Small Business: Navigating the Product Safety Certification Process

Andrew DeIonno
With planning and preparation, the certification process can go smoothly—even with limited resources.

Product safety certification is not usually number one on the list of things to do for any company, regardless of the company size. Usually a higher priority (oftentimes number one) is to make money by manufacturing and selling products. Many companies do embrace the safety certification process because it assists, in one way or another, in the bottom line. Safety certification can affect the bottom line by limiting liability exposure, decreasing time to market, and providing a safety marketing advantage.

The product safety certification process can seem daunting when the company is small. Small companies tend to have limited resources, a great product, and a few talented people. However, they often lack the finances to maintain a full test lab and a full-time regulatory engineer.

With a little planning, a little expansion of job responsibilities for talented engineers, and a lot of questions, a small business can manage the maze of product safety certification.

Where to Start

A great start is to begin investigating testing certification laboratories. The most commonly known is Underwriters Laboratories (UL), but it is important to realize that they are not the only test labs available. Test labs receive accreditations, one of which is to be named a Nationally Recognized Testing Laboratory (NRTL) through the Occupational Safety and Health Administration (OSHA). OSHA's Web site provides a list of accredited NRTLs, their testing locations, and contact information.

With this information, it is possible to eliminate laboratory locations that are too far away if proximity is a concern. If distance does not matter, other key considerations include:

• Possible travel costs to the lab (to address issues during the certification process).
• Freight costs for shipping samples to the lab, especially if the product is large or heavy.
• Time zone differences (particularly East to West Coast).
• Whether the test lab can perform all tests at one facility or whether some tests will need to be done at sister labs.
• Scope of accreditation (for NRTL program).

• Marketing slicks (sales sheets) to help the lab understand how the product is intended to be used.
• Electrical schematics for all circuitry that interfaces with safety features, high-voltage components (generally low voltage is supplied by one of the following: a battery, a Class 2 transformer, or a circuit that meets the requirements of a Class 2 power source).
• A working, salable sample of each product. This will be sent to the selected lab.
• Conditions of acceptability for critical components (usually loads or power conversion devices such as motors, transformers, power supplies, etc.). Make sure the current design addresses all of the conditions.
• Operation and maintenance manuals (if available).
• A list of components (bill of materials with each component's electrical and mechanical ratings).
• All accessories.

Contact the labs of interest, and supply the paperwork on the product. Request a formal written quote for the listing. During this step, instincts become critical. Remember that you are the customer, and you should expect reasonable deliveries on quotes. If the lab doesn't seem interested in your business, scratch them off the list. For the labs that respond, read the quote carefully and note questions as you review it.

Cost is an important consideration, but it should not be the only one. A well-written quote should disclose a time frame for completion of the listing, the standards to be used for the evaluation, and the fences or boundaries of the quote's scope in addition to the cost of doing the testing.

The Time Frame. The time frame is an estimate. It is generally based on a product complying with all of the requirements the first time through the process. The process consists of three main parts: the construction review (clause-by-clause review of the standard for the product), the testing (this is defined in the standard for a given product), and the report (highlights all of the critical safety features of a given product). Deficiencies in any of these areas could lead to a cost increase or increases. The increases are usually significant when compared with the original project estimates. It is important to avoid any reinspections, evaluations, or testing failures.

The Standards. The standards are the rulebook. The test lab will evaluate all standards that apply to the product. An old saying is quite appropriate here: to win you have to know the rules. So spend some up-front money and buy the applicable standards. Before starting the project, have the company's talented engineers review the product design to these standards. Also, know the results of as many tests as possible (preferably all applicable tests). If tests must be limited, then do the most important tests (e.g., normal temperature and abnormal operation). An honest assessment can save time and money. Correct all problem areas before submitting the product to the test lab.

The Scope. The quote's scope may only indicate, for example, that the listing is to UL Standard 73 (Motor-Operated Equipment). The quote often does not list other critical items. The fences are critical and may or may not be stated. Some hidden common fences are these:

• A product contains components that are not already certified. If these components cannot be replaced with certified components, then they must be evaluated.
• A product is deficient in construction. This happens primarily to manufacturers who do not read and apply the standard.
• A product fails testing. Failed tests result in the need to correct the deficiencies and resubmit the product for additional testing.
• A product contains a feature outside the scope of the quoted standard. This occurs when the lab has insufficient product information and makes a best guess at the scope. If organized documentation is supplied to the lab for the quote, this pitfall should be avoidable. If the lab still doesn't seem to understand a feature, then set up a visit to present a demonstration. It isn't free, but it will bring the lab up to speed more quickly. This will, in the long run, save time and money. Do such presentations only with the lab that will be conducting the tests.

The Questions. Don't be afraid to ask questions. The right lab should help clients feel comfortable about its services and should be able to provide answers to any questions about what is covered in the quote.

Select a lab that has the best fit. Some features that make a lab attractive include accessibility of the engineers for questions; quote response time; responsiveness during quoting, follow-up on the quote; willingness to answer questions about the quote; and general professionalism.

Making the Deal

Close the project with the lab and begin the certification process. If the responsible engineers have done their homework (read the standard, performed the tests, evaluated the design), then the product will stand a very good chance of passing the first time. If it doesn't pass, these activities still should enable the engineers to professionally discuss the interpretations of the standard.

Conclusion

This process can be handled by a few key talented people: a finance person for the quote, an engineer for the evaluation and listing, and a manager to lead the small team. Being prepared—reading the standard and incorporating necessary changes into the design—speeds the process. Being organized—preparing a docket of technical information—will assist the lab in the evaluation. By asking questions, understanding the fences, and knowing the process, the product safety certification process will go smoothly and easily.

Andrew DeIonna has more than 10 years of product safety and regulatory engineering with two different laboratories (ETL/ Semko and MET). He is currently product safety manager for Applica Consumers Products. He can be reached at ddeionno@earthlink.net.