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Thomas Paterson
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 Posted: Mon Jul 28, 2008 7:19 pm Post subject: UL/ETL Choking the market |
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Dear All,
As a lighting designer with a lot of experience outside the US market
as well as within, I have a very low opinion of UL, not only its
implementation but also its fundamental logic for existence and
methods of development. I will refer to UL, but also mean its
competitors, ETL, etcetera.
In most of the world, standards are written to require manufacturers,
constructors, designers, all responsible parties, to meet minimum
standards ensuring real safety. The codes are written to restrict
design freedom the least possible, with descriptive, performance based
requirements. The codes enforced by UL, on the other hand, are highly
construction based, restrict potential design solutions to problems
and address perceived risk rather than real risk. One example of this
last point is the back housings on every US downlight. If a full back
housing was really necessary, Europe (which has nothing of the sort)
would have burned down many times over.
In practice, UL functions in a few ways. First, it restricts design
innovation. The cost of bringing a product to market, of having it
tested, prohibits manufacturers experimenting with new fixture
typologies, evolved aesthetics and innovative design solutions - an
assured market is required before it is worth the cost of testing.
This can be seen in the difference between Lightfair (one large
exhibition hall) and Light and Build, with over a dozen major halls.
It costs construction clients enormously. For example, where a
Lucifer Lighting downlight in the US costs (of order) US$200, its
European version (sans backbox, but with all required for safe and
functional installation) just under $100. So this is not something
without cost, this is costing the construction industry and their
clients massively.
It delays the development of custom luminaires, which is a huge issue
for fast-track projects, most notably retail, part of the market that
drives the economy.
It is supported by the electrical unions as their on-site electricians
refuse to install non-UL fixtures, to ensure that their union
colleagues retain their jobs in factories. I am a supporter of
unions, but I think that they would be better off in the long term
with a more dynamic, vibrant business environment with a growing
lighting export industry than a heavily defended industry hemorrhaging
jobs to the far east.
UL has become such a monster that they hired nothing less than the
entire facade of the Luxor hotel in Las Vegas for a sign stating that
"UL is... SAFETY".
What I want to do is start sounding out industry professionals to see
if there is enough interest in pushing for a restructuring of the
codes enforced by UL. A code which is based on international codes,
and reinforced where DEMONSTRABLE risks exist would be much more
sensible. But what would this mean for the US lighting manufacturing
industry?
Well, that>s where things get complicated. UL also acts as a massive
trade barrier. A foreign manufacturer wanting to export to the US has
to re-engineer their products to meet UL requirements, pay for the re-
engineering, re-tooling, certification, etcetera and only then can it
start marketing its products. So dropping UL would drop a massive
protection for the US market. Of course, with the Dutch Philips
rapidly buying up the market, that might not appear to be an issue,
but of course, it is.
But. UL has also become a massive drag on the US market. Back boxes,
for example, require a lot of labor and materials in their
construction. We now see Chinese manufacturers who can carry out
these operations faster and far cheaper, can now amortize the costs of
UL across a container or two of commodity luminaires, and still sell
cheaper than anything built in the US. Now UL requires more labor,
more materials, more storage, in total, more costs and against Chinese
and other low cost manufacturing environments, the only way to compete
is to minimize these elements. So although in the short term, an
influx of European luminaires would be a blow to the industry, it
would be temporary adjustment pain, where maintaining existing codes
are leading to a long, drawn out struggle against a stronger
manufacturing environment. What could defend against low cost mass
production? Design innovation.
Also, once markets have come into conformance, innovative US products
would be able to compete in the wider market without the costs of
reengineering or the inability to innovate within the local market.
Imagine opening up the world market for the products that the US
excels at!
Risk assessment is always difficult. The temptation is always there
to restrict perceived risk, however, the lighting industry is a very
mature industry with massive exposure. The whole world is our
actuarial table, where people are dying or being hurt by a hole in
standards, it is visible with simple statistical analysis and it is
possible to tighten codes. Where there is no statistical issue
demonstrable, why should we have a code to restrict design? A little
analysis of the backbox issue, for example, would reveal that they are
not necessary, because we can look at a population of over 400m
people, totaling billions of luminaires, without a statistically
significant rate of death.
Ultimately, UL benefits a few, but hurts the majority of the market,
it reduces design innovation (a cost against quality of life as well
as the market), costs a vast amount of money, drags fast projects, and
contributes little.
Is there an appetite amongst design professionals to start a letter
writing campaign on this one? What is the feeling in the wider
community?
Thomas. |
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Thomas Paterson
Guest
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| Posted: Wed Jul 30, 2008 4:13 pm Post subject: Re: UL/ETL Choking the market |
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On Jul 30, 9:02 am, Victor Roberts <x...@lighting-research.com> wrote:
[quote]On Mon, 28 Jul 2008 12:19:22 -0700 (PDT), Thomas Paterson
t_p_pater...@hotmail.com> wrote:
It is supported by the electrical unions as their on-site electricians
refuse to install non-UL fixtures, to ensure that their union
colleagues retain their jobs in factories. I am a supporter of
unions, but I think that they would be better off in the long term
with a more dynamic, vibrant business environment with a growing
lighting export industry than a heavily defended industry hemorrhaging
jobs to the far east.
You may, or may not, have some valid concerns about UL, but
when you start to blame the problem on unions I start to
wonder how seriously I should take your whole essay.
--
Vic Roberts
[/quote]
Vic,
I wouldn>t say that I blame this on unions at all, I>m very clear, my
issue is with the structure of the UL codes, how they>re written, how
they restrict innovation, require over-engineering. The point is that
union support means that there is an on-site enforcement that is not
actually mandated by law in all cases (it is in some, depending upon
jurisdiction), it is practical support for UL and associated codes.
Also, as I say, I actually support unions in general - in this case, I
question whether their support for UL genuinely supports their cause
in the long run.
I think that employment of US electricians in factories and in the
construction industry would be improved by more rational certification
processes for electrical products, the ability to have a vibrant
lighting export industry, etc. The US market is 300m people, the
world has over 6bn, if US lighting products were more competative,
contained less material content, they would be exportable.
Further, if US fixtures weren>t so over engineered, less money would
go on luminaires in building programs, freeing up more money for other
aspects of construction. Whether that would end up in electricians'
pockets is rather questionable, I wouldn>t argue that case, but it
would put more money into other trades.
