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1、Subject 484, (474, 1699) (in reply, refer to Subject 484) 333 Pfingsten Road Northbrook, IL 60062 November 13, 2003 TO: Standards Technical Panel for Dehumidifiers and Room Air Conditioners, STP 474; Subscribers to ULs Standards Service for Room Air Conditioners; Arc-Fault Circuit-Interrupters (Leak
2、age-Current Detector-Interrupters) Subscribers to ULs Listing Service for Room Air Conditioners; Packaged Terminal Air Conditioners; Special Purpose Air Conditioners; Cord Type Arc-Fault Circuit-Interrupters; Cord Sets With Leakage Current Detection and Interruption Other Interested Parties SUBJECT:
3、 Report of the UL 484 Ad Hoc Meeting Discussion On October 31, 2003, at the OHare Hilton hotel in Chicago, IL, an ad hoc meeting was held to address the effective date for revisions to the Standard for Room Air Conditioners, UL 484, that requires the use of arc fault circuits interrupters (AFCls) an
4、d leakage-current detector-interrupters (LCDls) with portable room air conditioners (”RACs”). During the meeting, UL reviewed the process that UL follows to establish an effective date when new or revised requirements are adopted in a UL Standard for Safety. When the revised UL 484 requirements (con
5、cerning the use of AFCI or LCDI devices for RACs) were adopted, UL sent a bulletin to RAC manufacturers and others known to have an interest in the revisions, requesting comments regarding whether the effective date for these revisions should be set at 12 months, 18 months or 24 months following the
6、 adoption of the revised UL 484 requirements. In consideration of comments received by UL, an effective date of December 19, 2003 for the revised UL 484 requirements was established. Members of industry immediately appealed to UL to reconsider this effective date. They urged UL to set the effective
7、date at 24 months following publication of the requirements. On August 1, 2002, in response to this request, UL held a teleconference meeting with members of industry and others having an interest. Manufacturers of RACs said that additional time was required to allow for product design changes, prod
8、uct field testing, retooling and the like. RAC manufacturers also asked that the effective date be set to coincide with the usual annual RAC product model year SUBJECT 484 -2- NOVEMBER 13,2003 changeover date. RAC manufacturers indicated that August 1 represents the date in a typical year in which s
9、uch product model year changeover is initiated. Based on the additional information provided to UL, UL moved the effective date for the revised UL 484 requirements to August 1, 2004. On September 25, 2003, UL received a letter requesting that UL again extend the effective date for the revisions to U
10、L 484 by one year to August 1, 2005. This request led to the October 31, 2003 ad hoc meeting. During the October 31, 2003 ad hoc meeting, UL heard comments from both the RAC producers and the AFCVLCDI producers. Both sides were given an opportunity to explain their respective positions. The RAC prod
11、ucers and their trade association cited as their main concerns the lack of AFCVLCDI devices currently available and the lack of time to test such devices in the field. RAC producers also raised concerns regarding the inability of these devices to meet RAC producers internal safety requirements. Prod
12、ucers of AFCI and LCDI devices both indicated that they have products in production that meet the UL 484 revisions available to RAC manufacturers. One such producer stated that it had been producing such devices for several years. This LCDI producer also stated that in 1997 one RAC manufacturer carr
13、ied out three years of successful life testing with his companys product installed on its RAC. An AFCI producer passed around a sample of one such product currently available and designed for the RAC application. Furthermore, manufacturers of both LCDI and AFCI devices indicated that they are prepar
14、ed to continue to provide samples and assistance to RAC manufacturers. They said that they have manufacturing capacity available and are prepared to supply RAC manufacturers with quantities of AFCI or LCDI devices to meet the production quantities required by the RAC manufacturers. Having considered
15、 all information that has been provided to UL, UL has concluded that there are suitable AFCI and LCDI devices available for use to satisfy the revised UL 484 requirements. Field experience with AFCI and LCDI devices in various product applications, together with reported development and field applic
