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

Status
Not open for further replies.

LJSMITH1

Senior Member
Location
Stratford, CT
That is one of the points I'm trying to make, so maybe we agree.

I think we do on some levels.:)

Another point would be the objective of the instructions. I have instructions for mounting a ceiling fan box that says to use a lone 2x4 as a brace. The idea is to provide adequate support. To me, I can also use a 2x6 or any brace that would give me equivalent or better support. In some cases, I don't think a simple 2x4 would be the best choice. Just an example of where it does not always make sense to follow the instructions "to the letter" and shows there is more than one way to install the device without damaging the device's performance..

Conversely, another variation could get you in trouble - using a 2"x2" or a 1"x2" because that was what was laying around on the jobsite. I agree with what you are saying, but the logic can cut both ways. You may think the guy that used those smaller pieces of lumber is an idiot, but to the guy who did it, it was a good decision - until the fan drops on someone's head...

The point being is that there is no way for UL or the manufacturer to test/evaluate/analyze every iteration of possible installs for a given product and application. So, they just go with the most common or critical. Maybe in your example, the instructions should read "use a 2"x4" minimum"...


And that can be where the real pain in the neck happens.

At times, I am sure that this is the case.:)
 

iwire

Moderator
Staff member
Location
Massachusetts
The point being is that there is no way for UL or the manufacturer to test/evaluate/analyze every iteration of possible installs for a given product and application. So, they just go with the most common or critical. Maybe in your example, the instructions should read "use a 2"x4" minimum"...

And I think you are still missing the point completely.

As it stands today ULs position is, I must, ..... I am required to ..... follow each and every installation instruction to comply with 110.3(B)

There is no legal mechanism in place for me to call the manufacturer and ask if I can deviate from the instructions as you have suggested.

ULs position is both ridiculous and virtually imposable to comply with in many situations.
 
I think we do on some levels.:)



Conversely, another variation could get you in trouble - using a 2"x2" or a 1"x2" because that was what was laying around on the jobsite. I agree with what you are saying, but the logic can cut both ways. You may think the guy that used those smaller pieces of lumber is an idiot, but to the guy who did it, it was a good decision - until the fan drops on someone's head...

The point being is that there is no way for UL or the manufacturer to test/evaluate/analyze every iteration of possible installs for a given product and application. So, they just go with the most common or critical. Maybe in your example, the instructions should read "use a 2"x4" minimum"...

At times, I am sure that this is the case.:)

Just to clarify: not all parts of the installation instructions are part of the UL evaluation only that are pertinent to the UL listing. Ex. a pressure transmitter requires certain process connection and the process connection details and requirements are NOT part of the UL evaluation for the XP listing by UL.
 

mivey

Senior Member
Or maybe the mounting method is not even part of the UL test to evaluate if the product is ELECTRICALLY safe.
There ya go...the fan falling on someone's head does not mean the box failed.

Now if I started cutting out pieces of the box to make it fit somewhere, I think I am probably going to violate the integrity of the box and it might not pass UL inspection.
 

rbalex

Moderator
Staff member
Location
Mission Viejo, CA
Occupation
Professional Electrical Engineer
Just to Stir the Pot

Just to Stir the Pot

Before the 2006 White Book, it was clear that all non-hazardous location equipment was a subcategory of Electrical Equipment for Use in Ordinary Locations (AALZ). [BTW the 2009 White Book can be downloaded here.] Since they began listing the Category Codes alphabetically, it isn’t as obvious anymore.

In any case, I looked at the referenced “document.” The answer to the first question, “Can a UL Listed product be modified in the field if the manufacturer indicates that the revision is ok and sends out new parts?” was extracted directly from the text in AALZ. However, the answer, to the question addressed in the OP is not quite the same as statement in AALZ which is, “These products are intended to be installed in accordance with the installation instructions provided with the product. It is critical that the cautionary statements and installation and operating instructions on the product and in accompanying literature be followed.”

I consider, the document referenced in the OP to be analogous to the NEC Handbook; i.e., probably good advice but not actually enforceable. This is especially true since UL documents still aren’t even close to being a consensus.

As a thought experiment, what permits us to “modify” RMC by cutting it to length in the field? The NEC specifically tells us how to bend it, ream and thread cut ends; but there is nothing that clearly says the cut was made or permitted in the field. The UL Category Code (DYIX) doesn’t say anything either. Again, both the NEC and UL tell us we can get “Longer or shorter lengths with or without coupling and threaded or unthreaded” from the manufacturer, so maybe we should start ordering it that way.
 

