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1、Subject 943 (489) (in reply, refer to Subject 943) 1285 Walt Whitman Road Melville, L.I., NY 11747 December 7, 2004 TO: Standards Technical Panel (STP) for Ground-Fault Circuit-Interrupters, STP 943 Standards Technical Panel (STP) for Molded-Case Circuit Breakers, Molded-Case Subscribers to ULs Stan
2、dards Service for Switches, and Supplementary Protectors, STP 489 Ground-Fault Circuit-Interrupters Molded-Case Circuit Breakers, Molded-Case Switches and Circuit-Breaker Enclosures SUBJECT: Comments and Substantive Changes received on the ANSI Ballot of Proposed Requirements for theThird Edition of
3、 the Standard for Ground-Fault Circuit- Interrupters UL 943; SUMMARY OF TOPICS This bulletin Circulates comments received in response to ULs Subject 943 proposal bulletin dated May 7, 2004 proposing the following single proposal item, and provides responses to those comments: Addition of Requirement
4、s for GFCI Receptacle End of Life Test and Revision of Requirements for Reverse Line-Load Miswire Test COMMENTS DUE: December 28,2004 The attached comment matrix provides the proposed comment dispositions from the ballot of the proposal bulletin dated May 7, 2004. The ballots were due to the Project
5、 Manager by June 8, 2004. The matrix contains all of the comments that were received. The effective dates are the same as stated in the proposal bulletin dated May 7, 2004 unless noted otherwise. UL has determined that consensus has been achieved regarding the ANSI approval of the proposed revisions
6、 to UL 943. The initial consensus count is 18 yes, 4 no, and 1 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 December 28, 2004. If we do not hear from you by this date, your original vote will be maintained.
7、If the STP concurs with the dispositions/actions, UL plans to adopt the revised version of UL 943 as an ANSI standard. 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 28, 20
8、04. 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 e
9、ffort you have put forth to review this standard, and look forward to your continued participation in this UL/ANSI standard activity. Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130 Not for Resale, 08/30/2006 04:40:50 MDTNo rep
10、roduction or networking permitted without license from IHS -,-,- SUBJECT 943 -2- DECEMBER 7,2004 UNDERWRITERS LABORATORIES INC. EDWARD MINASIAN (Ext. 23305) Project Manager for STP 943 Standards Department MELVILLE OFFICE Phone: (631) 271-6200 Ext. 23305 Fax: (631) 439-6021 E-mail: Edward.D.M http:/
11、 Copyright O 2004 Underwriters Laboratories Inc. SR:CAA REVIEWED BY: BRADLEY J. SCHMIDT Chair for STP 943 Corporate Standards Phone: (847) 664-3064 Fax: (847) 313-3064 E-mail: Bradley.J.S http:/ Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern
12、Div./7838506130 Not for Resale, 08/30/2006 04:40:50 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 943 -Al- DECEMBER 7,2004 APPENDIX A COMMENTS MATRIX The Table below provides the proposed comment dispositions from the Ballot of proposal bulletin dated May 7, 2004.
13、 The Standard for Ground-Fault Circuit-Interrupters. STP Project Manager: Edward Minasian, Ext. 23305, Edward.D.M STP Chair: Bradley J. Schmidt, Ext. 43064 The columns in the comment resolution matrix can be defined as follows: Comment Submitter Para. # / Text Ref. Comment Action Disposition Name of
14、 person who submitted comment. Indicates the specific reference for the comment 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. The proposed disposition such as re
15、solved or unresolved Comment Submitter John J. Dougherty (General Electric Company) Paragraph I Text Reference Comment or Comment Summary This ballot suggests a change which does not add any new information to the User. It requires the User to run a test that he does not typically run today. The req
16、uested change is poorly written in that a myriad of visual and audible warnings could be implemented to meet the indication requirement. It will confuse users. As it adds no information and is confusing, it is truly unacceptable that the indication would probably be presented as a failsafe feature,
17、giving the user comfort when, in reality, no change has been made. For these reasons, I vote NO on this ballot. Table Continued on Next Page Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130 Not for Resale, 08/30/2006 04:40:50 MD
18、TNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 943 -A2- DECEMBER 7,2004 Table Continued No. I Comment Submitter AdionlDisposition: The following is the combined response from the task group specifically formed for that purpose to the four negative comments that UL re
19、ceived regarding the UL 943 proposals in the May 7, 2004 bulletin. Since the four comments address the same issues, the individual responses from task group members have been combined into a single response. Task Group response: RejectlResolved. The current requirements for the supervisory circuit i
20、n UL 943 are: 20.1 A ground-fault circuit-interrupter shall be provided with a supervisory circuit that will allow for periodic, convenient testing of the ability of the device to trip by way of a ground fault. 20.4 The results of the test shall be made known by means of an audible or visible indica
21、tion. The current requirement in UL 943 calls for an indication that the GFCI has tripped. The proposed requirement pertains to when the GFCI has reached ”end of life.” The end of life requirement would be a new aspect of the Standard, namely at ”end of life” a receptacle-type GFCI would be required
22、 to indicate when the GFCI that has been in the field can no longer pass its test function (.e., is no longer affording protection). The proposed requirement is seen as complementing, not subverting the standing UL requirements. The end of life indicator is broadly described to allow various technol
23、ogical methods. Methods can be audible, visual, denial of power, or a combination of these types of indicators. The end of life indicator can be initiated through a user depressing a button or initiated by other means. The consumer will help determine which type of indicator should prevail long term
24、. The UL standard will evolve as consumer information is gathered. By making the methods of indication broad, it will permit the receptacle industry to get to the first stepping-stone on an evolutionary path quickly, thus starting the information gathering process, while at the same time actively af
