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

[Pierre C Belarge]

I have been following this thread, and something has just popped into my head. (easy now)


I am just thinking out loud here...
It is possible that the NRTLs may have a situation here where following the installation instructions is part of the listing. When one deviates from the instructions/listing, a field evaluation will determine if the installation is compliant. That makes me wonder if this is exactly what they want. Field evals are expensive.

 

[Pierre C Belarge]

I will add, as my experience in the field and my experience as an inspector...

I would look at the installation as it deviates from the instructions, such as the above discussion and determine if my knowledge is strong enough to say that I would accept the installation although it deviates from the instructions, thus avoiding a field evaluation from the NRTL.
I am not an engineer. With that said, I will not engineer or pretend to understand something I am not comfortable with, but with some items, I believe my experience and knowledge is suitable to make determinations. Also, sometimes I will contact those that are more knowledgable than I and try to work it out. People such as engineers, building officials and Utility personnel.

 

[LJSMITH1]

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.

The Whitebook is intended to be a relatively generic guide to the product application, and is based on the NEC and the applicable UL, NEMA, ANSI, ASTM or other Standard.

The bottom line is that unfortunately there cannot be a single document that would address and help list all possible installation options for a given product. It is impractical and virtually impossible.

On the other hand, there should be a mechanism for dealing with the myriad of installation variations for a particular product. Just what that would be, I don't know. Would you want to require a particular manufacturer to address 90% of every possible variation of installation and have each tested and listed by an NRTL? If so, you are looking at major cost expenses due to all the extra testing that would be required.

The point of this whole Listing process is to validate a product's design, performance, and ability to function as specified in an industry adopted standard. You need standards to control the output of product.

From the 2008 UL White Book, page 34...

UL?s Listing Service is the most familiar form of UL?s product safety certification programs. The UL Listing Mark on a product means that the manufacturer has demonstrated the ability to produce a product that complies with appropriate requirements regarding reasonably foreseeable risks associated with the product.

The phrase "reasonably foreseeable risks" is interesting as it seems to imply that not all variations of installations and related risks have been identified.

As you know, the primary purpose of the NRTL Listing regulatory system is to ensure a safe work environment. In the case of the NEC, NRTL's help ensure that all electrical equipment has been tested for electrical safety prior to installation at a facility. A testing laboratory is someone who actually does the testing of the electrical equipment to determine if it is safe. The testing laboratory also determines under what conditions the equipment is safe to use.

The following is from a Q&A in the Federal Register. It gives a good background of why the NRTL program was started.

http://edocket.access.gpo.gov/2005/pdf/05-22630.pdf

B. Why Did OSHA Develop the NRTL
Program?

Prior to 1971, national consensus
organizations and other code developers
had provisions for independent testing
and certification of products to meet the
safety requirements of their voluntary
standards. For example, the National
Fire Protection Association (NFPA) has
long required safety testing of electric
equipment in various provisions of the
National Electrical Code (NEC). The
NEC is the dominant electrical safety
code in use in the United States.
During OSHA?s first 2 years, the
Agency adopted many established
Federal standards and national
consensus standards as OSHA standards
under section 6(a) of the Occupational
Safety and Health Act (OSH Act), 29
U.S.C. 655(a). Many of these standards
contained requirements for equipment
to be ??approved,?? ??listed,?? or ??labeled??
by certain qualified organizations that
could provide consistent determinations
about the safety of equipment. By
adopting these standards, OSHA
continued the long history in the United
States of equipment testing being
performed by independent testing
organizations. The Agency wanted to
assure itself, through such testing, that
products used in the workplace would
be safe. However, the consensus
standards adopted by OSHA through
section 6(a) of the OSH Act primarily
sanctioned product approvals of only
two organizations: Underwriters
Laboratories Inc. (UL) and Factory
Mutual Research Corporations (FMRC).
In the early 1980s, a successful
lawsuit was brought by another testing
organization that required OSHA to
conduct a rulemaking to establish a
program under which it would
recognize any qualified testing
laboratories that could test and certify
equipment to meet these approval
requirements, not only UL and FMRC.
In 1988, OSHA finalized 29 CFR 1910.7,
which established the NRTL Program
and set forth procedures for evaluating
and recognizing testing laboratories as
NRTLs. (53 FR 12102, April 12, 1988.)
Approval by NRTLs provides OSHA
assurance of the safety of certain types
of products used in the workplace, and
the NRTL Program assures that the
approvals are done by qualified testing
and certification organizations.

