What authority governs modifications to UL listed equipment?

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jim dungar

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sandsnow said:
If the product leaves the factory with a certain part then changing that part will affect the integrity of the listing.

According to UL's website and their White book, they do not make the statement that changing a part will affect the integrity of their listing.

In fact what they say is just the opposite: "UL has no way to determine if the product continues to comply with the safety requirements used to certify the product without investigating the modified product."

They go on to say "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."

Based on these statements it is clear that UL expects the AHJ to make the decision if a replacement attachment plug is acceptable or not.

 

sandsnow

Senior Member
True, they don't say exactly that. I don't think what they say is EXACTLY the opposite, but no matter.

The AHJ being the final word was in my first post.

So I guess we've come full circle ;) :D
 
raider1 said:
My point was that UL lists products not approves products, only the AHJ can approve electrical equipment.

Chris

UL approves products to bear the labels that they have tested it according to the listed UL Testing Standard and that it does meet the requirements of that standard.

AHJ can approve the use of an electrical equipment for a particular installation.

If the AHJ is to say that an equipemnt is not approved for a particular installation and the equipment does bear a UL Approval Label for that particular use then the AHJ may be in legal hot water.
 

sandsnow

Senior Member
weressl said:
UL approves products to bear the labels that they have tested it according to the listed UL Testing Standard and that it does meet the requirements of that standard.

AHJ can approve the use of an electrical equipment for a particular installation.

If the AHJ is to say that an equipemnt is not approved for a particular installation and the equipment does bear a UL Approval Label for that particular use then the AHJ may be in legal hot water.

Sorry but Chris is correct. UL was sued over the use of the word approved many moons ago.

Just cause a product bears a listing mark, does not mean I blindly approve it
 

iwire

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weressl said:
If the AHJ is to say that an equipemnt is not approved for a particular installation and the equipment does bear a UL Approval Label for that particular use then the AHJ may be in legal hot water.

Nope, the AHJ in most areas does not have to automatically accept UL listed equipment and like the others IMO you will not find UL approved products.

Check this link out and you will find 'UL Approved' is an incorrect statement.

http://www.ul.com/marks_labels/mark/mark3.html

Here in MA we have an amendment requiring the AHJ to accept any listed equipment when used in compliance with it's listing but MA is just a very small part of the US.
 

iwire

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Here is a more direct answer from UL

Q: What does "UL approved" mean?


A: "UL approved" is not a valid term used to refer to a UL Listed, UL Recognized or UL Classified product under any circumstance. There are a number of requirements and guidelines that should be followed to accurately communicate a product's UL certification. To learn more about these guidelines, please order the free informational brochure, "Show the UL Mark" by accessing our Request Form for Informational Materials.

Found here

UL Terminology
 

sandsnow

Senior Member
Wow, thanks Bob. Did you find that by googling "UL approved"

Thanks for coming back with that because the lawsuit was so many years ago, I only know it by word of mouth.
 
iwire said:
Nope, the AHJ in most areas does not have to automatically accept UL listed equipment and like the others IMO you will not find UL approved products.

Check this link out and you will find 'UL Approved' is an incorrect statement.

http://www.ul.com/marks_labels/mark/mark3.html

Here in MA we have an amendment requiring the AHJ to accept any listed equipment when used in compliance with it's listing but MA is just a very small part of the US.

I said UL approves the use of their label based on the performed testing.

I further said that if an AHJ does not permit the use of an equipment that UL listed for the specific use then the AHJ MAY be in legal hot water. My use of the 'UL Approval Label' in that sentence was incorrect.
 

Jraef

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The NEC is about installation, UL is about manufacturing equipment for safe operation. Differences between the two standards are too numerous to mention, but they are essentially irrelevant. Once a product is listed, the NEC then only applies to the installation of said product. I think the AHJ can technically still reject a listed product if he feels its design and construction is unsafe, but I have never seen that happen (unless it was misapplied).