LJSMITH1

Senior Member
Location
Stratford, CT
There ya go...the fan falling on someone's head does not mean the box failed.

Now if I started cutting out pieces of the box to make it fit somewhere, I think I am probably going to violate the integrity of the box and it might not pass UL inspection.

True...as the NRTL (UL) is typically listing the electrical product for electrically-related criteria. Structurally-related deficiencies are more of a general installation issue - but may be included as part of the specification. In specifications that I am intimately familiar with (fittings - UL514B), there are plenty of mechanical requirements that have little to do with electrical requirements. Pull Tests, Bend Tests, Torque Tests, Flex Tests, Wear tests, Corrosion Tests, etc.

My point is there are typically no separate instructions for electrical installation, another set of instructions for safety concerns, or another set of instructions for physical/mechanical hookup, etc. They are all consolidated into one document. However, the NRTL will test the product using the applicable and relative portions of the installation instructions. Who decides whats relative and applicable? You and the AHJ. Its virtually impossible to have install instructions that address every possible combination of variables that one may experience on a jobsite. I am sure the NRTL knows this, and cannot possibly address it in a single listing. This is why they have Field inspection services.

Like I repeated before, all this means nothing in the end because either the AHJ approves or not. The only time an NRTL listing is required is if the NEC specifies it, or the customer requires it, or the AHJ requires it. :cool:
 
Last edited:

iwire

Moderator
Staff member
Location
Massachusetts
I repeated before, all this means nothing in the end because either the AHJ approves or not.

Not quite, the AHJs approval means nothing if it goes against the NEC. The installer is still 'on the hook' for the lifetime of the installation.

So if the instructions say 'use a 2" x 4" to support the box' and I use a 2" x 6" with the AHJs approval I am still violating the NEC 110.3(B) according to ULs stated position that all instructions are part of the listing.
 

LJSMITH1

Senior Member
Location
Stratford, CT
Not quite, the AHJs approval means nothing if it goes against the NEC. The installer is still 'on the hook' for the lifetime of the installation.

So if the instructions say 'use a 2" x 4" to support the box' and I use a 2" x 6" with the AHJs approval I am still violating the NEC 110.3(B) according to ULs stated position that all instructions are part of the listing.

If the 2"x6" can support the required weight as determined by you (the expert) and the AHJ, the listing might be still valid. The problem is that the listing would have been obtained with only a 2"x4", not a 2"x6". So how is an NRTL going to validate and List the use of a 2"x6" without even testing it? What about using a metal stud? A piece of RMC? How about a piece of plywood? The combinations are endless.

From IAEI http://www.iaei.org/magazine/?p=3992

Question: Installation instructions
Does UL review installation instructions that are provided with UL certified products? Are they evaluated to make sure they comply with model codes? What codes are they evaluated for compliance with?


Answer
Yes, during Listing and Classification investigations, UL does evaluate the manufacturer’s installation instructions provided with UL certified products. Many UL Standards specify numerous requirements for the content of the installation instructions. UL reviews installation instructions to verify proper content and determine if the product can be installed and operated as intended in accordance with the applicable UL Standards, which are compatible with the installation codes. For electrical products, the National Electrical Code (NEC), NFPA 70, is the applicable code.

The Guide information that proceeds each product category in the UL Product Directories usually identifies the specific(s), as well as articles and sections of the Code when appropriate.

Here's a good one from UL. This document seeks to define what an installation instruction should contain in order to list a controls product.

http://www.ul.com/global/eng/documents/offerings/industries/lifesafetyandsecurity/securityandsignaling/listingdocument/ul_listingdocument.pdf

Here's a typical GuideInfo document from UL defining Electric Discharge Lighting Systems (IFAY) and the relevant excerpt:
http://database.ul.com/cgi-bin/XYV/template/LISEXT/1FRAME/showpage.html?&name=IFAY.GuideInfo&ccnshorttitle=Electric+Discharge+Lighting+Systems,+Cold+Cathode&objid=1074096534&cfgid=1073741824&version=versionless&parent_id=1073988136&sequence=1

INSTALLATION
Electric discharge lighting systems are provided as a system of parts that are field installed. These systems are installed using tools and techniques available only to an electrician. The systems are provided with installation instructions which define the scope of the system and method for installation. It is intended that the system installation instructions be retained with the installation to which they apply.

The Listing of a lighting system does not constitute approval of the design which is the responsibility of the manufacturer and the Authority Having Jurisdiction nor approval of the installation. The final acceptance of the field-installed lighting system is the responsibility of the Authority Having Jurisdiction.


Note the last sentence in the above paragraph. I am not making this stuff up. Apparently, my interpretation is at odds with yours, and no matter what example I provide to back up my statements, you keep referring back to 110.3(B).