Thomas. |
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Victor Roberts
Guest
|
| Posted: Wed Jul 30, 2008 7:02 pm Post subject: Re: UL/ETL Choking the market |
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On Mon, 28 Jul 2008 12:19:22 -0700 (PDT), Thomas Paterson
<t_p_paterson@hotmail.com> wrote:
[quote]Dear All,
As a lighting designer with a lot of experience outside the US market
as well as within, I have a very low opinion of UL, not only its
implementation but also its fundamental logic for existence and
methods of development. I will refer to UL, but also mean its
competitors, ETL, etcetera.
In most of the world, standards are written to require manufacturers,
constructors, designers, all responsible parties, to meet minimum
standards ensuring real safety. The codes are written to restrict
design freedom the least possible, with descriptive, performance based
requirements. The codes enforced by UL, on the other hand, are highly
construction based, restrict potential design solutions to problems
and address perceived risk rather than real risk. One example of this
last point is the back housings on every US downlight. If a full back
housing was really necessary, Europe (which has nothing of the sort)
would have burned down many times over.
In practice, UL functions in a few ways. First, it restricts design
innovation. The cost of bringing a product to market, of having it
tested, prohibits manufacturers experimenting with new fixture
typologies, evolved aesthetics and innovative design solutions - an
assured market is required before it is worth the cost of testing.
This can be seen in the difference between Lightfair (one large
exhibition hall) and Light and Build, with over a dozen major halls.
It costs construction clients enormously. For example, where a
Lucifer Lighting downlight in the US costs (of order) US$200, its
European version (sans backbox, but with all required for safe and
functional installation) just under $100. So this is not something
without cost, this is costing the construction industry and their
clients massively.
It delays the development of custom luminaires, which is a huge issue
for fast-track projects, most notably retail, part of the market that
drives the economy.
It is supported by the electrical unions as their on-site electricians
refuse to install non-UL fixtures, to ensure that their union
colleagues retain their jobs in factories. I am a supporter of
unions, but I think that they would be better off in the long term
with a more dynamic, vibrant business environment with a growing
lighting export industry than a heavily defended industry hemorrhaging
jobs to the far east.
UL has become such a monster that they hired nothing less than the
entire facade of the Luxor hotel in Las Vegas for a sign stating that
"UL is... SAFETY".
What I want to do is start sounding out industry professionals to see
if there is enough interest in pushing for a restructuring of the
codes enforced by UL. A code which is based on international codes,
and reinforced where DEMONSTRABLE risks exist would be much more
sensible. But what would this mean for the US lighting manufacturing
industry?
Well, that>s where things get complicated. UL also acts as a massive
trade barrier. A foreign manufacturer wanting to export to the US has
to re-engineer their products to meet UL requirements, pay for the re-
engineering, re-tooling, certification, etcetera and only then can it
start marketing its products. So dropping UL would drop a massive
protection for the US market. Of course, with the Dutch Philips
rapidly buying up the market, that might not appear to be an issue,
but of course, it is.
But. UL has also become a massive drag on the US market. Back boxes,
for example, require a lot of labor and materials in their
construction. We now see Chinese manufacturers who can carry out
these operations faster and far cheaper, can now amortize the costs of
UL across a container or two of commodity luminaires, and still sell
cheaper than anything built in the US. Now UL requires more labor,
more materials, more storage, in total, more costs and against Chinese
and other low cost manufacturing environments, the only way to compete
is to minimize these elements. So although in the short term, an
influx of European luminaires would be a blow to the industry, it
would be temporary adjustment pain, where maintaining existing codes
are leading to a long, drawn out struggle against a stronger
manufacturing environment. What could defend against low cost mass
production? Design innovation.
Also, once markets have come into conformance, innovative US products
would be able to compete in the wider market without the costs of
reengineering or the inability to innovate within the local market.
Imagine opening up the world market for the products that the US
excels at!
Risk assessment is always difficult. The temptation is always there
to restrict perceived risk, however, the lighting industry is a very
mature industry with massive exposure. The whole world is our
actuarial table, where people are dying or being hurt by a hole in
standards, it is visible with simple statistical analysis and it is
possible to tighten codes. Where there is no statistical issue
demonstrable, why should we have a code to restrict design? A little
analysis of the backbox issue, for example, would reveal that they are
not necessary, because we can look at a population of over 400m
people, totaling billions of luminaires, without a statistically
significant rate of death.
Ultimately, UL benefits a few, but hurts the majority of the market,
it reduces design innovation (a cost against quality of life as well
as the market), costs a vast amount of money, drags fast projects, and
contributes little.
Is there an appetite amongst design professionals to start a letter
writing campaign on this one? What is the feeling in the wider
community?
Thomas.
[/quote]
You may, or may not, have some valid concerns about UL, but
when you start to blame the problem on unions I start to
wonder how seriously I should take your whole essay.
--
Vic Roberts
http://www.RobertsResearchInc.com
To reply via e-mail:
replace xxx with vdr in the Reply to: address
or use e-mail address listed at the Web site.
This information is provided for educational purposes only.
It may not be used in any publication or posted on any Web
site without written permission. |
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RickR
Guest
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| Posted: Wed Jul 30, 2008 7:27 pm Post subject: Re: UL/ETL Choking the market |
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Perhaps a breakdown would help.
1. The codes themselves, are they too restrictive?
2. UL, as a organization, is it blocking improvements or adding an
independent review of the codes?
3. Is there an international set of codes that can be adopted instead
of the current practice?
4. Is prescriptive code acceptable, or is testing required?
A long time ago I drove a school bus and had parents, union, school
district and employer providing rules. I learned that you can never
decide for someone else how much safety is enough for them. The use of
lawyers is just an outgrowth of this basic function of human thought.
---------
RickR |
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Thomas Paterson
Guest
|
| Posted: Wed Jul 30, 2008 8:10 pm Post subject: Re: UL/ETL Choking the market |
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On Jul 30, 2:27 pm, RickR <r...@silhouettelights.com> wrote:
[quote]Perhaps a breakdown would help.
1. The codes themselves, are they too restrictive?
2. UL, as a organization, is it blocking improvements or adding an
independent review of the codes?
3. Is there an international set of codes that can be adopted instead
of the current practice?
4. Is prescriptive code acceptable, or is testing required?
A long time ago I drove a school bus and had parents, union, school
district and employer providing rules. I learned that you can never
decide for someone else how much safety is enough for them. The use of
lawyers is just an outgrowth of this basic function of human thought.