Its a lot to read and be aware of...I guess that's what we get for wanting regulations and standards. The lawyers always make sure we never run out of them...:roll:

 

[iwire]

Larry I appreciate and respect all the work you have been putting into this.

That said, from my point of view you are entirely deaf to the voices of those that have to work with this day in and day out.

It's like you have been brain washed by UL or any NRTL that everything they do is right, correct and needed.

 

[LJSMITH1]

Larry I appreciate and respect all the work you have been putting into this.

That said, from my point of view you are entirely deaf to the voices of those that have to work with this day in and day out.

It's like you have been brain washed by UL or any NRTL that everything they do is right, correct and needed.

Wrong...:roll: My point is that there is another way of looking at these things. I am merely trying to educate those who don't quite understand what the Listing process is all about. You seem to know all about it, yet you have probably never been involved in the process. I live the process every day, and as a manufacturer, I know the details of the testing that relate to my products and a few others. Any NRTL follows the testing by the book, and the book is written, adopted, and maintained by a consortium. If you don't like the specifications, or think they could be more 'field friendly', then get them changed through the proper channels.

Point is, its not the NRTL's fault if ALL the possible iterations of installation options are not addressed in the standard. The listing process just follows (blindly) the specification which is in black and white.

You seem to think that UL or any other NRTL is making decisions in a vacuum. You also seem to think that I don't believe that they are infallible. You are wrong on both counts. I just jumped through 1 year of "hoops" with UL to get a section of UL514B 'clarified' to be able to list a product that should easily be covered by the specification. It was no small feat, for a relatively simple change. Talk about frustrating!

I understand your frustration with having to work within the framework of a guide that can leave a lot to the imagination. I wish it was all black and white, but its not. I am not "brainwashed" as you so eloquently put it. My frame of reference is entirely different from yours - and always will be. I am honestly not trying to be argumentative, nor do I believe you are completely wrong in your understanding. I do appreciate your candidness and professionalism throughout our discussions...even though you think I am deaf to your point of view.:roll:

I am here in this forum and others primarily to learn what others experience, while sharing what I know or have experienced when appropriate. I know a part of the Listing process that many on this site don't have the opportunity to experience or to view documents that relate to the process.

Am I a bit 'eager' to explain my point...yes..:roll: I won't beat this one any more...I promise.

 

[iwire]

Larry, Perhaps brainwashed was the wrong way to express myself but I stand by my comment that you are deaf to those stuck woking with these problems in the feild.

You want to take this one on?

Nitpicking 110.3 (B)

 

[iwire]

Point is, its not the NRTL's fault if ALL the possible iterations of installation options are not addressed in the standard. The listing process just follows (blindly) the specification which is in black and white.

I have a real problem with, a serious problem with that.

If any 'authority' requires that instructions written by someone else be followed they darn well can't say it's not their fault if the instructions can not be followed. If UL says the instructions must be followed than UL must control or at the least monitor what those instructions say.

 

[fishin' electrician]

I don't think so!

I don't think so!

Just installed some paddle fans and this is right out of the instructions:

At least twice each year, tighten all screws and lower canopy to check mounting bracket screws and downrod assembly.

Ain't gonna happen UL, no way, no how.

 

[LJSMITH1]

Larry, Perhaps brainwashed was the wrong way to express myself but I stand by my comment that you are deaf to those stuck woking with these problems in the feild.

You want to take this one on?

Nitpicking 110.3 (B)

I left a comment over there too..

I am not "deaf" either. I am not making this up for my own evil plan to aggravate you on your job. I am just stating the facts as I have learned them, through my point of view as a manufacturer. I also see and agree with your position. As a manufacturer, I wish we could know all the possible methods or applications of our product. We know a lot, but never enough. We ask folks like you out in the field for honest feedback, and not everyone is as generous as you.

The people that are really responsible for all of this inconsistency is UL/NEMA and/or the NFPA. Don't forget the lawyers for the product liability insurance as well.:roll:

There should be a NFPA/UL/NEMA/CSA harmonized statement directly addressing this issue and how it relates directly to the field. This way we get more to black and white rather than indefinite shades of grey.

