September 2006 - Plugging into Product Testing

Sorting through the myriad of electric and electronic product testing standards and regulations

By David Lustig

In most areas of the world, getting your electrical product tested by an independent company or agency is mandatory. If for some reason yours falls outside of that category, it still is a good idea to have it certified to make sure every component, and the overall device itself, meets all necessary standards. And as you might expect, rules and regulations vary almost as much as the number of countries in the world.

So what do you do first to begin the testing process?

“When launching a new product, it is essential to identify the target countries in which the product will be sold,” explains Dean Davidson, director of retail and home appliances/electronics for Intertek, ETL SEMKO Division. Intertek, headquartered in the United Kingdom, is a global leader in testing, inspection and certification of products, commodities and systems.

“Having this information readily available,” Davidson continues, “will assist the marketer/product developer and their test lab in determining local market entry requirements and test lab capabilities, as well as helping to develop a realistic product launch timetable.”

In the United States, for example, among the laws or acts that apply to consumer product testing include the Consumer Product Safety Act, the Flammable Fabrics Act, the Refrigerator Safety Act, the Poison Prevention Packaging Act and the Federal Hazardous Substances Act.

Davidson says in addition to federal laws, many electrical products also face voluntary requirements driven by retailers, insurance companies and authorities having jurisdiction, as well as some mandatory electrical safety standards.

Production line safety testing has become an essential part of the manufacturing process, especially for products developed in the United States. It’s important to note that other countries may have different testing directives.

Nationally Recognized Testing Laboratories (NRTL) are third-party organizations recognized by the Occupational Safety and Health Administration (OSHA) as having the capability to provide product safety testing and certification services to manufacturers of a wide range of products.

Intertek says safety standards are developed through a consensus process that takes into account the viewpoints of manufacturers, the insurance industry, private organizations and consumers. The standards are then sponsored by non-government organizations such as the American National Standards Institute (ANSI), Underwriters Laboratories (UL), the National Fire Protection Association (NFPA) and others. These standards are then used by all testing companies to determine electrical product safety.

In addition to the laboratories, agencies and associations, there is at least one more program marketers, especially those specializing in DRTV, should pay close attention to: the Electronic Retailing Self-Regulation Program (ERSP).

Davidson says that programs, such as ERSP, can help drive the development of products and the testing that takes place related to product claims. As the risks of making false claims increase, so does the need to design products with performance claims in mind. As a result, he says, product testing protocols are becoming increasingly weighted towards claims verification and consumer usability.

But what works in the United States does not necessary apply in other countries, and Intertek’s Davidson cautions that the marketer/product developer and their test lab must take a detailed look at the legal market entry requirements outside the U.S., keeping in mind that those requirements can differ greatly from country to country.

Looking at U.S. regulations, explains B.J. Fazeli, president of B.J. Global Direct in Irvine, Calif., you must determine which directives or standards apply to the product.

“A product may be regulated by more than one directive or standard, depending on its intended use,” Fazeli adds, saying that you should also be prepared for strict regulations that are subject to change.

“Changes happen all the time,” he says, “so it’s essential to stay current.”

Rod Taylor, managing director, Seaward Electronic, Ltd., headquartered in the United Kingdom, adds that many times it is the very people who are going to use the product who determine what kind of qualifications it has to meet, and there is no one set of codes or rules.

“For the most part, UL [Underwriters Laboratories] will cover it all,” Taylor says. “However, think medical equipment. It might not only have to comply with medical standards but also hazardous material standards.”

Taylor also agrees that you should be prepared for strict regulations.

“The word ‘strict’ is interesting because we’re talking about the policing and regulatory side of things,” he adds. “People should not consider this as onerous. On the contrary, they should just consider it an opportunity to have peace of mind and a profitable business. If there is not a standard mandating a safe practice, they have to look around and determine what general customer practice would be as a responsible manufacturer.”

“The most important step is working with a reputable manufacturer or production management firm that has experience with test requirements,” says Bill Quarless, president and CEO of Impact Products Ltd. in Hong Kong.