16、ation of AFCls and LCDls with RACs, gives adequate evidence, in the judgment of UL, that the time currently remaining until August 1, 2004 is sufficient to allow for satisfactory product development. Manufacturers able to provide AFCI and LCDI devices have shown a willingness, capability and capacit
17、y to provide devices to and to work with RAC manufacturers to support product development and to resolve design problems in a timely manner. In view of the above outlined findings, UL concludes that the current effective date of August 1, 2004 will be maintained. Attached to this report is a letter
18、addressed to AHAM president Mr. Joe McGuire by UL president Loring Knoblauch, which further explains ULs review and decision in the matter. UNDERWRITERS LABORATORIES INC. REVIEWED BY: J.R. Beyreis Vice President - Engineering Underwriters Laboratories Inc. 333 Pfingsten Road Northbrook, IL 60062 Ted
19、 V. Hall Senior Vice President and Chief Technical Officer Underwriters Laboratories Inc. 333 Pfingsten Road Northbrook, IL 60062 Loring W. Knoblauch President 333 Pfingsten Road Northbrook, IL 60062 Copyright O 2003 Underwriters Laboratories Inc. SUBJECT 484 -3- NOVEMBER 13,2003 November 13, 2003 M
20、r. Joe McGuire President Association of Home Appliance Manufacturers (AHAM) 11 11 lgth Street NW, Suite 402 Washington, DC 20036 Dear Joe: Thank you for your communication on the air conditioner cord issue. I recognize that the issue is an important one for your members, as it is for the component m
21、anufacturers and for a wide variety of public safety advocates. Whatever decision UL reaches will leave some of our many and broad constituencies unhappy. We listened carefully to all of the information you and others provided, and carefully considered the arguments advanced. We promised to give you
22、 a fair and careful hearing, which we have done. Here are our conclusions: 1. The AFCVLCDI are clearly improvements to the product that will positively impact Public Safety. 2. Delaying the effective date will unnecessarily delay the introduction of a lifesaving device. 3. Our original process to de
23、termine an appropriate effective date was careful, comprehensive and thoughtful. We listened to a wide range of informed opinions, and made a careful and thoughtful decision that we believe appropriately balanced the equities. 4. Extending effective dates, once established, should happen rarely, and
24、 only when it is clear there is new information relevant to the decision or that our original decision process was flawed. 5. It is critical, we think, that manufacturers and component suppliers alike have as much predictability and notice as possible. Those that work hard to be ready to meet effect
25、ive dates should be rewarded for their diligence. Manufacturers who chose not to get ready should , likewise, not be relieved of the consequences of their inattention. We want a level playing field for all, with as little change in the rules as possible. 6. We found nothing that came out of this las
26、t round of meetings that constituted vital new information or suggested our original thinking was flawed. There are, we think, an ample supply of components, and there clearly will be manufacturers ready with product by the effective date. 7. We are glad that several of your members felt a strong ne
27、ed for adequate life testing before they introduce their products to market. This strikes us as an excellent idea and an example of their continuing focus on safe products. If the products cannot be adequately tested by the effective date, we would suggest holding the new products off the market unt
28、il they are ready but next time getting started early enough to allow for life testing (as we do when we calculate a reasonable effective date). -,-,- SUBJECT 484 -4- NOVEMBER 13,2003 8. In the end, we see no reason to change or extend this Effective Date. The original date- setting process was, we
29、think, a good one. No new facts have surfaced to change our thinking. 9. Please tell your members that once effective dates are established, it will be the rare exception when they are changed or extended. We will work hard (as we did in this case) to make the dates reasonable. But, once established
30、, we will not bow to industry pressure unless we feel a mistake has been made and Public Safety will be impacted. While you may not agree with our final decision, I believe the process was a good one and that all interested parties had ample opportunity to be heard. I am enclosing a copy of the report of the ad hoc meeting held on October 31, 2003 at the OHare Hilton. This report is being sent to those who were invited to or attended the meeting on October 31, 2003. Very truly yours, Loring W. Knoblauch President and CEO LWK:edw