---------
RickR
[/quote]
Rick,
good point:
1. UL codes are too restrictive because:
a) They are based on perceived risk, rather than on analysis
of real world data.
b) They are prescriptive rather than performance based, ie,
they almost define design solutions, rather than mandating safety
levels.
c) They accumulate and are not retired or reviewed and eased
often enough.
d) They protect the US market from foreign imports, but also
prevent export by requiring over-engineering which makes the fixtures
unappealing to foreign buyers.
2. UL as an organization is a business, not a government agency, as
such, they make money from testing, the more rigorous the testing
requirements, the more money they make. As such, they have a conflict
of interests in reviewing, reducing, reforming codes in ways which
reduce the UL burden.
3. There are a range of international codes that could be adopted or
borrowed. ISO standardizes many things, but is not complete. CE is
Europe specific, but is much more sensible and there is no financial
interest the codes, so they are rational. Historically, there were
British Standards, which form the basis of Australian Standards, NZ
Standards. BS is now absorbing CE and ISO, so everything is
converging, except in the US.
4. Other vested interests in the US market are predicated on UL (such
as my comment about unions using it to defend factory jobs, but also
manufacturers, reps not wanting more competition to their lines,
etc). The only interests which would prefer not to deal with UL are
clients (for budget and freedom of choice reasons) and designers (for
freedom to choose the best from around the world).
5. Most of the rest of the world does not require testing.
Manufacturers assume liability for compliance when they put the
stickers on their products. If their product breaches code
requirements or is otherwise a safety hazard (a breach of the legal
principle of due diligence), they are liable for the products.
As such, they don>t spend time engineering to jump through other
people>s hoops, but engineer the best product and are responsible for
quality. This works just fine for most of the rest of the world.
And, if they want to have the device or item tested, that>s their
prerogative and it>s encouraged. There are plenty of labs out there.
I agree with your point about the question of how much safety is
enough safety, but when it comes to electrical devices, the public
don>t need to see it, don>t need to know. The advantage of UL or CE
is that if it has that stamp, the client assumes it is ok. We need
rational decision making behind those codes, so that they have the
confidence of the end user and can back that up. Where there is a
world market and they can see that in other markets, there isn>t a
problem without backboxes (for example), they should acknowledge that
and eliminate the requirement from code.
France has particularly tough material safety requirements with regard
to fire. However, to pass them, you need to be able to demonstrate
that your product won>t combust when touched with a 960°C hot wire for
a given period of time. It>s performance based, doesn>t define
acceptable materials, etcetera. That>s how to write codes.
The other point I>d make is simply to look at the anecdotal evidence -
look at the number of US lighting products used outside of the States
(virtually none other than lamps) and the relative scale, variation
and creativity of Lightfair relative to Light and Build. It>s 1:10
difference in number of manufacturers, etc, in a market which is only
slightly larger.
Thomas. |
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Thomas Paterson
Guest
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| Posted: Wed Jul 30, 2008 10:37 pm Post subject: Re: UL/ETL Choking the market |
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On Jul 30, 3:42 pm, "TKM" <nom...@no.net> wrote:
[quote]"Thomas Paterson" <t_p_pater...@hotmail.com> wrote in message
news:229621e1-323d-4c33-b12b-d775f31b1fbe@a6g2000prm.googlegroups.com...
Dear All,
As a lighting designer with a lot of experience outside the US market
as well as within, I have a very low opinion of UL, not only its
implementation but also its fundamental logic for existence and
methods of development. I will refer to UL, but also mean its
competitors, ETL, etcetera.
In most of the world, standards are written to require manufacturers,
constructors, designers, all responsible parties, to meet minimum
standards ensuring real safety. The codes are written to restrict
design freedom the least possible, with descriptive, performance based
requirements. The codes enforced by UL, on the other hand, are highly
construction based, restrict potential design solutions to problems
and address perceived risk rather than real risk. One example of this
last point is the back housings on every US downlight. If a full back
housing was really necessary, Europe (which has nothing of the sort)
would have burned down many times over.
In practice, UL functions in a few ways. First, it restricts design
innovation. The cost of bringing a product to market, of having it
tested, prohibits manufacturers experimenting with new fixture
typologies, evolved aesthetics and innovative design solutions - an
assured market is required before it is worth the cost of testing.
This can be seen in the difference between Lightfair (one large
exhibition hall) and Light and Build, with over a dozen major halls.
It costs construction clients enormously. For example, where a
Lucifer Lighting downlight in the US costs (of order) US$200, its
European version (sans backbox, but with all required for safe and
functional installation) just under $100. So this is not something
without cost, this is costing the construction industry and their
clients massively.
It delays the development of custom luminaires, which is a huge issue
for fast-track projects, most notably retail, part of the market that
drives the economy.
It is supported by the electrical unions as their on-site electricians
refuse to install non-UL fixtures, to ensure that their union
colleagues retain their jobs in factories. I am a supporter of
unions, but I think that they would be better off in the long term
with a more dynamic, vibrant business environment with a growing
lighting export industry than a heavily defended industry hemorrhaging
jobs to the far east.
UL has become such a monster that they hired nothing less than the
entire facade of the Luxor hotel in Las Vegas for a sign stating that
"UL is... SAFETY".
What I want to do is start sounding out industry professionals to see
if there is enough interest in pushing for a restructuring of the
codes enforced by UL. A code which is based on international codes,
and reinforced where DEMONSTRABLE risks exist would be much more
sensible. But what would this mean for the US lighting manufacturing
industry?
Well, that>s where things get complicated. UL also acts as a massive
trade barrier. A foreign manufacturer wanting to export to the US has
to re-engineer their products to meet UL requirements, pay for the re-
engineering, re-tooling, certification, etcetera and only then can it
start marketing its products. So dropping UL would drop a massive
protection for the US market. Of course, with the Dutch Philips
rapidly buying up the market, that might not appear to be an issue,
but of course, it is.
But. UL has also become a massive drag on the US market. Back boxes,
for example, require a lot of labor and materials in their
construction. We now see Chinese manufacturers who can carry out
these operations faster and far cheaper, can now amortize the costs of
UL across a container or two of commodity luminaires, and still sell
cheaper than anything built in the US. Now UL requires more labor,
more materials, more storage, in total, more costs and against Chinese
and other low cost manufacturing environments, the only way to compete
is to minimize these elements. So although in the short term, an
influx of European luminaires would be a blow to the industry, it
would be temporary adjustment pain, where maintaining existing codes
are leading to a long, drawn out struggle against a stronger
manufacturing environment. What could defend against low cost mass
production? Design innovation.
