UL Listings on Equipment

jtester

Senior Member
Location
Las Cruces N.M.
I usually refer to the UL White Book when trying to determine when a piece of equipment can have a UL listing. I wonder when does the assembly of UL listed items require UL listing itself. For example, a sewer lift station with a wet well, pumps, alarms, controls, etc. The motors are listed, the control panel is, electrical equipment is, etc. Does the entire lift station need to be?

Jim T
 

Jraef

Moderator
Staff member
Location
San Francisco Bay Area, CA, USA
Occupation
Electrical Engineer
If the lift station is factory assembled and sold as a complete unit, it might need to be. There are companies that do that for sewage lift stations, I believe their packages are listed, although they may be FM listed instead of UL.
 

jtester

Senior Member
Location
Las Cruces N.M.
Much of this type of equipment is designed by a manufacturer, and field assembled. Not just sewer lift stations, but many different types of mechanical systems in sewage plants. Where would I find out when an NRTL listing is available?

Thanks

Jim T
 

rbalex

Moderator
Staff member
If OSHA (Federal or State) applies, with the exception of four “State Plan” States that have “Standards frequently not identical to the Federal”, virtually anything that can be NRTL certified must be. See 29CFR 1910.399 and read the definitions of Approved, Accepted and Acceptable. From the FedOSHA perspective, they clearly identify the AHJ and what the AHJ "approves."

It is essential that the definition of Acceptable be carefully reviewed. Subsections (1), (2) and (3) are not “options” – they are the order of precedence; i.e., (2) can only be applied if (1) is unavailable and (3) can only be applied if (2) is unavailable. Even the four “exception” States are pretty close on this issue.

If OSHA (Federal or State) doesn't apply, check with the local AHJ and especially the insurer of the facility where the product will be installed. Lack of third-party certification, if available, can be presumptive evidence of a lack of due diligence.
 

renosteinke

Senior Member
Location
NE Arkansas
There is absolutely no relation between whether UL listed parts are use, and whether the assembly would meet UL requirements. To 'infer' that there is any merit to using listed components would be to set yourself up to making something that was very dangerous, while patting yourself on the back for all the 'safety' you practice.

Case in point: In the days before UL listed power strips, the ones they used at their labs typically had metal cases that were not grounded at all- not even by the receptacle yokes - though every individual component had a UL recognition of some sort.

Likewise, the current doctrine is that making a power strip by using a 4-square box, industrial cover, etc., is not allowed, even though every part is UL listed.

I believe we are unrealistically expecting far too much of the listing labs. We elect our government- not pass it off to some unaccountable bureaucracy run by anonymous parties. Just because UL lists 'manufactured homes' ... would you trade your home for one? I thought not.

You mention lift stations, which is ironic. The vast bulk of the pump manufacturer have absolutely no use for UL, or its' listings ... and get them for only a minor part of their production, where absolutely necessary. The major, and the 'best', manufacturers scoff at UL. There is a history there, and the industry has its' issues with some of the tests UL wanted to perform. (No point in going into details; the dispute is nearly a half-century old, and I don't see folks suffering as a consequence).

A listing mark is no substitute for good design.
 

jtester

Senior Member
Location
Las Cruces N.M.
I understand what both of you are saying, and I agree that if a listing exists this equipment must be listed, and also that building something out of a bunch of listed components doesn't ensure a good end product.
I'm trying to find out where the listings are found. I have usually looked at the UL White Book, but can't seem to find anything applicable. I quickly looked through the FM website and also came up empty. Perhaps there are no promulgated standards for these various devices.
Bob, I did read through the OSHA section and that makes me pay more attention to your statement that almost anything will require some listing. If there's no standard available, option 1, then I go to option 2 which makes it up to the AHJ. Here in New Mexico, the electrical code says that when there's no standard then a licensed engineer can review and approve it. Again I need to find out if there's a standard. The manufacturers say there aren't any, I just want to be sure.

Jim
 

rbalex

Moderator
Staff member
I understand what both of you are saying, and I agree that if a listing exists this equipment must be listed, and also that building something out of a bunch of listed components doesn't ensure a good end product.
I'm trying to find out where the listings are found. I have usually looked at the UL White Book, but can't seem to find anything applicable. I quickly looked through the FM website and also came up empty. Perhaps there are no promulgated standards for these various devices.
Bob, I did read through the OSHA section and that makes me pay more attention to your statement that almost anything will require some listing. If there's no standard available, option 1, then I go to option 2 which makes it up to the AHJ. Here in New Mexico, the electrical code says that when there's no standard then a licensed engineer can review and approve it. Again I need to find out if there's a standard. The manufacturers say there aren't any, I just want to be sure.

Jim
That's basiccally option 3 - and it's fine. We use it in refinery applications all the time. One of the reasons Sections 500.8(A) and 500.4(B) FPN No.1 were developed is IAEI practically demanded all equipment, even acceptable general purpose equipment, in Classified Locations be specifically listed/labeled for it. Thankfully, CMP14 resisted. Note options 500.8(A)(1),(2),and (3) roughly parallel FedOSHA's defintion of Acceptable.

One thing renostienke and I definitely agree on is that NRTL certification, especially UL's, is oversold. Unfortunately that's the state of affairs ATM.

One product line that is a good example of his position is motors. The NEMA motor group refuses to have general purpose (ordinary location) motors certified - by anyone, even though UL has had a Standard (UL 1004) and Category Code (prgy) for them for years. Since 29CFR 1910.399 basically only applies to "electrical" products, his statement about lift stations/pumps is also well taken. Listing/Labeling is not universal for all product lines; however, as long as the general enforcement community requires listing/labeling it will be a long time before the general requirement will be relaxed.
 

rbalex

Moderator
Staff member
Another point FedOHSA Acceptable (2) only applies if the AHJ is also qualified to conduct the appropriate testing/certifications. Very few have the capability.
 
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