UL-298-BULLETINS-2004.pdf

Subject 153 (298) (in reply, refer to Subject 153) 12 Laboratory Drive Research Triangle Park, NC 27709 November 11, 2004 TO: Standards Technical Panel (STP) for Portable Electric Luminaires Subscribers to UL?s Standards Service for: Portable Electric Luminaires Portable Electric Hand Lamps Public Review Participants SUBJECT: Circulation of comments received on the ANSI Ballot of Proposed Requirements for the Twelfth Edition of the Standard for Portable Electric Luminaires, UL 153; SUMMARY OF TOPICS This bulletin contains the comments received from the ballot of the proposals contained in the Subject 153 (298, 1786) meeting report dated July 9, 2004, and the proposed dispositions for the comments. COMMENTS DUE: December 2,2004 STP ballots were due to the Project Manager by August IO, 2004. The matrix contains all of the comments that were received. There are no additional or revised proposals as a result of the comments received. UL has determined that consensus has been achieved regarding the ANSI approval of the proposed revisions to UL 153. The initial consensus for specific proposals (numbering is consistent with the ballot in the July 9, 2004 meeting report) is as follows: Items 3A and 3B - Portable Hand Lights: 15 yes, 1 no, and O abstain; Item 3C - Play Value: 16 yes, O no, and O abstain; Item 3D - Spacers: 16 yes, O no, and O abstain; Item 3F - Portable Luminaires with a Seasonal Theme: 16 yes, O no, and O abstain; Item 3G - Thickness of Tissue Paper Used in Abnormal Operation Test: 16 yes, O no, and O abstain; Item 3H - Low Voltage Lighting: 16 yes, O no, and O abstain; and Item New Business - Correction to 170.1.3: 16 yes, O no, and O abstain. If you wish to change your vote in light of the dispositions/actions or the proposed changes, please respond to us in writing by November 26, 2004. If we do not hear from you by this date, your original vote will be maintained. Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130, User=abc, abcdd Not for Resale, 09/10/2006 00:49:47 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 153 -2- NOVEMBER 11, 2004 If the STP concurs with the dispositions/actions, UL plans to adopt the revised version of UL 153 as an ANSI standard. RIGHT TO APPEAL Anyone who has submitted an objection has the right to appeal this action on a procedural basis through ULs Appeals Process. If you wish to appeal, please respond by December 2, 2004. Please note only appeals based on a procedural issue will be heard, technical issues should be resolved at the consensus body level. Guidelines on how to register an appeal can be obtained on http:/ ulstandardsinfonet.uI.com or by contacting the STP Project Manager. UL appreciates the time and effort you have put forth to review this standard, and look forward to your continued participation in this UL/ANSI standard activity. UNDERWRITERS LABORATORIES INC. REVIEWED BY: DIXIE STEVENS Project Manager for STP 153 Standards Department Engineering Associate Phone: (91 9) 549-1 885 Fax: (919) 547-6182 E-mail: Dixie.W.Stevensus.ul.com http:/ulstandardsinfonet.ul.com/stp Copyright O 2004 Underwriters Laboratories Inc. DIANA PAPPAS JORDAN Chair for STP 153 Global Standards Phone: (847) 664-2008 E-mail: Diana.Pappas.Jordanus.ul.com SR:SAB bül-I 53.12-20041026 Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130, User=abc, abcdd Not for Resale, 09/10/2006 00:49:47 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 153 -Al- NOVEMBER 11, 2004 APPENDIX A COMMENTS MATRIX The Table below provides the proposed comment dispositions from the Ballot of BSWUL 153, meeting report dated July 9, 2004. The Standard for Portable Electric Luminaires. STP Project Manager: Dixie Stevens, Phone: (91 9) 549-1 885, E-mail: Dixie.W.Stevensus.ul.com STP Chair: Diana Pappas Jordan, Phone: (847-664-2008. E-mail: Diana.Pappas.Jordanus.ul.com The columns in the comment resolution matrix can be defined as follows: Item Numerical identifier for comment. Comment Submitter Name of person who submitted comment. Indicates the specific reference for the comment Para. # / Text Ref. Comment Action This comment matrix presents a summary of the comment and the suggested wording of proposals. The action, such as accepted or disagree, and the justification for the action, if needed. Disposition The proposed disposition such as resolved or unresolved. Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130, User=abc, abcdd Not for Resale, 09/10/2006 00:49:47 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 153 Subject or Topic: UL 153 -A2- NOVEMBER 11, 2004 1 'aragraph I Text teference 'ortable Hand .amps; Portable iand Lamp Switch Ballot items 3A ind 38) 3allot Item 3H, LV .ighting Comment or Comment Summary I am voting no on items 3A and 38 regarding Portable Hand Lights. I am opposed to the allowance for the USE of supplementary protection for protecting a switch, receptacle and undetermined load on a portable hand lamp. Once the receptacle is added to the hand lamp, it becomes an extension cord set. Extension cord sets require minimum 16 AWG conductors (see NEC Section 240.5(8)(3). A receptacle should not be permitted to be used in a portable hand lamp where 18 AWG cord are used. In addition, I have reservations about someone changing a supplementary protector while the circuit is still energized. This could easily create an unsafe condition for a layperson not knowing that the circuit should be de-energized before servicing the protector. I can only suggest that if a receptacle is to be included in a portable hand lamp, then the portable hand lamp should be evaluated to the requirements for cord sets and power supply cords (UL 817). If a receptacle is included in the portable hand lamp, logically it becomes an extension cord set and the product should be evaluated to the appropriate standard. For proposal 3H my only objection is based on the effective date. Extending an NEC requirement out to February 2006 for a change to installation instructions is not justified. A complex design change would be understood. AdionlDisposition Unresolved. UL believes that the proposal doesn't conflict with the NEC. The 2002 Code 240.5(8)(3) indicated that extension cord sets shall be 16 AWG minimum. The 2005 Code 240.5(8)(3) revised the requirement for extension cord sets to remove the 16 AWG minimum cord size requirement and replace it with “shall be considered to be protected when applied within the extension cord listing requirement“ This moves the burden of providing adequate construction for the cord to address over current protection from the NEC to the product standard. The Listing requirement for extension cords per UL817 state that the cord size shall be 16 AWG minimum, except that 18 AWG minimum is allowed, providing that the extension cord is provided with supplementary over current protection. This is exactly what is being proposed for portable hand lamps. The commenter does not agree with the code change and maintains his objection to the proposed requirements. This comment is related to the implementation of the proposed requirements and is not subject to balloting. This effective date comment is being handled separately by the PDE. Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130, User=abc, abcdd Not for Resale, 09/10/2006 00:49:47 MDTNo reproduction or networking permitted without license from IHS -,-,- Subjects 153 (298, 1786) (in reply, refer to Subject 153) 12 Laboratory Drive Research Triangle Park, NC 27709 July 9, 2004 TO: Standards Technical Panel (STP) for Portable Luminaires, STP 153 Subscribers to ULs Standards Service for: Portable Electric Luminaires, UL 153; Portable Electric Hand Lamps, UL 298; and Nightlights, UL 1786 Other Interested Parties SUBJECT: Report of the Meeting of the Standards Technical Panel of UL for Portable Luminaires; Request for Comments on the Proposed Requirements for the Twelfth Edition of the Standard for Portable Electric Luminaires, UL 153; and the Proposed Third Edition of the Standard for Direct Plug-In Nightlights, UL 1786; PROPOSED EFFECTIVE DATES Summary of Topics The following topics were discussed at the meeting: I ) Comments received by UL in response to the ballot of the proposed third edition of UL 1786, Subject 1786 bulletin dated December 12, 2003; and 2) Comments received by CSA in response to their constituent review of the proposed Standard for Direct Plug-In Nightlights, and proposed changes to the draft standard, as agreed to by the CSA Integrated Committee on Lighting Products. Where STP consensus exists regarding how comments should be resolved, the STPs views will be sent to the Technical Harmonization Committee who will work to resolve the comments in a manner that will satisfy both the UL STP and the CSA Committee for this binational standard. 