UL’s Industry File Review process has, until recently, been the sole method UL uses review and update products when standards change in order to maintain certifications on products carrying the UL Mark.
But the introduction of a second product review process at UL, the Continuing Certification Program (CCP), promises to maintain UL’s peerless reputation for helping to ensure product safety while better addressing the practical considerations any standards change imposes on manufacturers.
An Industry File Review (IFR) has long been UL’s method of keeping products it certifies in line with updated standards. To do this, UL first determines whether an upgraded standard should lead to a change in a UL certified product. If so, an IFR Announcement/Action Required letter is sent to manufacturers of UL certified products, letting them know their currently certified products may no longer comply with the updated UL Standard. UL would then initiate a product review evaluation to determine compliance with the updated standard.
Manufacturers of products identified through this process sometimes faced having to make significant changes to their assembly processes under strict deadlines in order to maintain a product’s UL Mark, often incurring unexpected and unwanted expenses to comply.
To address these legitimate concerns, UL developed the Continuing Certification pilot program as an alternative to the IFR process.
The key change defining the CCP is that UL’s independent expert councils used to review standards and provide input for their development, the Standards Technical Panels (STP), would be integrated into the product review process. This means that STP members now have the opportunity to advise UL in determining the course of action in applying the required changes to products.
During a CCP, the STP members, who normally participate in UL’s Collaborative Standards Development System (CSDS), would be required to vote during this participation on whether they believe the new requirements are or are not substantially different enough than the present ones to require that a manufacturer meet the new or revised requirements. The STP vote would assist the Certification Body of UL in making that decision.
If no changes are required, as determined by the Certification Body’s decision, then manufacturers can continue to use the UL Mark on these products without submitting them to an IFR. This can continue as long as there are no changes to the product requiring a Certification Decision or no changes to requirements that mandate a review. However, if a change is required, all present UL certified products affected by the decision need to be re-evaluated to what is required in the newest version of the UL Standard.
Those with questions about the process can contact Senior Staff Engineer Bill Carney at (847) 664-1088. To link to UL’s online Standards Technical Panel page, refer to http://ulstandards.ul.com/develop-standards/proposals/