 

[LJSMITH1]

Just installed some paddle fans and this is right out of the instructions:

Ain't gonna happen UL, no way, no how.

Playing devil's advocate...what happens when the down rod bracket works itself loose from an unbalanced fan assembly, and detaches from the ceiling and konks someone in the head and injures them? Who is going to be named on the lawsuit? The fan Mfr - definitely, the HO/Landlord possibly, but the installer too..

As the installer, you will make the case that its not your job to call the HO every 6 months to have the fan checked...and you would be right. However, lawsuits never seem to go the way you plan, so you might be guilty until proven innocent..

IMO, if a Mfr. requires this level of PM/safety check, then their fan design is junk. Or, if its considered top of the line, the Mfr.'s lawyers have tried to close up any and all loopholes to absolve them of liability.

 

[weressl]

Playing devil's advocate...what happens when the down rod bracket works itself loose from an unbalanced fan assembly, and detaches from the ceiling and konks someone in the head and injures them? Who is going to be named on the lawsuit? The fan Mfr - definitely, the HO/Landlord possibly, but the installer too..

As the installer, you will make the case that its not your job to call the HO every 6 months to have the fan checked...and you would be right. However, lawsuits never seem to go the way you plan, so you might be guilty until proven innocent..

IMO, if a Mfr. requires this level of PM/safety check, then their fan design is junk. Or, if its considered top of the line, the Mfr.'s lawyers have tried to close up any and all loopholes to absolve them of liability.

This type of ambiguity has been addressed by some of the mnaufactureers and you can see preface in some larger equipment IOM's, such as:

The text in this manual uses these conventions:​

?​

​

​

​

[FONT=Swis721BT,Bold][FONT=Swis721BT,Bold]Bold type [/FONT][/FONT]highlights important concepts in discussions, key terms in procedures, and menu options.​

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[FONT=Swis721BT,Italic][FONT=Swis721BT,Italic]Italic type [/FONT][/FONT]highlights notes and new terms where they are defined.​

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Rectangular boxes containing bold type are warnings or cautions that pertain to the system or its electrical connections.

What would be helpful if the distinction would include areas that are must be complied with to retain the listing in the equipment in installation operation and maintenance areas. This would also automatically define responsibilities:

Instalaltion instructions pertaining to engineering and craft, in some cases it may be muticraft, eg. electricians, plumbers, mechanics.

Operations and maintenance is the responsibility of the owner or whoever the owner may designate.

So IMO the responsibility is murky and unnecessarily so. Even the above only tries to clarify the extent of the manufacturers responsibility.​

 

[LJSMITH1]

This type of ambiguity has been addressed by some of the mnaufactureers and you can see preface in some larger equipment IOM's, such as:

The text in this manual uses these conventions:​

?​

​

​

​

[FONT=Swis721BT,Bold][FONT=Swis721BT,Bold]Bold type [/FONT][/FONT]highlights important concepts in discussions, key terms in procedures, and menu options.​

?​

​

​

​

[FONT=Swis721BT,Italic][FONT=Swis721BT,Italic]Italic type [/FONT][/FONT]highlights notes and new terms where they are defined.​

?​

​

​

​

Rectangular boxes containing bold type are warnings or cautions that pertain to the system or its electrical connections.

What would be helpful if the distinction would include areas that are must be complied with to retain the listing in the equipment in installation operation and maintenance areas. This would also automatically define responsibilities:

Instalaltion instructions pertaining to engineering and craft, in some cases it may be muticraft, eg. electricians, plumbers, mechanics.

Operations and maintenance is the responsibility of the owner or whoever the owner may designate.

So IMO the responsibility is murky and unnecessarily so. Even the above only tries to clarify the extent of the manufacturers responsibility.​

That's a great suggestion...but as you heard others already say, installation instructions are only a guide (at best). I bet many of these "instructions" go into the trash without even a glance (except those included with the $8000 switchgear...)

 

[weressl]

That's a great suggestion...but as you heard others already say, installation instructions are only a guide (at best). I bet many of these "instructions" go into the trash without even a glance (except those included with the $8000 switchgear...)

I didn't got that impression, but then again, I did not read all posts in this thread. Nor dor I believe that any craftsman would do that who cares about their work and not just a paycheck earner. There are many of those on this forum!

