September 24, 2019
By Michael Shulman, Principal Engineer, Lighting
UL’s General Coverage programs offer lighting manufacturers flexibility to apply UL Certification Marks to a wide range of sign or luminaire sizes and shapes. These programs combine our vast selection of approved (Listed or Recognized) components for pre-selection with specific design parameters and instructions for production-line testing. Through the General Coverage program, manufacturers can offer large catalogs of products built around common platforms that are customized to meet their customer/market preferences.
General Coverage relies on the manufacturer to understand and design within the scope of certain requirements in the relevant Standards: UL 48 for signs, UL 1598 for fixed luminaires and UL 153 for portable luminaires. The manufacturer is expected to identify the requirements from the Standard that apply to each new design, carry out production-line tests and maintain applicable documents for review by the UL field engineer during periodic visits. The manufacturer’s level of knowledge and quality control measures are important elements of these programs.
The General Coverage program concept is widely accepted to apply to designs that do not require a temperature test (i.e., temperature-test exempt). In reality, the program concepts broadly apply to many other luminaire design features that are documented as being “in accordance with the Standard.” The UL Follow-Up Inspection Instructions provide the guidance needed to apply these provisions of the General Coverage program.
Throughout the last decade, UL has collaborated with the sign industry to reverse earlier trends of deteriorating sign quality and resulting safety issues. One of the most impactful measures adopted was the Manufacturer’s Technical Representative (MTR) for which every sign manufacturer authorized to apply UL Marks is required to have at least one active employee who has completed online training for applying the UL 48 General Coverage program. The MTR provides a convenient means to onboard new production staff responsible for overseeing safety compliance, which can be especially critical during times of rapid personnel turnover. At times when UL field engineer visits do not align with production schedules, the availability of onsite trained MTRs and the convenience of the online training tools ensure the facility always has access to staff or a resource to detect and resolve common compliance issues.
The fixed and portable luminaire industry today faces challenges similar to those faced by the sign industry. A recent review of compliance data showed an increase in certain types of non-compliances, such as the use of components that are not pre-approved for General Coverage applications. It is vital for the General Coverage manufacturing staff to remain attentive to the requirements of the standard and the program rules because their downstream distributors and retailers expect delivery of fully compliant UL Listed products.
Based on the positive experience of the sign industry, UL decided to extend the MTR program to fixed and portable luminaires. Online training modules have been developed to address the core safety and design requirements of each standard (UL 1598 and UL 153) along with the key features and manufacturer’s responsibilities within the General Coverage program. The training is structured to benefit any staff applying the follow-up instructions and responsible to read and implement requirements from the relevant standards. The UL 1598 and UL 153 MTR programs were launched on June 1, with full implementation across all manufacturing sites (where the UL labels are applied) expected by the end of 2019. Eligible manufacturers can register at UL.com/LuminaireMTR.
The luminaire General Coverage MTR program is expected to not only increase accountability and decrease certain non-compliance findings, but also boost confidence in the downstream distribution chain all the way to the final purchaser. Its focus is to enhance the value of the UL Mark for manufacturers, AHJs and consumers, while reinforcing our partnership with manufacturers in building safer products.