Violating a listing

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jim dungar

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Does any one have any proof that removing or changing a molded cord connector would violate a UL Listing?

Most people would say yes only on the basis of it doesn't follow the manufacturers instructions. If this is the case aren't we violating the UL Listing every time we use "good" wirenuts rather than the cheap ones supplied as a component with a fixture?

UL seems to allow substitutions of material that has the same ratings and UL listing. Without this substitution capability manufacturers would not be able to easily change their own components.
 

petersonra

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Northern illinois
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engineer
Re: Violating a listing

I think in a very technical way an argument could be made that both situations you describe would indeed violate the UL listing. But it also seems to be an argument about how many angels can dance on the head of a pin.

I don't think the cord is itself listed, but rather is recognized (wire nuts are probably listed though). You can't "legally" replace a recognized component except with the same part.

As I understand the situation, if it was listed, then replacing it with another listed component of the same ratings would be "legal".

<edited to correct brain fade>

[ October 15, 2004, 02:37 PM: Message edited by: petersonra ]
 

bphgravity

Senior Member
Location
Florida
Re: Violating a listing

I feel if a change or substitution is made and approved by the AHJ, then a minor violation of the listing is insignifcant. To change the intended use of a product or the manner in which it is used would be a problem, but making a change such as using longer support screws or your own wire nuts does not change the operation or function of that component.
 

petersonra

Senior Member
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Northern illinois
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engineer
Re: Violating a listing

Just out of curiousity - under what logic does any AHJ have any right, power, or authority to allow or disallow a modification to a UL listed assembly?

:)
 

sandsnow

Senior Member
Re: Violating a listing

I wish more people were so concerned about the significance of the UL listing of a product. :D

Anyway, the approval of any product used for electrical installation is up to the AHJ except where specifically required by the Code. Such as all electric signs shall be listed.

The approval of products is the responsibility of the the AHJ. The listing of a product helps in that approval. see 90-4 and 90-7. That is it in a nutshell.

For example, a switchboard can be shipped from the factory as 3 phase 4 wire, but the actual system may be 1 pase 3 wire. The manufacturer may come out to modify the equipment. Remove and reinstall all the bussing.

Another example is a switchboard is made without barriers between the utility compartment and the customer wiring compartment. A barrier is installed in the field.

In both cases the AHJ can ask for a UL field evaluation to determine that the significance of the listing mark has been maintained. Or the AHJ could accept both. My call was top one reject and bottom one accept. that was due to the extent of the modifications. The most important consideration is maintaing the withstand rating (bracing).

The important thing to remember is that you can violate the Code, but you cannot violate the UL listing. When a piece of equipment is modified in the field, the significance of the listing is in question. The original UL evaluation of the product is based on when it was first manufactured. It depends upon the extent of the modification as to requiring a field evaluation.

Another option to the field eval. is to completely replace the product.

So in the case of the molded cord cap, No significance to the listing is lost if the cap is replaced with one of equal rating.
 

jim dungar

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Re: Violating a listing

We constantly violate (invalidate?) UL Listings.

My understanding is that all field cut conduit entrances (no manufacturer supplied hub or knockouts) technically violate the UL TYPE listing of equipment. These violations render all enclosures as UL TYPE 1 regardless of their original rating (i.e. 3R, 4, or 12). UL claims this, because they have not tested the actual size and quality of the field cut/drilled/punched hole.

But, the AHJ can use the previous valid listings and the actual field conditions to evaluate and approve the installation
 

tom baker

First Chief Moderator
Staff member
Re: Violating a listing

Jim, we have traffic signal cabinets that come with an instruction from the manufacturer 'to maintain the NEMA 3r rating a meyers type hub must be used'.
 

petersonra

Senior Member
Location
Northern illinois
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engineer
Re: Violating a listing

I believe you may be mistaken in this regard. UL only requries that you use a fitting that has the same or higher rating as the enclosure it is installed in. e.g.- if you install a fitting rated at Nema4Xin a NEMA4X enclosure this is acceptable and maintains the rating of the ensloure. However, if you put a fitting in the box that is rated NEMA1 (like an EMT fitting) the box is not "de-listed" but rather reverts to a Nema 1 enclosure.
 

jim dungar

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Retired Electrical Engineer - Power Systems
Re: Violating a listing

Maybe my UL inspector is just being difficult.

This is a quote from the UL website "It is the responsibility of the Authority Having Jurisdiction (AHJ) to determine the acceptability of the modification or if the modifications are significant enough to require one of UL's Field Engineering Services staff members to evaluate the modified product. UL can assist the AHJ in making this determination."

This seems to put the violation/de-listing of a UL label entirely on the shoulders of the AHJ.
It appear that a factory applied NRTL listing/label should only be used as a tool not an absolute when evaluating an installation.
 

sandsnow

Senior Member
Re: Violating a listing

Originally posted by jim dungar:
Maybe my UL inspector is just being difficult.
Are you a manufacturer? I was curious why you are dealing with a UL inspector ?

This is a quote from the UL website "It is the responsibility of the Authority Having Jurisdiction (AHJ) to determine the acceptability of the modification or if the modifications are significant enough to require one of UL's Field Engineering Services staff members to evaluate the modified product. UL can assist the AHJ in making this determination."

This seems to put the violation/de-listing of a UL label entirely on the shoulders of the AHJ.
That's exactly right. The AHJ is the one who ultimately approves the product. Technically UL's job is done when the product leaves the factory with the listing mark. They are as stated available for consultation (free to AHJ and maybe others) and for field evaluations (cost to manufacturer or user )

It appear that a factory applied NRTL listing/label should only be used as a tool not an absolute when evaluating an installation.
Not exactly, it depends on the jurisdiction. I can only speak for mine. If a contractor uses a listed product correctly I will accept it no problem, no questions. If something appears wrong, I will call UL for clarification. If the product has been modified (as I wrote previous), then a field eval. may be necessary.
We had some luminaires that were being installed in a hotel. The fixture wires appeared to exit the fixture incorrectly, there was a sharp edge. The manufacturer stated they were manufactured correctly. They were listed by CSA, who just happens to have an office in our city. I brought the luminaire down to them (CSA) and in two days there was a new shipment of luminaires (manafactured correctly) on the job. I did not outright reject the luminaires at first, only question the construction. I used the testing lab. as a tool.

And there have been times when a product looks funny to me, but the testing lab. verifies the product is manufactured correctly and we move on.

edited to seperate quote from my comments

[ November 09, 2004, 06:53 PM: Message edited by: sandsnow ]
 

tkb

Senior Member
Location
MA
Re: Violating a listing

How do you get access to a testing lab, how much does it cost, and how long do they take to get you results?
 
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