The NEC gives all final approval authority to the AHJ. If you don't agree with an AHJ, you can challenge them all day long. They may not have NEC articles to back up their decisions (I would hope that they do), but they also are not required to do so.

Every jurisdiction in the country is different, and they may have interpretations of the NEC that may not line up with yours. You know as well as I do that there are some folks that are still on the 2005 or earlier NEC.

Perhaps a definitive statement from the NFPA and/or UL regarding installation instruction use would go a long way in clarifying this issue with many folks.:)
 
Last edited:

LJSMITH1

Senior Member
Location
Stratford, CT
If codes are a minimum where does it say that I can not exceed the code?

So if the manf. ask for a 2x4 and I install a 2x6 how has the manf. specs. been violated?

We are discussing Mfr. install instructions and how they relate to the NRTL Listing...:cool:

Exceeding the Mfr. instructions may or may not void the NRTL listing. It all depends what it is and how it could possibly affect other performance or safety issues. The only people that could answer that definitively are the Mfr. and the NRTL...:)
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
We are discussing Mfr. install instructions and how they relate to the NRTL Listing...:cool:

Exceeding the Mfr. instructions may or may not void the NRTL listing. It all depends what it is and how it could possibly affect other performance or safety issues. The only people that could answer that definitively are the Mfr. and the NRTL...:)
But unless they actually change the supplied instructions, the use of the alternate method, even if approved by both the manufacturer and the NRTL would still be a code violation.
 

LJSMITH1

Senior Member
Location
Stratford, CT
But unless they actually change the supplied instructions, the use of the alternate method, even if approved by both the manufacturer and the NRTL would still be a code violation.

How so? If the NRTL retested with the alternate method, and listed it, how would it be a code violation? The listing is the validation of the product performance and adherence to applicable NEC requirements.

Another approval option by the NRTL is a field evaluation. The NRTL could evaluate and then sign off on it. When that happens, the sign off is essentially a listing. Therefore, no code violation.

Right?:cool:

The real question becomes, who is going to pay for all these additional tests and field evaluations to help people sleep at night?:):roll:
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
How so? If the NRTL retested with the alternate method, and listed it, how would it be a code violation? The listing is the validation of the product performance and adherence to applicable NEC requirements.

Another approval option by the NRTL is a field evaluation. The NRTL could evaluate and then sign off on it. When that happens, the sign off is essentially a listing. Therefore, no code violation.

Right?:cool:

The real question becomes, who is going to pay for all these additional tests and field evaluations to help people sleep at night?:):roll:
Still a code violation unless the manufacture actually provides a set of instructions that permit the alternate method. UL says all supplied instructions are 110.3(B) instructions...field evaluation does not change the instructions.
 

LJSMITH1

Senior Member
Location
Stratford, CT
Still a code violation unless the manufacture actually provides a set of instructions that permit the alternate method. UL says all supplied instructions are 110.3(B) instructions...field evaluation does not change the instructions.

I agree and disagree :). Any NRTL field inspection process overrides the deviation from the installation instructions. If the NRTL approves of the deviation (through internal tests or other means of evaluation), they will issue a letter to that GC or EC - Listing that particular install as acceptable. I know, because I have been through it.

However, this will not become part of the regular Listing (available to everyone) unless the manufacturer changes the installation instructions and has the product additionally tested and subsequently re-Listed. So in this case, a deviation from the standard install may result in a loss of the Listing, which may be required per code - hence a code violation.:cool:
 

mivey

Senior Member
The real question becomes, who is going to pay for all these additional tests and field evaluations to help people sleep at night?:):roll:
I say we bill you. Everybody was sleeping fine until you started poking the dog with a stick.:grin:
 

LJSMITH1

Senior Member
Location
Stratford, CT
I still say ULs position is ridiculous, ever changing and unobtainable no mater how well intentioned it may be.

Don't forget its not just UL, its all NRTL's and the NEC as they work as a group on specifications and listings. I think there should be some kind of clear harmonization of the policy regarding this issue, and maybe someone with more clout than me can make that happen.:cool:
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
Don't forget its not just UL, its all NRTL's and the NEC as they work as a group on specifications and listings. I think there should be some kind of clear harmonization of the policy regarding this issue, and maybe someone with more clout than me can make that happen.:cool:
Another issue is the actual listing and labeling instructions that are only found in the White Book and not provided with the product. It is extremely unreasonable to expect the installer to dig around in these other documents to find installation information that is required for a safe and code compliant installation.
 
Status
Not open for further replies.
Top