Also just to be clear, the NEC "suggests" what is called NRTL listing, of which UL is just one of many. In most states there is a separate State Electrical Code, mostly just adopting a version of the NEC and then making minor adjustments. One of the most common adjustments made by states is the requirement for NRTL listing. Once that happens, it is up to the AHJ to enforce it.

But if UL is the NRTL listing that the AC unit has on it and you modify anything that was part of the listed system in a way not specifically laid out by the manufacturer, you have technically nullified its listing and the AHJ can then reject it. By the way, the AHJ can also approve it with your modifications if you make a good case for what you did and why, emphasizing that you have INCREASED the safety of the installed system. Still kind of a crap shoot though, I have run across a few AHJs who are very strict about modifying anything with a UL label on it without ever considering the merits of what I did. I had one reject a job because I punched a conduit hole in an area not designated by the manufacturer as conduit entry, even though it was the safest place to bring in the wires. The original equipment was designed such that you had to bring the conduit into a removable cover, and yet you needed access to the insides to do maintenance and calibration. I came in the side so the cover could be removed, I got red-tagged.
 

iwire

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Jraef said:
Also just to be clear, the NEC "suggests" what is called NRTL listing,

Actually to be clear there are quite a few specific items that the NEC does more then 'suggest' listing for it requires listing.
 

jim dungar

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Jraef said:
But if UL is the NRTL listing that the AC unit has on it and you modify anything that was part of the listed system in a way not specifically laid out by the manufacturer, you have technically nullified its listing...

That is not what UL says. UL states they can not pass judgment until the modification has been evaluated.

Using your logic, in a state that requires an NRTL, there is no way at all to be able to install raceways into a UL listed junction box that was built with blank endwalls. As soon as you cut, drill, or punch a conduit entry you have modified the box. UL has no way to know if you cut an oversized oval shaped hole, left a large burr, or something else happened that would prevent the conduit from properly sealing the hole and maintaining the original enclosure rating. UL says it is up to the AHJ to evaluate all field modifications.
 

ohm

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When I was specifying a bunch of listed ASCO solenoid valves I noticed they came with very long leads. Since we only needed 6" leads I thought we could save a few bucks by ordering shorter leads. The answer came back that if we did not buy exactly what UL tested & listed it voided the UL label. So, we just cut the wire and went on with life.
 

geerhed

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ohm said:
When I was specifying a bunch of listed ASCO solenoid valves I noticed they came with very long leads. Since we only needed 6" leads I thought we could save a few bucks by ordering shorter leads. The answer came back that if we did not buy exactly what UL tested & listed it voided the UL label. So, we just cut the wire and went on with life.

In my experience, the AHJ wins.

UL is only interested if the manufacturer is not following their procedure on a continuing basis. That can get a violation notice and production-hold at least.

ohm - who told you don't modify your valve leads? Was this UL or an in-house entity?:-?
 

ohm

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Birmingham, AL
geerhed said:
In my experience, the AHJ wins.

UL is only interested if the manufacturer is not following their procedure on a continuing basis. That can get a violation notice and production-hold at least.

ohm - who told you don't modify your valve leads? Was this UL or an in-house entity?:-?

It came back from ASCO. But, everyone knows you have to at least strip & terminate the leads. It does however point re-enforce the comments we've all heard ...if you modify a piece of equipment, it voids the UL listing. The final say about violating voiding the UL listing is the AHJ (inspector) or could be a commanding officer, or even the owner.
 

petersonra

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ohm said:
When I was specifying a bunch of listed ASCO solenoid valves I noticed they came with very long leads. Since we only needed 6" leads I thought we could save a few bucks by ordering shorter leads. The answer came back that if we did not buy exactly what UL tested & listed it voided the UL label. So, we just cut the wire and went on with life.

That is sort of true. It is cheaper to get a UL listing for a specific product configuration, than one that has multiple configurations. Asco probably saved a few bucks on the listing by only submitting it with a specific number of feet of wire.

A large number of years ago, I had an end user question whether it was 'legal" to run Asco solenoid valve leads in conduit since they were not using a NEC type wire insulation. An interesting discussion ensued between the end user, myself, and Asco.
 
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