Also, once markets have come into conformance, innovative US products
would be able to compete in the wider market without the costs of
reengineering or the inability to innovate within the local market.
Imagine opening up the world market for the products that the US
excels at!
Risk assessment is always difficult. The temptation is always there
to restrict perceived risk, however, the lighting industry is a very
mature industry with massive exposure. The whole world is our
actuarial table, where people are dying or being hurt by a hole in
standards, it is visible with simple statistical analysis and it is
possible to tighten codes. Where there is no statistical issue
demonstrable, why should we have a code to restrict design? A little
analysis of the backbox issue, for example, would reveal that they are
not necessary, because we can look at a population of over 400m
people, totaling billions of luminaires, without a statistically
significant rate of death.
Ultimately, UL benefits a few, but hurts the majority of the market,
it reduces design innovation (a cost against quality of life as well
as the market), costs a vast amount of money, drags fast projects, and
contributes little.
Is there an appetite amongst design professionals to start a letter
writing campaign on this one? What is the feeling in the wider
community?
Thomas.
Thomas has given us a good bit to think about.
As part of a client consulting contract, I serve on three UL Standards
Technical Panels (STPs). The STPs are the committees that write the UL
standards. I>ve been part of the process for about 5 years now.
But, since I don>t work for U.L., and STP membership is a non-paying
volunteer position, I am interested in how the system might work better,
take less time, cost less and better serve the needs of the lighting
industry as well as users of the products.
So, to add to the discussion, let me start with a few observations:
- Fire and electrical safety are the main objectives for U.L. lighting
standards. The sense (while not stated) is that you can>t ever have enough
of either
- U.L. is a not-for-profit organization. In most other countries its
functions are handled by government departments.
- Product testing and standards development costs are paid virtually 100%
by customers, mostly manufacturers, via consulting and testing fees.
Luminaire
manufacturers, therefore, have a strong incentive to keep these costs low
and to react
promptly to any changes in standards which increase costs.
- Membership on the U.L. Standards Technical Panels is open and U.L., from
my experience, works to keep the STPs balanced and representative of
manufacturers, users and designers with a stake in the products involved.
The STP panel for UL1838 (Low Voltage Landscape Lighting Systems), for
example, has two of the top U.S. landscape lighting designers as members.
- The main lighting STPs (UL1598 - Luminaires and UL 153 - Portable
Electric
Luminaires) both have several manufacturers as members. Some are small
manufacturers; others represent the large consolidated brands. Usually the
committee members are technical or product engineering people, not luminaire
designers, and not from product management or marketing. In STP meetings or
discussions,
usually the cost and manufacturing viewpoints are front and center.
Sometimes design is brought in; but the discussions focus on products which
exist in physical form, not design or conceptual drawings.
-U.L. and CSA (Canadian Standards Association) are the two North American
organizations primarily involved in standards development. There are other
testing laboratories that test to U.L. or CSA standards and which can apply
their own marks to products; but which do not develop standards.
-Both U.L. and CSA have supported "harmonized" standards. UL1598, for
example, is virtually the same in the U.S. and Canada and efforts are
underway to make it a tri-national standard with Mexico. There>s a gradual
movement to harmonize North American with European standards as well.
Thomas, It isn>t clear to me that North American standards are more
restrictive than European standards. In fact, in a couple of specific
situations, I>ve found the reverse. But they are different and sometimes
the philosophy behind the standard is different too.
Your idea that "U.L. "restricts design" doesn>t follow from what I see in
the U.L. STPs where the manufacturers themselves have the power to object
and vote on proposals that seem unfair, raise costs or call for unnecessary
overdesign.
Terry McGowan
[/quote]
Terry,
I>d point out a couple of key points:
1. manufacturers who sit on these panels are unlikely to put in
restrictions that hurt their own business, but have no interest in
protecting other businesses - that doesn>t mean they shouldn>t be
involved, far from it. But, it does mean that anything that equally
adds costs to their competitors as well as to themselves has no
competative impact.
2. I do not assert that UL is tighter on all points, rather that it
is inflexible to points where it is over restrictive. There are
things done in the States which make european electricians squirm -
show wirenuts to some European electricians and see the response. The
trouble is that in spite of overwhelming evidence that some things are
not necessary, UL has not evolved - backboxes being a great example.
3. The idea that because people CAN sit on panels, doesn>t mean that
they do or feel empowered. I myself have sat on ANSI standards
writing committees through ESTA, so I am prepared to be involved in
such things, but most aren>t.
4. Committees are nice and democratic, but it doesn>t take looking
far to see where democracy, particularly optional participation
democracy has made some bad choices. Also, this shouldn>t be about
democracy, it should be about expertise in this case and actuarial
study - analysis of real risk, not perceived risk.
5. I am looking more at the actual market that operates under the UL
system, rather than UL itself. Are the products more expensive?
Generally yes. Are there less innovations? Yes? Are actually safe
devices prevented from being used? Yes.
That>s my basis for frustration.
T. |
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TKM
Guest
|
| Posted: Thu Jul 31, 2008 1:42 am Post subject: Re: UL/ETL Choking the market |
|
|
"Thomas Paterson" <t_p_paterson@hotmail.com> wrote in message
news:229621e1-323d-4c33-b12b-d775f31b1fbe@a6g2000prm.googlegroups.com...
[quote]Dear All,
As a lighting designer with a lot of experience outside the US market
as well as within, I have a very low opinion of UL, not only its
implementation but also its fundamental logic for existence and
methods of development. I will refer to UL, but also mean its
competitors, ETL, etcetera.
In most of the world, standards are written to require manufacturers,
constructors, designers, all responsible parties, to meet minimum
standards ensuring real safety. The codes are written to restrict
design freedom the least possible, with descriptive, performance based
requirements. The codes enforced by UL, on the other hand, are highly
construction based, restrict potential design solutions to problems
and address perceived risk rather than real risk. One example of this
last point is the back housings on every US downlight. If a full back
housing was really necessary, Europe (which has nothing of the sort)
would have burned down many times over.
