April 2008
For regulatory authorities in the electrical inspection community.
Taking the Mystery
Out of UL’s
Follow-Up
Services
by Rich Berman
In 2007, more than 21 billion UL Marks were applied to products worldwide. Authorities
Having Jurisdiction (AHJs) and other electrical industry professionals often ask about UL’s
Marks and the methods we have in place to control products that bear the UL Mark.
The purpose of this article is to answer a few of these questions, such as:
• Why do some products have to use a
holographic UL Mark, while others don’t?
• How does UL guard against “speciallyconstructed” products being provided for
test, and then inferior products later sold
to the public?
• Does UL visit all manufacturing facilities,
regardless of where they are located?
• How does UL verify production material
composition, such as plastic compounds
or metal alloys?
Product Certification
It all begins with a product submittal, when a
manufacturer decides to submit their product
to UL for testing and certification. UL
technical staff members examine the product
and conduct appropriate tests in accordance
with the applicable standard. If all requirements are met, the manufacturer receives
authorization to apply the UL Mark.
At the conclusion of a product investigation,
UL prepares a “Follow-Up Services Procedure”
to describe and otherwise document critical
elements of the product’s construction.
Examples of critical elements include components, wire sizes and types, spacing, materials,
and dimensions.
Follow-Up Services
But it doesn’t end there. At the time that
certification is granted, Follow-Up Service
begins. Throughout the lifetime of the UL
certification, UL audits the manufacturer’s
production to monitor products coming off
the production line for conformance with the
Follow-Up Services Procedure.
UL field representatives conduct audits at all
locations where the product is manufactured
and where UL Marks are applied. UL has a
network of 126 inspection centers in 99
countries to perform this function. The
a supplement of
frequency of inspection is based on the product category or number of UL Marks applied.
At locations where production is infrequent,
manufacturers must submit to “productionready” visits by UL staff. In addition to factory
audits, UL staff members routinely select
samples from the open market to further verify
continued compliance with UL requirements.
UL Marks
Depending on the type of product and the certification service associated with that product,
manufacturers may either purchase labels with
UL Marks directly from UL or an authorized
label supplier. When authorized by UL, manufacturers may produce their own UL Marks,
using artwork approved by UL. UL certification markings can be applied on an adhesivebacked label, or through a molding, stamping,
etching or silk-screening process.
Continued on page 2
Electrical Connections
a supplement of The Code Authority®
Protecting the UL Mark from
Counterfeiters
As with other large companies with
desirable brands, counterfeit UL Marks
have been detected on some imported
electrical products. While this represents
only a small fraction of all UL Marks used
annually, UL takes an aggressive stance
with counterfeiters.
UL works closely with U.S. Customs and
Border Protection personnel and other law
enforcement personnel around the world to
provide the information necessary to distinguish between authentic and counterfeit UL
Marks. Since 1995, there have been more
than 1,300 seizures of counterfeit products
at entry ports in the U.S., preventing
millions of counterfeit product from
reaching consumers.
Holographic UL Marks
UL has mandated the use of holographic
labels for several product categories that
have been targeted by counterfeiters.
Holographic labels incorporate security
features making it very difficult for
counterfeiters to reproduce. See http://
www.ul.com/marks_labels/hologram.html
for a list of the product categories where
holographic UL Marks are required.
Manufacturers Must Control UL Marks
In addition to making sure that UL Marks
are affixed only to products that fully comply with UL requirements, the manufacturer
is required to assure that no references are
made to UL certification for products that
Published by the Regulatory Services
Department of Underwriters Laboratories
Inc.
© 2008. All rights reserved.
UL
are not authorized or do not fully comply
with UL requirements. This includes all
advertising materials, electronic references,
such as websites, email, etc., and all
promotional and trade show products and
literature.
Production line and other follow-up testing
is required for certain types of products.
Records of all required testing are required
be kept by the manufacturer for verification
by the local UL field staff. Such records
include:
April 2008
Design Changes
During the normal lifecycle of a product,
design changes are anticipated to provide
new features, substitute components or
materials, reduce costs, etc. Manufacturers are required to submit such changes
to UL prior to implementing them. UL evaluates all such revisions, and if acceptable,
authorizes the manufacturer to continue to
apply the UL Mark.
• Equipment and test methods used
• Frequency of testing and records
• Disposition or corrective action for
noncompliant products
• Calibration of test and measuring
equipment used as part of the FollowUp Services program
UL field representatives audit production,
checking products being manufactured to
verify that all details are consistent with the
original product tested and documented in
the Follow-Up Services Procedure.
Material Traceability
Nonmetallic components may be constructed from composites that provide
characteristics such as insulating properties
or protection against
environmental factors.
Metallic components may
be relied upon for physical strength or grounding.
Whatever the function, the
specific materials used in
the construction of products
may be critical to the ability
of that product to meet UL’s
requirements.
As any modifications to
materials could have a
detrimental effect on compliance with UL requirements, the manufacturer
assumes the responsibility that all materials
used in the construction of the product are
as described in the Follow-Up Services
Procedure. During periodic inspections, UL
field representatives verify that a manufacturer maintains traceability of materials.
Managing Editor: Rich Berman
+1-847-664-2554
Richard.Berman@us.ul.com
www.ul.com/tca
Variation Notices
Variation Notices are used by UL field
representatives to record observed differences between a product or manufacturing
process and a description in a Follow-Up
Services Procedure. Variation Notices
serve to document the manufacturer’s
construction changes, product noncompliances, factory test failures or other unusual
situations at the time of inspection. If
observed differences of critical elements
of the construction are noted, products
are not permitted to continue to bear a UL
Mark, until such time as additional testing or other investigation is completed to
determine continued compliance with UL
requirements.
UL Certification is Just the Beginning
As illustrated in this article, UL’s work is far
from over when we complete an investigation for certification of a manufacturer’s
product. Our relationship with the manufacturer continues as long as the manufacturer desires to use the UL Mark.
For more information about UL’s Follow-Up
Services, please contact Leon Przybyla at
+1-520-275-7298; or at Leon.J.Przybyla@
us.ul.com.
Editor: Heather Kile
+1-847-664-1265
Heather.Kile@us.ul.com
www.ul.com/tca