UL Listing Required?

[edwalsh]

If I manufacture a control system (for load shedding) using typical UL listed electrcial parts (relays, indicator lamps, push buttons) that do not violate any code, is this device required to have a UL label?
Thanks

 

[cpal]

What is the equipment used for,

if it is a transfer sw for a article 700 installation and you are assembling component parts to achieve load shedding I would insist on a field inspection to certify the gear (I think) . Also if this is a Emg Sys. do you really want to be responsible with out a nrtl insp???

 

[petersonra]

What is the equipment used for,

if it is a transfer sw for a article 700 installation and you are assembling component parts to achieve load shedding I would insist on a field inspection to certify the gear (I think) . Also if this is a Emg Sys. do you really want to be responsible with out a nrtl insp???

what good does an nrtl inspection give you? it does nothing to shift liability away from the manufacturer. nor does the nrtl even look at the design to see if it is safe, or correct. they only check for the things they care about such as component selection, wire colors, wire and fuse sizes, etc. It is not uncommon for a listed panel not to work properly because of design deficiencies not related to UL standards, it was just designed wrong.

 

[cpal]

what good does an nrtl inspection give you? it does nothing to shift liability away from the manufacturer. nor does the nrtl even look at the design to see if it is safe, or correct. they only check for the things they care about such as component selection, wire colors, wire and fuse sizes, etc. It is not uncommon for a listed panel not to work properly because of design deficiencies not related to UL standards, it was just designed wrong.

I'm not going to get into an argument as the quality of the op installation but if it is going to be inspected there IS and argument to have a testing agency review the product. why do most manufactures spend the money they do for the useless ul (or other ntrl) labeling

90.7 Examination of Equipment for Safety.
For specific items of equipment and materials referred to in this Code, examinations for safety made under standard conditions provide a basis for approval where the record is made generally available through promulgation by organizations properly equipped and qualified for experimental testing, inspections of the run of goods at factories, and service-value determination through field inspections. This avoids the necessity for repetition of examinations by different examiners, frequently with inadequate facilities for such work, and the confusion that would result from conflicting reports on the suitability of devices and materials examined for a given purpose.
It is the intent of this Code that factory-installed internal wiring or the construction of equipment need not be inspected at the time of installation of the equipment, except to detect alterations or damage, if the equipment has been listed by a qualified electrical testing laboratory that is recognized as having the facilities described in the preceding paragraph and that requires suitability for installation in accordance with this Code.

just a thought

 

[edwalsh]

What is the equipment used for,

if it is a transfer sw for a article 700 installation and you are assembling component parts to achieve load shedding I would insist on a field inspection to certify the gear (I think) . Also if this is a Emg Sys. do you really want to be responsible with out a nrtl insp???

This is a load shedding device for small kw residential generators that will automatically shed the larger loads so the generator overcurrent protection won't trip. The homeowner can also manually turn back on loads that were shut down automatically if they manage the available power wisely during a long term power outage. I have been told since we make the device in our shop and sell it as a load shedding option that it needs to be UL listed.

 

[jim dungar]

It is incorrect to say that the internal wiring of your equipment is NEC compliant. The NEC does not cover the internal wiring of most electrical equipment. For example: the NEC requires single conductors to be installed in raceways or cableassemblies, and I will bet that you do not have any raceways inside of your panels.

 

[petersonra]

This is a load shedding device for small kw residential generators that will automatically shed the larger loads so the generator overcurrent protection won't trip. The homeowner can also manually turn back on loads that were shut down automatically if they manage the available power wisely during a long term power outage. I have been told since we make the device in our shop and sell it as a load shedding option that it needs to be UL listed.

I believe you have been told wrong.

You assemble load centers without bothering to get the whole assembly UL listed.

 

[roger]

I have been told since we make the device in our shop and sell it as a load shedding option that it needs to be UL listed.

I would ask who ever is telling you this to provide back up to what they are telling you.

In 99 percent of residential situations you are looking at an article 702 application and there is no Life Safety issues with this equipment, not that that would necessarily make a difference anyways.

There is no wording in article 702 requiring any of the equipment to be listed by an NRTL and as Charlie posted, article 90.7 points out that "specific items" in the NEC are required to be listed, but this is not the case in article 702 applications.

90.7 Examination of Equipment for Safety.
For specific items of equipment and materials referred to in this Code, examinations for safety made under standard conditions provide a basis for approval where the record is made generally available through promulgation by organizations properly equipped and qualified for experimental testing, inspections of the run of goods at factories, and service-value determination through field inspections.

An example that would require listed equipment would be article 406.2

406.2 Receptacle Rating and Type

(A) Receptacles Receptacles shall be listed and marked with the manufacturer's name or identification and voltage and ampere ratings.