25、fording an increased level of safety to the consumer. The end of life test involves simulating the failure of a component that renders the receptacle-type GFCI in a non-protective state. In particular, the failed component renders the trip solenoid permanently inoperable. Failure of the trip solenoi
26、d was identified in the NEMA field study completed in 2001 as the predominant end of life failure mode in receptacle GFCls. Other modes of failure will be covered and methods of indication assessed as technology and experience evolves. The component responsible for causing the trip solenoid to becom
27、e inoperable is selected by the UL engineer in consultation with the receptacle GFCI manufacturer. Although it might be seen as preferable to identify a specific component, new design technologies offering improved safety performance that are employed can differ from one another. Under this circumst
28、ance, identification of a specific component to simulate end of life would have the undesirable effect of being prescriptive, .e., unduly prescribing how the receptacle GFCI is to be constructed thus prohibiting technological advances in using new components, and possibly inhibiting improved safety
29、functionalities. The NEMA field study demonstrates the need for implementation of this new performance requirement. The NEMA proposal is a step in the direction of safety, taking advantage of technological capabilities that are available today. I Paragraph I Text Reference I Comment or Comment Summa
30、ry Table Continued on Next Page Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130 Not for Resale, 08/30/2006 04:40:50 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 943 -A3- DECEMBER 7,2004 Tabl
31、e Continued - No. 2. - - (Prc - Comment or Comment Summary All currently manufactured GFCI, per paragraph 20.1, have a means to perform an internal test function that provides a convenient method for testing the ability of the device to trip. Tripping of the device indicates a properly functioning G
32、FCI and if the device does not trip then it is well known that the device has reached its end of life and must be replaced. Users are instructed to test their GFCI regularly. Section 37F proposes a new requirement for an end of life function that audibly or visually indicates when a GFCI has reached
33、 its end of life. If the proposed changes are added then UL 943 suggests that there needs to be two indications that the device has reached its end of life: (a) the device does not trip when the test button is pushed 20.1 and (b) when the device fails to trip it must also provide an indication by vi
34、sual or audible means 20.4.1. We believe that the present method of testing for end of life is sufficient and adding an additional indicator is unnecessary and may confuse the user. Paragraph 37F.2.1 proposes a test to demonstrate proper operation of the new end of life function by shorting or openi
35、ng a single component in the GFCI circuit. Since there are many critical components in the GFCI circuit that may cause improper operation, we do not believe this test provides sufficient evidence that the end of life circuit indicator is properly functioning. A certification test to demonstrate prop
36、er operation of an end of life function should at minimum include opening or shorting each critical GFCI circuit component and then repeating the end of life test. !ct Manaaers Note: Please see Action/Disuosition for Mr. Douahetfvs comments above. J Table Continued on Next Page Copyright Underwriter
37、s Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130 Not for Resale, 08/30/2006 04:40:50 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 943 -A4- DECEMBER 7,2004 Table Continued John Young :Siemens Energy PROPOSED EFFEC
38、TIVE DATE 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 ra
39、ised. 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 Project Manager separate from the letter ballot. Subscribers and other interested parties: If you are
40、 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. Comments should be made in writing and may be sent b
41、y fax to (631) 439-6021 or by mail to the attention of Mr. Edward Minasian at ULs Melville office. Comments may also be sent via E-mail to Edward.D.M. Please reference all correspondence to Subject 943. Note all comments received are public and may be circulated to others. If you respond by fax or E
42、-mail, please include your full name and company name and address to ensure a reply. SUMMARY OF TOPICS This bulletin proposes the following changes in requirements: Addition of Requirements for GFCI Receptacle End of Life Test and Revision of Requirements for Reverse Line-Load Miswire Test Copyright
43、 Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130 Not for Resale, 08/30/2006 04:40:50 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 943 -2- MAY 7,2004 STP BALLOTS AND ALL COMMENTS DUE: June 8,2004 Attac
44、hed as Appendix A for your review and comment are proposed requirements for UL 943. Attached as Appendix B for your review and comment are the impact statement and proposed effective date. Attached as Appendix C and D are the STP ballot instructions and the STP ballot, respectively. Questions regard
45、ing 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 fo
46、rm. PRODUCTSANDINDUSTRIESAFFECTED BYTHE PROPOSAL UL requests your assistance in identifying other products or industries that might be affected by the requirements contained in this bulletin. UL suggests that all suppliers or customers for these products and industries be made aware of these require
47、ments prior to their proposed effective date. Also, please forward your suggestions to UL so that these products and industries may be identified in future bu I let ins. * * * * * * Unless specifically requested to do so, UL will not acknowledge comments indicating concurrence with these proposals.
48、UNDERWRITERS LABORATORIES INC. REVIEWED BY: EDWARD MINASIAN (Ext. 23305) Project Manager for STP 943 Standards Department MELVILLE OFFICE Phone: (631) 271-6200 Ext. 23305 Fax: (631) 439-6021 E-mail: Edward.D.M http:/ BRADLEY J. SCHMIDT Chair for STP 943 Corporate Standards Phone: (847) 664-3064 Fax: (847) 313-3064 E-mail: Bradley.J.S http:/ Copyright O 2004 Underwriters Laboratories Inc. SR:CAA Copyright Underwriters Laboratories