3) Proposed new/revised requirements for UL 153. A) Portable Hand Lights B) Portable Hand Lamp Switch C) Play Value D) Spacers E) Tungsten Halogen Lamp Replacement F) Portable Luminaires with a Seasonal Theme G) Thickness of Tissue Paper Used in Abnormal Operation Test Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130, User=abc, abcdd Not for Resale, 09/10/2006 00:49:47 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 153 -2- JULY 9,2004 H) Low Voltage Lighting 4) New Business A) Strength of Spacers B) Miscellaneous Correction COMMENTS DUE: August IO, 2004 A meeting of the Standards Technical Panel of UL for Portable Luminaires was held on Thursday, June IO, 2003 at ULs Research Triangle Park Office. The purpose of the meeting was to discuss comments received by UL in response to the ballot of the proposed third edition of UL 1786, Subject 1786 bulletin dated December 12, 2003, comments received by CSA in response to their constituent review of the proposed Standard for Direct Plug-In Nightlights, and proposed changes to the draft standard, as agreed to by the CSA Integrated Committee on Lighting Products, and proposed newhevised requirements for UL 153. INSTRUCTIONS STP Members: If you are a voting member of the STP, complete the attached ballot with your vote on the standard or proposals. Please note that all negative ballots must be accompanied by supporting written reasons and, where possible, proposals for a solution to the problem raised. Impact statements and effective date information are not subject to letter ballot. Therefore, comments regarding impact statements and effective dates may be made and should be sent to the STP Secretary separate from the letter ballot. Subscribers and other interested parties: If you are a subscriber or other interested party, you are requested to send comments on the proposed requirements, impact statements, and proposed effective dates to the STP Project Manager. The STP member ballot should not be used to submit your comments. UL 1786 The STPs position on comments received in response to the ballot of UL 1786 are being forwarded to the Technical Harmonization Committee (THC) by copy of this report. The THC is charged with the reconciliation of STP comments with those received by CSA, as well as the update of the draft document, based on the comments received. Once an updated draft and a completed comment resolution matrix has been received by the Project Manager from the THC, a bulletin will be published for member review. STP members will have an opportunity to either maintain or change their vote at that time. Comments should be made in writing and may be sent by fax to (919) 547-6182 or by mail to the attention of Dixie Stevens at ULs Research Triangle Park office. Comments may also be sent via E-mail to Dixie.W.Stevensus.uI.com. Please reference all correspondence to Subject 153. Note all comments received are public and may be circulated to others. If you respond by fax or E-mail, please include your full name and company name and address to ensure a reply. STP BALLOTS AND ALL COMMENTS DUE: AUGUST 20,2004 Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130, User=abc, abcdd Not for Resale, 09/10/2006 00:49:47 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 153 -3- JULY 9,2004 Attached as Appendix A for your review and comment is the report of the STP 153 Meeting. Appendix B contains the STPs position on comments received in response to the ballot of UL 1786, Standard for Direct Plug-In Nightlights, bulletin dated December 13, 2003, and the STPs position on comments received by CSA during their constituent review of the same material. Both these tables will be forwarded to the THC for reconciliation. Appendix C contains proposed newhevised requirements to UL 153, Standard for Portable Electric Luminaires, for your review and comment. Appendix D contains the impact statements and proposed effective dates for the proposed requirements for UL 153. Attached as Appendix E is the STP ballot for proposed newhevised requirements for UL 153. Attached as Appendix F is a list of those who attended the meeting. Questions regarding interpretation of requirements should be directed to the responsible UL Staff. Please note that proposed requirements are of a tentative and early nature and are for review and comment only. Current requirements are to be used to judge a product until these requirements are published in final form. * * * * * * The following report is not intended to be a verbatim transcript of the discussion at the meeting, but is intended to record the significant features of those discussions. Unless specifically requested to do so, UL will not acknowledge comments indicating concurrence with these proposals. UNDERWRITERS LABORATORIES INC. REVIEWED BY: DIXIE STEVENS Project Manager for STP 153 Standards Department Engineering Associate Phone: (91 9) 549-1 885 Fax: (919) 547-6182 E-mail: Dixie.W.Stevensus.ul.com http:/ulstandardsinfonet.ul.com/stp DANIEL P. RYAN Chair for STP 153 Global Standards Phone: (91 9) 549-1 658 Fax: (919) 547-6399 E-mail: Daniel.P.Ryanus.ul.com Copyright O 2004 Underwriters Laboratories Inc. SR:SAB bül-I 53.12-20040520 Appendices: A - Report of the STP Meeting B - Comment Resolution Matrixes for UL 1786 C - UL 153 Proposals D - Impact Statements and Effective Date Information E - Ballot