranty requirements. The only way (GM, say) could deny you this option was for them to insist on doing it in their shop - at NO cost to you.

Square D, by asserting this frivolous argument, is only setting the stage for the courts to really hammer them. Since I'm not aware of the issue oficially arising, I can only assume that their legal department knows better - even if their salesmen don't.

 

[macmikeman]

Figure it like this. UL can be sued just like anybody or any organization can. My guess is they have in house legal counsil (or loads of in house council). Elaborate directions are a ruse, because seldom will you follow all the instructions they direct you to. The attorneys told them to do this on purpose. " Therefore your honor, we ought to be found not guilty as the installer in this case did not follow our carefully crafted set of specific instructions as to priming the subject dishwasher with two quarts of preheated water or whatever it was that was so out to lunch that we included with the listing...."

 

[weressl]

OK, maybe the soap example is stretching things, but here is a randomly chosen dishwasher instruction manual.

http://www.geappliances.ca/images/english/pdfs/206c1559p101en.pdf


Here is just a sampling from that.


No Mr inspector, I did not add 2 quarts of water to the bottom of the
dishwasher to lubricate the pump seal, I will try to be better next time.

Neither of those examples are INSTALLATION instructions pertaining to the Electrical Contractor. Both of those are USE and OPERATION instructions.

 

[weressl]

I would be willing to bet that P&S has no intent to limit the use of their product to wall boxes only. As far as calling then and asking them, that would not change anything...UL says I have to follow the supplied instructions. Them telling me it is not a listing violation does not change the supplied instructions.

That may be P&S INTENT, but in fact they requested UL to test for one or more specific use(s) and were unwilling to pay for other tests for other installation methods and situations, then any alternative installation that is NOT part of the listing would be the violation of the listing.

Ex.: There are pressure transmitters that have up to 30 different installation methods and multiple agency listing combinations and all ARE listed and illustrated in the instruction book. It describes the installation method and the corresponding agency compliance with each separate diagram. Should you wish to use a 31th installation method and you'd be in no compliance with any of the listings.

 

[LJSMITH1]

Gentlemen...UL does not draft or require the instructions, the manufacturer does. The manufacturers include installation/use instructions to insure that their product will be evaluated in a standard format (i.e. connections, torques, environments, etc.).

The NRTL follows the installation instructions (to the letter) and completes the required testing on the product. If the product fails, it is not listed. If it passes, it does so because the manufacturer has defined the exact conditions the product will be guaranteed to function properly.

Yes, the manufacturer installation instructions (when included with the product) can be considered a 'guide'. However, the legal hawks have also done their job of protecting the company should a "non-standard" installation cause injury or property loss. What I mean by non-standard is an installation or use that is not clearly defined in the manufacturer's instructions.

Lets say a manufacturer is sued, and finds out that someone used a drywall screw instead of the approved #6-32 screw to attach a receptacle to a box, and it causes injury or fire because it was too long or pointy and shorted out against the hot pigtails inside the box. Whose fault is it? I am sure the injured or damaged property owner will insist its the manufacturer, while the blame might really rest with the electrician...:roll: The bottom line is that a non-listed or manufacturer approved subsitute screw was used in place of the standard supplied screw. If the NRTL tested the receptacle mounting with that same drywall screw, the product would have NOT been listed in the first place - for the exact reason of why this installation failed.

I guess nowadays its all about CYA, not common sense...:roll:

 

[LJSMITH1]

Neither of those examples are INSTALLATION instructions pertaining to the Electrical Contractor. Both of those are USE and OPERATION instructions.

I agree.

 

[ozark01]

I am under the impression that the manufactures installation instructions override the codes. What is ya'll's take on that?

 

[don_resqcapt19]

That may be P&S INTENT, but in fact they requested UL to test for one or more specific use(s) and were unwilling to pay for other tests for other installation methods and situations, then any alternative installation that is NOT part of the listing would be the violation of the listing.
...

So what about the other brands of receptacles that do not have an installation instruction? How does UL test them? Do they test every possible installation method? Or does the lack of an installation instruction, simply mean that you can't install the product?