In practice, UL functions in a few ways. First, it restricts design
innovation. The cost of bringing a product to market, of having it
tested, prohibits manufacturers experimenting with new fixture
typologies, evolved aesthetics and innovative design solutions - an
assured market is required before it is worth the cost of testing.
This can be seen in the difference between Lightfair (one large
exhibition hall) and Light and Build, with over a dozen major halls.
It costs construction clients enormously. For example, where a
Lucifer Lighting downlight in the US costs (of order) US$200, its
European version (sans backbox, but with all required for safe and
functional installation) just under $100. So this is not something
without cost, this is costing the construction industry and their
clients massively.
It delays the development of custom luminaires, which is a huge issue
for fast-track projects, most notably retail, part of the market that
drives the economy.
It is supported by the electrical unions as their on-site electricians
refuse to install non-UL fixtures, to ensure that their union
colleagues retain their jobs in factories. I am a supporter of
unions, but I think that they would be better off in the long term
with a more dynamic, vibrant business environment with a growing
lighting export industry than a heavily defended industry hemorrhaging
jobs to the far east.
UL has become such a monster that they hired nothing less than the
entire facade of the Luxor hotel in Las Vegas for a sign stating that
"UL is... SAFETY".
What I want to do is start sounding out industry professionals to see
if there is enough interest in pushing for a restructuring of the
codes enforced by UL. A code which is based on international codes,
and reinforced where DEMONSTRABLE risks exist would be much more
sensible. But what would this mean for the US lighting manufacturing
industry?
Well, that>s where things get complicated. UL also acts as a massive
trade barrier. A foreign manufacturer wanting to export to the US has
to re-engineer their products to meet UL requirements, pay for the re-
engineering, re-tooling, certification, etcetera and only then can it
start marketing its products. So dropping UL would drop a massive
protection for the US market. Of course, with the Dutch Philips
rapidly buying up the market, that might not appear to be an issue,
but of course, it is.
But. UL has also become a massive drag on the US market. Back boxes,
for example, require a lot of labor and materials in their
construction. We now see Chinese manufacturers who can carry out
these operations faster and far cheaper, can now amortize the costs of
UL across a container or two of commodity luminaires, and still sell
cheaper than anything built in the US. Now UL requires more labor,
more materials, more storage, in total, more costs and against Chinese
and other low cost manufacturing environments, the only way to compete
is to minimize these elements. So although in the short term, an
influx of European luminaires would be a blow to the industry, it
would be temporary adjustment pain, where maintaining existing codes
are leading to a long, drawn out struggle against a stronger
manufacturing environment. What could defend against low cost mass
production? Design innovation.
Also, once markets have come into conformance, innovative US products
would be able to compete in the wider market without the costs of
reengineering or the inability to innovate within the local market.
Imagine opening up the world market for the products that the US
excels at!
Risk assessment is always difficult. The temptation is always there
to restrict perceived risk, however, the lighting industry is a very
mature industry with massive exposure. The whole world is our
actuarial table, where people are dying or being hurt by a hole in
standards, it is visible with simple statistical analysis and it is
possible to tighten codes. Where there is no statistical issue
demonstrable, why should we have a code to restrict design? A little
analysis of the backbox issue, for example, would reveal that they are
not necessary, because we can look at a population of over 400m
people, totaling billions of luminaires, without a statistically
significant rate of death.
Ultimately, UL benefits a few, but hurts the majority of the market,
it reduces design innovation (a cost against quality of life as well
as the market), costs a vast amount of money, drags fast projects, and
contributes little.
Is there an appetite amongst design professionals to start a letter
writing campaign on this one? What is the feeling in the wider
community?
Thomas.
[/quote]
Thomas has given us a good bit to think about.
As part of a client consulting contract, I serve on three UL Standards
Technical Panels (STPs). The STPs are the committees that write the UL
standards. I>ve been part of the process for about 5 years now.
But, since I don>t work for U.L., and STP membership is a non-paying
volunteer position, I am interested in how the system might work better,
take less time, cost less and better serve the needs of the lighting
industry as well as users of the products.
So, to add to the discussion, let me start with a few observations:
- Fire and electrical safety are the main objectives for U.L. lighting
standards. The sense (while not stated) is that you can>t ever have enough
of either
- U.L. is a not-for-profit organization. In most other countries its
functions are handled by government departments.
- Product testing and standards development costs are paid virtually 100%
by customers, mostly manufacturers, via consulting and testing fees.
Luminaire
manufacturers, therefore, have a strong incentive to keep these costs low
and to react
promptly to any changes in standards which increase costs.
- Membership on the U.L. Standards Technical Panels is open and U.L., from
my experience, works to keep the STPs balanced and representative of
manufacturers, users and designers with a stake in the products involved.
The STP panel for UL1838 (Low Voltage Landscape Lighting Systems), for
example, has two of the top U.S. landscape lighting designers as members.
- The main lighting STPs (UL1598 - Luminaires and UL 153 - Portable
Electric
Luminaires) both have several manufacturers as members. Some are small
manufacturers; others represent the large consolidated brands. Usually the
committee members are technical or product engineering people, not luminaire
designers, and not from product management or marketing. In STP meetings or
discussions,
usually the cost and manufacturing viewpoints are front and center.
Sometimes design is brought in; but the discussions focus on products which
exist in physical form, not design or conceptual drawings.
-U.L. and CSA (Canadian Standards Association) are the two North American
organizations primarily involved in standards development. There are other
testing laboratories that test to U.L. or CSA standards and which can apply
their own marks to products; but which do not develop standards.
-Both U.L. and CSA have supported "harmonized" standards. UL1598, for
example, is virtually the same in the U.S. and Canada and efforts are
underway to make it a tri-national standard with Mexico. There>s a gradual
movement to harmonize North American with European standards as well.
Thomas, It isn>t clear to me that North American standards are more
restrictive than European standards. In fact, in a couple of specific
situations, I>ve found the reverse. But they are different and sometimes
the philosophy behind the standard is different too.
Your idea that "U.L. "restricts design" doesn>t follow from what I see in
the U.L. STPs where the manufacturers themselves have the power to object
and vote on proposals that seem unfair, raise costs or call for unnecessary
overdesign.
Terry McGowan |
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| Back to top |
Jeff Engel
Guest
|
| Posted: Thu Jul 31, 2008 7:07 am Post subject: Re: UL/ETL Choking the market |
|
|
Thomas Paterson wrote:
[quote]Dear All,
As a lighting designer with a lot of experience outside the US market
as well as within, I have a very low opinion of UL, not only its
implementation but also its fundamental logic for existence and
methods of development. I will refer to UL, but also mean its
competitors, ETL, etcetera.