The equipment used for 702 is only required to be approved for it's intended use meaning that if the contactor(s), relay(s), enclosure(s), etc... are used correctly there is no reason that an inspector could turn down these items as a functioning part of a wiring system and would be able to approve the installation on that basis.

There is also no requirement that the AHJ conduct tests or witness the operation of article 702 equipment as there is in both 700.4 and 701.5

Roger

 

[jtester]

If your device is not listed, you might find access to some jurisdictions difficult. New Mexico, for example has the following requirement in their electrical code

14.10.4.10 AMENDMENTS TO THE 2005 NATIONAL ELECTRICAL CODE. The following amendments are made to the 2005 national electrical code. The article and section numbering is keyed to the national electrical code format.

A. Article 110. Requirements for Electrical Installations.

(1) 110.2 Add: Listing and labeling by a nationally recognized testing laboratory as listed by the occupation safety and health administration.

(2) Electrical wiring, equipment, or material that is not listed and labeled and a (UL) safety standard exists shall be certified by a nationally recognized testing laboratory approved by the electrical bureau.

(3) Electrical wiring, equipment, or materials that is not listed and labeled and a (UL) safety standards does not exist shall be certified by an electrical engineer licensed to practice in New Mexico. The certification will verify manufacturer?s safety and performance test data of the product.

I don't know any NM PE's who certify products, although there may be some.

Jim T

 

[ABB]

Nfpa 110

Nfpa 110

Not to kick the beehive, but does NFPA 110 "Standard for Emergency and Standby Power systems apply to residential?

The scope section of NFPA 110 takes a hands off approach to its applicability..........so would it be an AHJ question ?

Sorry for hitching on your post Ed.

 

[roger]

In that most residential applications are optional, NFPA 110 would play a very small role if any at all.

Notice that both article 700 and 701 have FPN's that mention and would take you to NFPA 110 for pertinent information yet article 702 has no such references.


Roger

 

[megloff11x]

OSHA generally requires that installed equipment be either listed for that use, inspected on site by a NRTL, or sometimes you can document yourself that it's OK. I would get on the OSHA website and tool around for your specific case, and ask for an official opinion if you can't find your answer.

UL is not the only agency that can "list" stuff. You can go to CSA, TUV, and others (see OSHA for their list) who will list you to UL standards.

The main thing is safety. The theory goes that UL, et. al. have been analyzing stuff for hazards for decades and can find all potential problems better than you just brainstorming it and doing your best. In practice you get a little logo stamp and a standard number stamp and that number may not apply to your application but you think, "I see UL listed, it must be good across the board." Maybe not. Then you can spend the GNP of several small countries on their $1000 standard pamphlets (too thin to call them a book) and pay several folks a lot of money to try and translate this into English for you.

They're making this harder than it should be. George Patton's maternal Grandfather disciplined himself in his later years not to carry a pistol after some lawyer type insulted his honor by asking for a signature on a contract after they shook on it. How times have changed for the worse.

Matt

 

[roger]

Matt, OSHA does not have any jurisdiction in private homes, and regardless, they haven't been invited to this party anyways.

Ed is using NRTL listed components, they're just not listed as an assembly.

If listing all components of a wiring system as an assembly ever becomes mandatory we will have to start listing every combination of different manufacturers switches and light fixtures as units, this would mean using a manufactures new fixture with a different manufacturers new switch could stop a project for years waiting for the listing process to take place.

Roger

 

[megloff11x]

Matt, OSHA does not have any jurisdiction in private homes, and regardless, they haven't been invited to this party anyways.

Ed is using NRTL listed components, they're just not listed as an assembly.

If listing all components of a wiring system as an assembly ever becomes mandatory we will have to start listing every combination of different manufacturers switches and light fixtures as units, this would mean using a manufactures new fixture with a different manufacturers new switch could stop a project for years waiting for the listing process to take place.

Roger

I deal 100% with industrial and spoke to the question from that angle. I agree that the process is unduly complicated. If his components are used as listed for, and are properly sized and installed, and all other requirements and issues have been properly addressed, I wouldn't see a problem.

Matt

 

[tom baker]

If I manufacture a control system (for load shedding) using typical UL listed electrcial parts (relays, indicator lamps, push buttons) that do not violate any code, is this device required to have a UL label?
Thanks

In Washington State we have a state rule that allows a end user to fabricate a control panel with listed parts. Make sure you understand the difference between listed and recognized. There are no manufacturers of listed terminal blocks, I found out.
But if you are manufacturing, thats a different issue, and the rules will vary from state to state. Our AHJs won't allow a control panel with out a UL 508A label.
For manufacturing, the UL, ETL or similar listing process protects you and the customer.