Variation notices FAQ
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Where can I find more information about Follow-Up Services?
Please visit our Global Field Services Web Site at http://www.ul.com/ for additional information on Follow-Up Services. In addition, there is a document called "UL Variation Notice and Corrective Action Requirements" that helps UL customers become more familiar with the Variation Notice process, available here: Variation_Notice_And_Corrective_Action_Requirements
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How and when is a variation notice issued?
When a product does not comply with the Follow-Up Service Procedure, applicable standard or other requirements, UL field representatives document the nonconformance on a variation notice (VN). A variation notice is a channel of communication between UL and a manufacturer and creates a record when nonconformances are discovered.
When a nonconformance is found in the field or during a Follow-Up Service visit at the factory, it is important for a customer to address not only the product nonconformance, but also any underlying process or system issue that may have led to nonconformance. Appropriate containment and system-level corrective action are necessary to assure that all products bearing the UL Mark comply with all requirements, and that action is taken to reduce the likelihood of the same nonconformance from recurring.
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What are the manufacturer’s options and responsibilities to resolve items written on the variation notice?
When a VN is issued, a manufacturer has three options for handling nonconforming UL Marked products:
- Modify all nonconforming UL Marked products to bring them into compliance with the Follow-Up Service Procedure or any other requirements.
- Remove any markings on the product referring to UL, or obliterate these markings if the marking is imprinted, die-stamped, molded, etc.
- Request temporary acceptance of the revised construction from UL. By informing the field representative, UL will review and determine whether shipment can continue for a limited period of time, or if shipment must be discontinued. Regardless of this decision, longer-term authorization to use the UL Mark with a revised construction can only be obtained after an applicant contacts UL Customer Service to request a permanent change in the Follow-Up Services Procedure.
In addition to any option above, a manufacturer should investigate the root cause of the VN and take action to prevent a nonconformance from recurring. Examples of such actions include providing additional training, revising work instructions, providing job aids, revising engineering change and procurement processes, etc. While a formal written corrective action plan is not currently required, a UL field representative will review the proposed action with a manufacturer before closing the VN.
Manufacturers are encouraged to discuss ongoing corrective actions with their field representative, who may be able to provide assistance or share resources available from UL to implement effective corrective actions.
A manufacturer is responsible for forwarding a copy of the VN to the applicant. In addition, variation notices are available to both manufacturers and applicants at UL's customer portal, https://my.secure.home1.ul.com/.
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How are non-conformances of a variation notice handled within UL's Engineering Department?
For the UL review of some or all nonconformances, also called "Variation Items", UL's Engineering Department may be involved. Upon the completion of this review, the Applicant will receive an Engineering Resolution Letter that provides a clear resolution for each nonconformance, identifying whether each item is acceptable or unacceptable. The manufacturer and UL Field Representative will be sent copies of this letter to keep everyone informed.
Please note that this only applies to Variation Items that needed involvement of UL's Engineering Department as referenced in the Engineering Resolution Letter. If multiple Variation Items have been noted for the same product, all items must be found acceptable before the new construction is eligible to bear the UL Mark.
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Why is it important for a manufacturer to prevent the occurrence of variation notices?
It is in the best interest of manufacturers and UL to prevent the occurrence of variation notices since both parties share a mutual goal of having only products that meet requirements introduced into the supply chain and identified by the presence of the UL Mark on the product. Variation Notices can cause production interruptions depending upon the nature and severity of the nonconformance.
In addition, Variation Notices and other information relative to a manufacturer's nonconformance history, if significant, can lead to a UL decision to institute a Customer Corrective Action Process designed to assist the manufacturer improve their process controls and to ensure products intending to bear the UL Mark comply with UL requirements. This may result in the manufacturer incurring additional costs associated with the resolution of the Variation Notice as well as possible increased inspection/audit visits.
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What can the manufacturer do to prevent the occurrence of variation notices?
One of the common reasons a manufacturer receives variation notices is incorporating product construction changes not covered in the Follow-Up Service Procedure. To prevent this, an applicant should submit any product construction changes to UL for evaluation and acceptance before the changes are incorporated into products that are intended to bear UL Marks. Another common reason for receiving a variation notice is a component substitution not covered in the Follow-Up Service Procedure. To prevent issues with component selection, manufacturers should request that the applicant obtain UL authorization before proceeding with the component substitutions.
Another common reason that variation notices may be issued is the inability to verify that components and materials utilized in the product meet the stated requirements defined in the Follow-Up Service procedure. To understand traceability requirements, applicants should discuss this with UL's Conformity Assessment Services Department during the product investigation to determine what the component/material traceability expectations will be during routine factory inspections/audits. UL has additional information available regarding traceability requirements at the following location: UL_Traceability_Requirements
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Who can I contact to discuss product changes or other questions concerning UL Procedure requirements?
You can discuss any questions with your local field services representative, your customer service professional or your normal conformity assessment services contact.
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What is a VN fee?
The Variation Notice fee covers UL's efforts to determine that all variations documented have been properly addressed and that products carrying the UL Mark continue to comply with requirements. It also includes confirmation activities performed by field staff to verify corrective actions implemented by a manufacturer. This fee does not apply if ALL Variation Items are resolved as typographical errors by UL.