In most of the world, standards are written to require manufacturers,
constructors, designers, all responsible parties, to meet minimum
standards ensuring real safety. The codes are written to restrict
design freedom the least possible, with descriptive, performance based
requirements. The codes enforced by UL, on the other hand, are highly
construction based, restrict potential design solutions to problems
and address perceived risk rather than real risk. One example of this
last point is the back housings on every US downlight. If a full back
housing was really necessary, Europe (which has nothing of the sort)
would have burned down many times over.
In practice, UL functions in a few ways. First, it restricts design
innovation. The cost of bringing a product to market, of having it
tested, prohibits manufacturers experimenting with new fixture
typologies, evolved aesthetics and innovative design solutions - an
assured market is required before it is worth the cost of testing.
This can be seen in the difference between Lightfair (one large
exhibition hall) and Light and Build, with over a dozen major halls.
It costs construction clients enormously. For example, where a
Lucifer Lighting downlight in the US costs (of order) US$200, its
European version (sans backbox, but with all required for safe and
functional installation) just under $100. So this is not something
without cost, this is costing the construction industry and their
clients massively.
It delays the development of custom luminaires, which is a huge issue
for fast-track projects, most notably retail, part of the market that
drives the economy.
It is supported by the electrical unions as their on-site electricians
refuse to install non-UL fixtures, to ensure that their union
colleagues retain their jobs in factories. I am a supporter of
unions, but I think that they would be better off in the long term
with a more dynamic, vibrant business environment with a growing
lighting export industry than a heavily defended industry hemorrhaging
jobs to the far east.
UL has become such a monster that they hired nothing less than the
entire facade of the Luxor hotel in Las Vegas for a sign stating that
"UL is... SAFETY".
What I want to do is start sounding out industry professionals to see
if there is enough interest in pushing for a restructuring of the
codes enforced by UL. A code which is based on international codes,
and reinforced where DEMONSTRABLE risks exist would be much more
sensible. But what would this mean for the US lighting manufacturing
industry?
Well, that>s where things get complicated. UL also acts as a massive
trade barrier. A foreign manufacturer wanting to export to the US has
to re-engineer their products to meet UL requirements, pay for the re-
engineering, re-tooling, certification, etcetera and only then can it
start marketing its products. So dropping UL would drop a massive
protection for the US market. Of course, with the Dutch Philips
rapidly buying up the market, that might not appear to be an issue,
but of course, it is.
But. UL has also become a massive drag on the US market. Back boxes,
for example, require a lot of labor and materials in their
construction. We now see Chinese manufacturers who can carry out
these operations faster and far cheaper, can now amortize the costs of
UL across a container or two of commodity luminaires, and still sell
cheaper than anything built in the US. Now UL requires more labor,
more materials, more storage, in total, more costs and against Chinese
and other low cost manufacturing environments, the only way to compete
is to minimize these elements. So although in the short term, an
influx of European luminaires would be a blow to the industry, it
would be temporary adjustment pain, where maintaining existing codes
are leading to a long, drawn out struggle against a stronger
manufacturing environment. What could defend against low cost mass
production? Design innovation.
Also, once markets have come into conformance, innovative US products
would be able to compete in the wider market without the costs of
reengineering or the inability to innovate within the local market.
Imagine opening up the world market for the products that the US
excels at!
Risk assessment is always difficult. The temptation is always there
to restrict perceived risk, however, the lighting industry is a very
mature industry with massive exposure. The whole world is our
actuarial table, where people are dying or being hurt by a hole in
standards, it is visible with simple statistical analysis and it is
possible to tighten codes. Where there is no statistical issue
demonstrable, why should we have a code to restrict design? A little
analysis of the backbox issue, for example, would reveal that they are
not necessary, because we can look at a population of over 400m
people, totaling billions of luminaires, without a statistically
significant rate of death.
Ultimately, UL benefits a few, but hurts the majority of the market,
it reduces design innovation (a cost against quality of life as well
as the market), costs a vast amount of money, drags fast projects, and
contributes little.
Is there an appetite amongst design professionals to start a letter
writing campaign on this one? What is the feeling in the wider
community?
Thomas.
UL has outlived its usefulness. When factory production of electrical[/quote]
products was in its infancy, the casualty insurance underwriters found
cause to come together in establishing safety standards. UL protected
insurers from faulty and risky products. Now the concerns for fault and
risk have evolved toward product liability. So essentially,
manufacturers pay twice: once to UL for a certification of compliance,
and second for liability legalities, and tort claims. Liability
exposure alone would serve as a deterrent against inherently dangerous
products. Underwriters Laboratories would disagree on a philosophical
basis, but it seems that the issue of risk management is now in the
hands of liability lawyers, not white lab coat guys. Large
manufacturers can afford to continue to pay tribute to the
"not-for-profit" UL juggernaut, and it might be a fairly cheap
reassurance that safety is certified. But in reality it is vigilance
against liability that drives safety implementation. If there was a
continuing viable function for Underwriters Laboratories, the costs
would still be absorbed by insurance companies who would be the direct
beneficiaries. UL is currently in the business of being UL. The best
recent evidence of their need to promote themselves came when LED
technology first got hot in the market. UL went from a "no need to
regulate" stance to a "we gotta get in the game" stance real suddenly.
What would happen if LEDs came into the country before UL had a chance
to pontificate? Free, unhindered enterprise? Not too likely with UL on
watch! |
|
| |
|
| Back to top |
Willy
Guest
|
| Posted: Fri Aug 01, 2008 2:07 am Post subject: Re: UL/ETL Choking the market |
|
|
"Jeff Engel" <searcher623@comcast.net> wrote in message
news:rpydnUuZF6rDsQzVnZ2dnUVZ_qadnZ2d@comcast.com...
[quote]Thomas Paterson wrote:
Dear All,
As a lighting designer with a lot of experience outside the US market
as well as within, I have a very low opinion of UL, not only its
implementation but also its fundamental logic for existence and
methods of development. I will refer to UL, but also mean its
competitors, ETL, etcetera.
In most of the world, standards are written to require manufacturers,
constructors, designers, all responsible parties, to meet minimum
standards ensuring real safety. The codes are written to restrict
design freedom the least possible, with descriptive, performance based
requirements. The codes enforced by UL, on the other hand, are highly
construction based, restrict potential design solutions to problems
and address perceived risk rather than real risk. One example of this
last point is the back housings on every US downlight. If a full back
housing was really necessary, Europe (which has nothing of the sort)
would have burned down many times over.
In practice, UL functions in a few ways. First, it restricts design
innovation. The cost of bringing a product to market, of having it
tested, prohibits manufacturers experimenting with new fixture
typologies, evolved aesthetics and innovative design solutions - an
assured market is required before it is worth the cost of testing.
This can be seen in the difference between Lightfair (one large
exhibition hall) and Light and Build, with over a dozen major halls.
It costs construction clients enormously. For example, where a
Lucifer Lighting downlight in the US costs (of order) US$200, its
European version (sans backbox, but with all required for safe and
functional installation) just under $100. So this is not something
without cost, this is costing the construction industry and their
clients massively.
It delays the development of custom luminaires, which is a huge issue
for fast-track projects, most notably retail, part of the market that
drives the economy.
It is supported by the electrical unions as their on-site electricians
refuse to install non-UL fixtures, to ensure that their union
colleagues retain their jobs in factories. I am a supporter of
unions, but I think that they would be better off in the long term
with a more dynamic, vibrant business environment with a growing
lighting export industry than a heavily defended industry hemorrhaging
jobs to the far east.
UL has become such a monster that they hired nothing less than the
entire facade of the Luxor hotel in Las Vegas for a sign stating that
"UL is... SAFETY".
What I want to do is start sounding out industry professionals to see
if there is enough interest in pushing for a restructuring of the
codes enforced by UL. A code which is based on international codes,
and reinforced where DEMONSTRABLE risks exist would be much more
sensible. But what would this mean for the US lighting manufacturing
industry?
Well, that>s where things get complicated. UL also acts as a massive
trade barrier. A foreign manufacturer wanting to export to the US has
to re-engineer their products to meet UL requirements, pay for the re-
engineering, re-tooling, certification, etcetera and only then can it
start marketing its products. So dropping UL would drop a massive
protection for the US market. Of course, with the Dutch Philips
rapidly buying up the market, that might not appear to be an issue,
but of course, it is.
But. UL has also become a massive drag on the US market. Back boxes,
for example, require a lot of labor and materials in their
construction. We now see Chinese manufacturers who can carry out
these operations faster and far cheaper, can now amortize the costs of
UL across a container or two of commodity luminaires, and still sell
cheaper than anything built in the US. Now UL requires more labor,
more materials, more storage, in total, more costs and against Chinese
and other low cost manufacturing environments, the only way to compete
is to minimize these elements. So although in the short term, an
influx of European luminaires would be a blow to the industry, it
would be temporary adjustment pain, where maintaining existing codes
are leading to a long, drawn out struggle against a stronger
manufacturing environment. What could defend against low cost mass
production? Design innovation.
Also, once markets have come into conformance, innovative US products
would be able to compete in the wider market without the costs of
reengineering or the inability to innovate within the local market.
Imagine opening up the world market for the products that the US
excels at!
Risk assessment is always difficult. The temptation is always there
to restrict perceived risk, however, the lighting industry is a very
mature industry with massive exposure. The whole world is our
actuarial table, where people are dying or being hurt by a hole in
standards, it is visible with simple statistical analysis and it is
possible to tighten codes. Where there is no statistical issue
demonstrable, why should we have a code to restrict design? A little
analysis of the backbox issue, for example, would reveal that they are
not necessary, because we can look at a population of over 400m
people, totaling billions of luminaires, without a statistically
significant rate of death.
Ultimately, UL benefits a few, but hurts the majority of the market,
it reduces design innovation (a cost against quality of life as well
as the market), costs a vast amount of money, drags fast projects, and
contributes little.
Is there an appetite amongst design professionals to start a letter
writing campaign on this one? What is the feeling in the wider
community?
Thomas.
UL has outlived its usefulness. When factory production of electrical
products was in its infancy, the casualty insurance underwriters found
cause to come together in establishing safety standards. UL protected
insurers from faulty and risky products. Now the concerns for fault and
risk have evolved toward product liability. So essentially, manufacturers
pay twice: once to UL for a certification of compliance, and second for
liability legalities, and tort claims. Liability exposure alone would
serve as a deterrent against inherently dangerous products. Underwriters
Laboratories would disagree on a philosophical basis, but it seems that
the issue of risk management is now in the hands of liability lawyers, not
white lab coat guys. Large manufacturers can afford to continue to pay
tribute to the "not-for-profit" UL juggernaut, and it might be a fairly
cheap reassurance that safety is certified. But in reality it is
vigilance against liability that drives safety implementation. If there
was a continuing viable function for Underwriters Laboratories, the costs
would still be absorbed by insurance companies who would be the direct
beneficiaries. UL is currently in the business of being UL. The best
recent evidence of their need to promote themselves came when LED
technology first got hot in the market. UL went from a "no need to
regulate" stance to a "we gotta get in the game" stance real suddenly.
What would happen if LEDs came into the country before UL had a chance to
pontificate? Free, unhindered enterprise? Not too likely with UL on
watch!
[/quote]
AS an outsider that has been reading this thread since Tom started it, I
have one question.
As I understand it, UL is completely voluntary.
If that is actually true, why wouldn>t a manufacturer choose to step away
from UL approval? Is it purely a liability issue?
Willy |
|
| |
|
| Back to top |
Jeff Engel
Guest
|
| Posted: Fri Aug 01, 2008 5:58 am Post subject: Re: UL/ETL Choking the market |
|
|
Willy wrote:
[quote]"Jeff Engel" <searcher623@comcast.net> wrote in message
news:rpydnUuZF6rDsQzVnZ2dnUVZ_qadnZ2d@comcast.com...
Thomas Paterson wrote:
Dear All,
As a lighting designer with a lot of experience outside the US market
as well as within, I have a very low opinion of UL, not only its
implementation but also its fundamental logic for existence and
methods of development. I will refer to UL, but also mean its
competitors, ETL, etcetera.
