Does modifying a UL lighting fixture void UL?

[barnjunkie]

If the OP wanted to keep a Listing on a luminaire, it sounds like he is doing a commercial job and wants to stay compliant to the requirements of the NEC. Hope the OP understands that the Authority Having Jurisdiction will have the final determination of whether the installation is compliant. Some luminaries led retrofit kits retain the original listing as long as it was installed according to manufacturer’s instructions.
NRTL certification is only necessary if your jurisdiction deems it necessary.
Making a fixture compliant for residential use would only be necessary if the home was being inspected for building or property transfer purposes. And that is “if” the local codes require it.

 

[manwithtools]

"NRTL certification is only necessary if your jurisdiction deems it necessary. "

Some AHJ's want that listing because they then have "plausible deniability", they can simply say they did not inspect it because it had a UL sticker on it. This is more of an issue on larger installations where the inspector is out of his comfort zone.

As a shop that builds UL 508A control panels, we encounter this frequently.

 

[ard]

I hate wading back into the 'conversation'...

There is a huge amount to "UL-centric" disinformation that floats around the Internet when Americans Google "UL vs CE". People should be aware of this. I'm not going to go into a chapter and verse analysis, but a few points.

I will totally admit that a UL listing (or other NRTL listing) is necessary to meet the NEC in the US.

At the same time, a UL listing does you no good selling your product in the UK or Germany.


Does everyone know that UL is in fact a "Notified Body" under EU laws, and a company can utilize their relationship with UL to CE mark their product. So, in a way, UL does CE marking. A CE Mark from UL?!?!?!? Shocking huh?

The fact that the EU regulations around CE marking have, for some products, the ability of a manufacturer to 'self certify' their product (NOT their entire company or their quality system, just the product itself based on the overall maturity of their quality system) has been twisted into 'they just put a label on it'. Some fraudulent vendors will CE Mark illegally; some vendors place a CE meaning 'China export'...there will always be bad vendors, thieves. But there are also vendors that UL label a product with a counterfeit label, or fashion a symbol to fool consumers.

Why is it that people assume under UL there can be no cheats, but under CE there will be cheating? UL is not a regulator- it is a civil, business relationship- a contract- just two companies willingly working together. If a company doesn't get a UL listing, or cheats on their UL listing, there is virtually no penalty. The downside for cheating on UL and cheating on CE is, basically, the same. (Note: not sure if there are statutory laws in the EU for fraudulent CE marks.)

My point is that all this "UL is better than CE" or "UL is safer that self certifying CE" is nothing more than UL and US business interests trying to protect their business turf.

Live overseas, buy CE marked product- you will find a very robust, safe regulatory environment for products that are used day in and day out.

The concept that "here in America only UL makes us safe" is pretty silly.

open your minds a bit. Houses aren't burning down in the EU, people aren't being electrocuted. They are just two differnet systems that do the same thing.

 

[Infinia]

"My point is that all this "UL is better than CE" or "UL is safer that self certifying CE" is nothing more than UL and US business interests trying to protect their business turf."
This is nothing but an opinion. a false one at that! You tend to argue from a point of authority, but youre not , please cite some facts for a change.

As I said before CE self certifications is not the same thing as an independent not-profit 3rd party verification.
open your mind? I wonder about the root causes of the recent Greenfield tower fire and German VW software cheats, perhaps a glimpse of the future of a CE world. the only right thing you said, there are no punishments, no one will go to jail. full stop

UL markings can be copied but a UL listing number can also be verified.
CE is a move in the right direction, towards open market barriers v regulatory agencies. Self certifications is a joke.

 

[Matt Matt]

Here's some clarification.

What is a CE mark and is it equivalent to a UL Listing Mark?

A CE Marking is a European marking of conformity that indicates that a product complies with the requirements of the applicable European laws or directives. The European Community established the CE marking system to ensure free movement of products between member countries and to remove internal barriers to trade. The CE marking is a legally required marking in the European Union (EU) and applies to a variety of product categories. It is usually a manufacturer’s self-declaration that the product complies with European laws and may not include assessment to safety requirements.

Because most products bearing the CE mark are not required to be third-party certified, are not subject to ongoing factory surveillance of production, and may not be compliant with applicable U.S. product safety standards, they are not considered to be Listed as defined in NFPA and ICC model codes and standards.