If you have installed the same thing over and over, then perhaps you no longer need to review the instructions. The caviat is that they are subject to change. In some cases UL forced such changes when in the field some defficency was discovered.

 

[ryan_618]

I changed a few of the luminaires in my home the other day. I read the instructions, just out of curiosity. It said to use the supplied wire conenctors to make the connection. The wire connectors were rubbish, so I threw them away and used the ideal tan connectors that I much prefer. I have violated 110.3(B).

 

[LJSMITH1]

I changed a few of the luminaires in my home the other day. I read the instructions, just out of curiosity. It said to use the supplied wire conenctors to make the connection. The wire connectors were rubbish, so I threw them away and used the ideal tan connectors that I much prefer. I have violated 110.3(B).

It seems that this is a prime example of what some folks think of the installation instructions....they should just be thrown out.:roll:

If the AHJ decided that he liked the supplied wire connectors better, he would have every right to red tag you.

 

[mivey]

If the AHJ decided that he liked the supplied wire connectors better, he would have every right to red tag you.

That tag would never fly here. The inspector has every right to act like a moron. Fortunately, most inspectors excercise the right to use common sense.

 

[Riograndeelectric]

OK if you look at the instructions for weather proof bell boxes. it says to use a sealing compound on the box closer plugs.This in it self would be a violation if the plugs are not sealed /. but how many of you will put a sealant around the threads of the box closure plugs? as not installed per Manufacture instructions.

 

[ohmhead]

Well most manufactures write it because they built it and tested it they kinda know what is what for there product .

How many electricians read the paper work with gear & equipment or transformers in the field ?

Its just another trans !

I read it and iam not just saying it to be a know it all take a transformer they call out clearance off walls and they state conduit or conductor entrance to a transformer but some think its ok to run conductors over the coils or run conduit into the back of a transformer or into the top because the code doesnt cover that scope of work the code is not everything the manufactures are what it needs to be or how it needs to be sorry but thats my opinion .

You come in the side front left or right of a transformer or the bottom front under the taps as instructions show but for years ive heard many heated discussions on this.

Each electrician has his own way its what were shown or we learn that reflects our projects and how one gets to be a company that most engineers or inspectors like to see or inspect .

 

[ohmhead]

Well i just could not hold back this think about this who reads the cans of pvc glue and i will say i do but i do not go by the instructions it will not ever happen at our jobs !


KRALOY company

SET SCHEDULE
for pvc solvents & cemments

60 deg to 100 de temp 2 1/2" in to 6 " pipe

30 MINUTE SET TIME ! whats this its on the can instructions also


This is the time to allow joint to set up and to be carefully handled for long runs of pipe care should be taken not to disturb joints for 1/2 to 1 1/2 hours before handling or burying conduit . And its on 90 percent of most pvc glue cans read and weep!

well iam a code violator and in addition to manufactures white pages this is the flip side of my last post !


What electrical contractor in the usa waits 1 1/2 hours none think duct bank with 70# 4 inch conduits we ant waiten!

 

[LJSMITH1]

Well i just could not hold back this think about this who reads the cans of pvc glue and i will say i do but i do not go by the instructions it will not ever happen at our jobs !


KRALOY company

SET SCHEDULE
for pvc solvents & cemments

60 deg to 100 de temp 2 1/2" in to 6 " pipe

30 MINUTE SET TIME ! whats this its on the can instructions also


This is the time to allow joint to set up and to be carefully handled for long runs of pipe care should be taken not to disturb joints for 1/2 to 1 1/2 hours before handling or burying conduit . And its on 90 percent of most pvc glue cans read and weep!

well iam a code violator and in addition to manufactures white pages this is the flip side of my last post !


What electrical contractor in the usa waits 1 1/2 hours none think duct bank with 70# 4 inch conduits we ant waiten!

So if a joint comes apart while being buried only 15 minutes after it was glued, whose fault is it? The manufacturer's?:roll: The good part is that when the conductors are attempting to be pulled, you will find the problem, dig it up, and fix it.

While 98% of the folks that glue PVC conduit this way won't have a problem, there are probably 2% who will. Same thing goes for plumbers who just have to pressurize the PVC supply system ASAP...:roll: