Memorandum of Understanding?

Memorandum of Understanding?

Presently there exists between UL and CSA a Memorandum of Understanding on evaluations of end products and component products (UL_CSA MOU.cfm). The MOU was jointly developed by UL and CSA at the manufacturers request in order to reduce duplicity of testing by having only one agency, either UL or CSA, test a given product covering its use in either or both countries. For some products, the MOU has worked well and saved time. Less success has been seen for components. And in the 5 years, expansion of the MOU to cover other products has ground to a halt.  Some NEMA members are pretty frustrated with the lack of progress and are wondering why isn’t it working? 

Both UL and CSA commonly referred to as SDO’S (Standard Development Organizations) routinely List and Certify products to minimum electrical safety (fire and shock hazard) requirements and are mutually accredited in accordance with both OSHA (US) and Standards Council of Canada (Canada) guidelines. This accreditation by both UL and CSA requires (as a prerequisite) that they both employ a documented quality management system that follow the ISO/IEC 17025 standard outline (used by testing and calibration laboratories world wide) in order to implement quality systems aimed at improving their ability to consistently produce valid results which is a prerequisite for accreditation from an Accreditation Body. In fact, all OSHA Nationally Recognized Testing Laboratories (NRTL’s) such as UL, CSA, and ETL, use ISO/IEC 17025.

What NEMA members want to know is; why most of the accredited NRTL’s in North America are willing to accept valid product test data from each other, except UL? Especially in cases where the laboratories providing the needed assessment; 

  • are equally accredited,
  • have published an MOU
  • use harmonized standards developed under CANENA,
  • maintain follow-up product oversight and in some instances;
  • employ the very same test facility, laboratory equipment and test technicians where product test data is submitted under oversight of DAP and CATEGORY compliance programs?

Given the amount of effort and resources expended on the UL/CSA MOU, CANENA Harmonization efforts and DAP/Category programs by manufacturers and SDO’s alike, shouldn’t a compliant manufacturer be enabled to move more efficiently through the conformity assessment process, regardless of who provides the service?

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