A contractor wants to add UL labels to unlabeled products at the job site. Is this acceptable?

No, UL Marks may only be applied at manufacturing facilities authorized by UL. Any violations should be immediately reported to UL. The only exception is if UL authorizes the UL Mark to be applied in the field as a result of a field inspection. During a field inspection UL representatives determine if the product complies with applicable safety standards and requirements, and if compliance is determined product labeling is performed in the presence of the UL representative. However, this takes place only after the local authority having jurisdiction has been consulted.

UL field inspections are intended for installed equipment and products that have active UL certification but do not bear the UL Mark due to factory labeling errors, inadvertent removal of the label, or that have undergone minor modifications. To qualify for this service, the certified equipment or products must also have been manufactured at a UL-authorized manufacturing facility in accordance with UL's Follow-Up Services requirements and should not have been in use for more than one year or covered by the general coverage category for signs. If qualified, products/equipment can be labeled on the spot.

So basically, you're not allowed to modify the original product, you're not allowed to remove any electrical part or add any electrical parts. You're not allowed to drill any additional holes,...
Any modifications a field inspection is required.

http://www.ul.com/code-authorities/resources/faqs-for-code-authorities/

 

[ard]

"My point is that all this "UL is better than CE" or "UL is safer that self certifying CE" is nothing more than UL and US business interests trying to protect their business turf."
This is nothing but an opinion. a false one at that! You tend to argue from a point of authority , but youre not , please cite some facts for a change.

It is an opinion. Ive dont this for 25 or so years.

Your frantic need to defend this position is..uh..odd.

as I said before CE self certifications is not the same thing as an independent not-profit 3rd party verification.

UL not for profit? LOL

How many products have you contracted with UL to get UL/CSA listing?

open your mind? I wonder about the root causes of the recent Greenfield tower fire and German VW software cheats, perhaps a glimpse of the future of a CE world. the only right thing you said, there are no punishments, no one will go to jail. full stop

Was not aware UL is inspecting car emissions in the USA and thats why no US mfg has been caught. Good to know. Full stop

UL markings can be copied but a UL listing number can also be verified..

Still can be counterfeit, CE marking can likewise be verified,



So you are saying that all the medical devices in Europe that are 'self certified' are a joke?

You seem stuck on 'self certifying'. You actually dont know how CE marking works.

 

[Matt Matt]

So you are saying that all the medical devices in Europe that are 'self certified' are a joke?

You are comparing apples to oranges.

I think my original question was, does removing a ballast void UL certification?
I think your answer was "no it doesn't". Am I correct?

Edit: I see you modified your answer to something differant in post 4&6

 

[Infinia]

It is an opinion. Ive dont this for 25 or so years.

Your frantic need to defend this position is..uh..odd.

more "facts" from an authority LOL
You are the one who made the outrageous claim. I'm not the one defending it. Hold on, the odd thing is all the twisting this into the classic argument fallacies.

UL not for profit? LOL

yup look into it,
No one said theyre efficient and streamlined for the industries they serve.

How many products have you contracted with UL to get UL/CSA listing?

two, and one was successfully granted. The other one, who knows I didn't stick around in that career path. And you?

Was not aware UL is inspecting car emissions in the USA and thats why no US mfg has been caught. Good to know. Full stop

No the issue is 3rd party cert / verifications. In the VW example I cited, the agency is CARB. look it up.
Since no USA auto corporations have been caught yet, is the basis for your argument that California State agencies on behalf all USA Mfg is using pollution regulations against car imports from just Germany .. hmm distorted thinking. Excuse me, but your credibility has continually shrunken, it's almost nil by this point. I love a good conspiracy story as well as the next guy, but this is one isnt too good.

Still can be counterfeit, CE marking can likewise be verified,

really how does this work? with no unique numbers issued that consumers can see? Is there a web site I can punch in a brands product or model #.

So you are saying that all the medical devices in Europe that are 'self certified' are a joke?

no one said that, stop twisting my words.

You seem stuck on 'self certifying'. You actually dont know how CE marking works.

You actually don't have a clue how UL works.

hmm the last refuge of an authority figure when confronted is to revert the conversation back to what they know. I'm" stuck" sure thing bub.

 

[ard]

You are comparing apples to oranges.

I think my original question was, does removing a ballast void UL certification?
I think your answer was "no it doesn't". Am I correct?