In most of the world, standards are written to require manufacturers,
constructors, designers, all responsible parties, to meet minimum
standards ensuring real safety. The codes are written to restrict
design freedom the least possible, with descriptive, performance based
requirements. The codes enforced by UL, on the other hand, are highly
construction based, restrict potential design solutions to problems
and address perceived risk rather than real risk. One example of this
last point is the back housings on every US downlight. If a full back
housing was really necessary, Europe (which has nothing of the sort)
would have burned down many times over.
In practice, UL functions in a few ways. First, it restricts design
innovation. The cost of bringing a product to market, of having it
tested, prohibits manufacturers experimenting with new fixture
typologies, evolved aesthetics and innovative design solutions - an
assured market is required before it is worth the cost of testing.
This can be seen in the difference between Lightfair (one large
exhibition hall) and Light and Build, with over a dozen major halls.
It costs construction clients enormously. For example, where a
Lucifer Lighting downlight in the US costs (of order) US$200, its
European version (sans backbox, but with all required for safe and
functional installation) just under $100. So this is not something
without cost, this is costing the construction industry and their
clients massively.
It delays the development of custom luminaires, which is a huge issue
for fast-track projects, most notably retail, part of the market that
drives the economy.
It is supported by the electrical unions as their on-site electricians
refuse to install non-UL fixtures, to ensure that their union
colleagues retain their jobs in factories. I am a supporter of
unions, but I think that they would be better off in the long term
with a more dynamic, vibrant business environment with a growing
lighting export industry than a heavily defended industry hemorrhaging
jobs to the far east.
UL has become such a monster that they hired nothing less than the
entire facade of the Luxor hotel in Las Vegas for a sign stating that
"UL is... SAFETY".
What I want to do is start sounding out industry professionals to see
if there is enough interest in pushing for a restructuring of the
codes enforced by UL. A code which is based on international codes,
and reinforced where DEMONSTRABLE risks exist would be much more
sensible. But what would this mean for the US lighting manufacturing
industry?
Well, that>s where things get complicated. UL also acts as a massive
trade barrier. A foreign manufacturer wanting to export to the US has
to re-engineer their products to meet UL requirements, pay for the re-
engineering, re-tooling, certification, etcetera and only then can it
start marketing its products. So dropping UL would drop a massive
protection for the US market. Of course, with the Dutch Philips
rapidly buying up the market, that might not appear to be an issue,
but of course, it is.
But. UL has also become a massive drag on the US market. Back boxes,
for example, require a lot of labor and materials in their
construction. We now see Chinese manufacturers who can carry out
these operations faster and far cheaper, can now amortize the costs of
UL across a container or two of commodity luminaires, and still sell
cheaper than anything built in the US. Now UL requires more labor,
more materials, more storage, in total, more costs and against Chinese
and other low cost manufacturing environments, the only way to compete
is to minimize these elements. So although in the short term, an
influx of European luminaires would be a blow to the industry, it
would be temporary adjustment pain, where maintaining existing codes
are leading to a long, drawn out struggle against a stronger
manufacturing environment. What could defend against low cost mass
production? Design innovation.
Also, once markets have come into conformance, innovative US products
would be able to compete in the wider market without the costs of
reengineering or the inability to innovate within the local market.
Imagine opening up the world market for the products that the US
excels at!
Risk assessment is always difficult. The temptation is always there
to restrict perceived risk, however, the lighting industry is a very
mature industry with massive exposure. The whole world is our
actuarial table, where people are dying or being hurt by a hole in
standards, it is visible with simple statistical analysis and it is
possible to tighten codes. Where there is no statistical issue
demonstrable, why should we have a code to restrict design? A little
analysis of the backbox issue, for example, would reveal that they are
not necessary, because we can look at a population of over 400m
people, totaling billions of luminaires, without a statistically
significant rate of death.
Ultimately, UL benefits a few, but hurts the majority of the market,
it reduces design innovation (a cost against quality of life as well
as the market), costs a vast amount of money, drags fast projects, and
contributes little.
Is there an appetite amongst design professionals to start a letter
writing campaign on this one? What is the feeling in the wider
community?
Thomas.
UL has outlived its usefulness. When factory production of electrical
products was in its infancy, the casualty insurance underwriters found
cause to come together in establishing safety standards. UL protected
insurers from faulty and risky products. Now the concerns for fault
and risk have evolved toward product liability. So essentially,
manufacturers pay twice: once to UL for a certification of compliance,
and second for liability legalities, and tort claims. Liability
exposure alone would serve as a deterrent against inherently dangerous
products. Underwriters Laboratories would disagree on a philosophical
basis, but it seems that the issue of risk management is now in the
hands of liability lawyers, not white lab coat guys. Large
manufacturers can afford to continue to pay tribute to the
"not-for-profit" UL juggernaut, and it might be a fairly cheap
reassurance that safety is certified. But in reality it is vigilance
against liability that drives safety implementation. If there was a
continuing viable function for Underwriters Laboratories, the costs
would still be absorbed by insurance companies who would be the direct
beneficiaries. UL is currently in the business of being UL. The best
recent evidence of their need to promote themselves came when LED
technology first got hot in the market. UL went from a "no need to
regulate" stance to a "we gotta get in the game" stance real suddenly.
What would happen if LEDs came into the country before UL had a chance
to pontificate? Free, unhindered enterprise? Not too likely with UL
on watch!
AS an outsider that has been reading this thread since Tom started it, I
have one question.
As I understand it, UL is completely voluntary.
If that is actually true, why wouldn>t a manufacturer choose to step
away from UL approval? Is it purely a liability issue?
Willy
Commercial building projects are inspected during construction for[/quote]
safety, and UL is the de facto mandatory standard. Some inspectors will
not approve ETL rated fixtures without a big brouhaha about equivalence.
So UL/ETL listing is not really optional. Without ETL, UL would almost
be a monopoly, and a "not-for-profit" monopoly at that! The status quo
is so long established that the lighting and electrical products
industry can only pay homage to the Elephant in the room. What Mr.
Patterson and i are pointing out is that UL is expensive and inflexible.
For example: a desirable designed wall scone that is UL approved is
needed with a switch on the body rather than being hard wired. Can the
manufacturer make a batch with this very simple starightforward
modification? NO! UL approval will be needed for the variation. And what
will that add to the cost of the fixture? WAY TOO MUCH, forcing the
specifier to re-select a less desirable fixture. Do the mega-major
industrial conglomerates worry about this? No need to, since they have
the UL process running "in-house". But for a small innovator to get the
approval needed for a one time sale, the waiting and cost are
prohibitive. |
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