Luminaire labels

[hmspe]

I have a project where the City, based on a recommendation from a lighting consultant, is requiring that all labels in and on the exterior luminaires be removed, if the labels are visible from outside. As a PE I think safety issues outweigh aesthetics and that this is a very bad idea, but I thought I should check in here to see if anyone has any comments.

 

[NoVA Comms Power]

I... requiring that all labels in and on the exterior luminaires be removed, if the labels are visible from outside ...

You mean labels stating "Maximum Wattage XX" and other sorts of safety-related "details" ??? :-?

If so, I'd think that their removal would invalidate the UL listing (which includes marking requirements) and likely the manufacturer's instructions as well.

 

[raider1]

is requiring that all labels in and on the exterior luminaires be removed, if the labels are visible from outside.

If these lables are part of the listing requirements then I think that would violate the listing to remove them. For example the max wattage label as mentioned by Novacomms should not be removed same with the UL or other listing identification label.

Chris

 

[hmspe]

You mean labels stating "Maximum Wattage XX" and other sorts of safety-related "details" ??? :-?

If so, I'd think that their removal would invalidate the UL listing (which includes marking requirements) and likely the manufacturer's instructions as well.

That's what they're asking for.

There's gray area here. I doubt that most manufacturers' instructions say, "DO NOT REMOVE THE LABEL". 410.4(A) and 410.35 require marking. I think the intent is that the markings be essentially permanent and readily visible, but there's nothing in the text that relates to durability of the label, location of the label, or moving the label. Without black letter text it comes down to interpretation.

I'm not sure that removing a UL label is a violation. To the best of my knowledge luminaires are not required by the NEC to be UL listed or UL labeled -- they just have to be acceptable to the AHJ.

Martin

 

[rbalex]

Technically, these are "marks" rather than "lables." See Section 410.35.

Someone may argue, "The NEC doesn't say I can't remove them." However, if they are removed, the luminaire is no longer "marked" as the Section referenced says they "shall be" (present tense.)

UL has a rather extensive marking document, the Luminaire Marking Guide.