Edit: I see you modified your answer to something differant in post 4&6

Actually I was incorrect about the NEC requring listed products, admited that and correct my post so as not to confuse anyone.

I was silent on the UL certification impact- others have addressed that.

Your concern about needing to maintain 'code' so as to not void your insurance was also addressed. You can do whatever you wish, as long as you dont willfully cause a loss.

 

[ard]

I'm" stuck" sure thing bub.

I guess we will agree to disagree.

There are two systems for regulation of product safety. NRTL listing in the US, CE marking in EU. Voluntary in the USA, mandatory in EU.

There are apparently many that feel that europe is 'unsafe' and the only safe country is the USofA.

Anyone still reading and not ready to jab sharp sticks in their eyes can draw their own conclusions.

 

[ard]

No the issue is 3rd party cert / verifications. In the VW example I cited, the agency is CARB. look it up. .

Didnt want to leave this go...

This wasnt CARB doing any kind of emissions testing...they didnt catch this as part of any regulatory action nor inspection.

CARB had commissioned a study at a university to help validate their presumed 'driving cycle' by commissioning real time, actual use driving data. (They wanted to see if their presumed 'driving profile' for emissions testing and pollution calculation was representative of actual use.) It was during this university lead study that this VW pollution scam was uncovered.

Had nothing to do with CARB's job as a regulator

Look it up

 

[Matt Matt]

Actually I was incorrect about the NEC requring listed products, admited that and correct my post so as not to confuse anyone.

I was silent on the UL certification impact- others have addressed that.

Your concern about needing to maintain 'code' so as to not void your insurance was also addressed. You can do whatever you wish, as long as you dont willfully cause a loss.

I think I mentioned something about CSA approval has very little leeway when modifying. But you group UL/CAS, this is a dual certificate. Soon as you modify anything CSA, even if it is it dual certificate, A new CSA certificate needs to be issued under CSA revisions. Not even an electrician, master electrician, a technologist can modify CSA without explicit CSA approval. So grouping both of these together is falsehood. Individually you might be able to modify UL, but the same doesn't partake with CSA.

Example, you are producing something that has CSA/UL approval. You modify this as a manufacture, you need a new CSA approval. As a manufacture, one of your representatives are allowed to take a CSA approval approving course, and have internal self approving(so long as that new internal inspector signs off on product produced) . I'm not sure if this is equal to UL.

Keep in mind I'm discussing consumer goods electrical only! Not any other manufacturing process or goods!

This is just like: you buy a toaster, you get home, you modify it to run on 240, you slap a stove plug on it because somebody on the Internet told you can do it safely, and then we have a trailer park on fire.

Oops, I forgot to tell you to fuse it properly and swap out the resister and heating coil.

Remember my last question in the first post???

 

[Infinia]

Didnt want to leave this go...

This wasnt CARB doing any kind of emissions testing...they didnt catch this as part of any regulatory action nor inspection.

CARB had commissioned a study at a university to help validate their presumed 'driving cycle' by commissioning real time, actual use driving data. (They wanted to see if their presumed 'driving profile' for emissions testing and pollution calculation was representative of actual use.) It was during this university lead study that this VW pollution scam was uncovered.

Had nothing to do with CARB's job as a regulatorLook it up

If not for CARB a 3rd party , VW would still be up to their tricks, CE or otherwise. I wonder what the EC actions were if any to account for VWs and now Porsche's sins?
CARB knew VW was doing something hanky. VW knew the SMOG testing methodology and designed their firmware around it. Plain and simple, a cheat. It would be silly and exorbitantly expensive to change all of CA SMOG tests just to uncover a bad apple. if CARB commissioned it how did they have nothing to do with it. They certainly did their job, a good job indeed. There is a regulation/ test and 'the letter of the law' you cant ignore the latter.
sheesh oh brother you really should of let it go! I think your missing the whole point and diverting one of my example to minutia and semantics.
Another example that your logic and conclusions are severely distorted to an extreme

 

[Matt Matt]

Another example that your logic and conclusions are severely distorted to an extreme

The next thing will be discussing is hockey helmets and their approvals. Or their third-party approval's. And then It will spin off into medical supplies or something of that such.

 

[Platonic Solid]

UL used to be Non-Profit. That changed in 2012.
(Not getting involved in the rest of whatever this is.)

 

[spudley]

And I'm trying to figure out why I read the whole thread...