“This should be done in the early stages of development, ensuring that the product will meet the standards before the molds are even opened,” he continues. “The firm can consult with the lab throughout the development phase and ensure only listed parts are used prior to the certification testing.”

Some products get scrutinized a little more than others. Asking which electrical products seems to undergo the most rigorous testing returns a variety of answers.

Intertek’s Davidson believes that while product safety standards have been developed for, and are applicable to, virtually all electrical products that pose a fire, shock of mechanical hazard; the most stringent requirements are placed on medical devices.

“Testing is dependent upon the intended use,” says Fazeli. “If you have a product that is intended for medical use, it will have to undergo more testing, unlike kitchen appliances which might have less.”

Then there is the question of exactly how does a product testing company do its work.

“Most product testing companies will work their clients to develop an effective comparison testing or claims verification program,” says Davidson.

In many cases, he says, testing to known industry standards can establish marketable benchmarks for products. In other cases, verifying existing claims or testing to extremes to create new unique selling propositions is as simple as a brainstorming session with your preferred laboratory.

Marketers who plan to enter the European market also must consider Restriction of Hazardous Substances (RoHS). Not applicable in the United States, it restricts the use of some materials in electric products in European Union countries.

“It’s effectively been running since July 1,” says Taylor, “and applies to all electrical products with the exception of medical equipment.

“Although this is a European directive, this can be seen in the United States,” he says, referring to the New York State mercury protection law.

“It is recognized that mercury is a particularly hazardous substance. The problem occurs when the product is disposed of. The element can leak into the ground and pollute, among other things, groundwater.”

Davidson says, with millions of electrical and electronic products being introduced into the market each year, concern has continued to grow regarding the environmental impact of these products.

According to the European Union directive, new electrical equipment placed on the market cannot contain more than specific levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl and polybrominated diphenyl ether.

“Among the RoHS’s directive’s largest impact to manufacturers is the transition from the use of lead solder to lead-free solders,” Davidson says.

Despite all the careful planning and research, everyone says there are always common mistakes that continually bubble to the surface.

“One of they key things that smaller manufacturers especially do is consider testing to be an expensive and unnecessary burden,” says Taylor. “But when you look at the overall picture, you see that it is not that big. For example, [we encountered] a large washing machine manufacturer that implemented a process that was much more stringent in terms of safety testing. What happened was that anything that was outside the limits was put back for rework. Their warranty claims dropped by 50 percent!”

Quarless sees the two biggest mistakes made by marketers are those who do not work with a competent firm and not developing the product with the firm that will manufacture it.

“The first mistake is obvious,” he says. “There are many Chinese factories that make electrical products, but not that many that have the experience to pass UL standards.

“The second mistake, however, is not so obvious,” Quarless continues. “Many marketers prefer to develop and prototype their products in the U.S., then send the prototype to China to be manufactured. I always advise my clients to work closely with the firm that will manufacture it.

“The factory engineers work closely with the lab engineers throughout the development phase, into prototyping and product testing. With constant communication and feedback, meeting the required standards is usually done easily with minimal problems.”

Fazeli feels the biggest mistake that product developers or marketers make is in the area of quality control.

“I have seen products that have been marketed successfully only to be returned by the consumer due to poor quality,” he says. “Quality control and quality assurance are two of the most important areas of product development.”

Davidson believes the single most common mistake is to begin the testing process during the later stages of the product development life cycle.

“Whether it is claims verification, performance testing to an industry standard or safety certification, finding issues or non-compliances before production can save expensive reworking, reduce the possibility of product recalls and help to protect brand reputation in the marketplace.”

The answer is that there is no “easy” way to get your product or products to comply with the myriad of regulatory bodies and testing demands made by the United States and almost every other country on the planet.

While there is not an easy answer, there are workable, usable answers.

Plan from start to finish and look at the “big” picture.

Consider talking to the intended manufacturer, whether it is in the U.S. or overseas, before committing the finished plans, and listen to what their engineers have to say.

Do your homework. Find out the standards and design specifications for every country you plan to market your product in. France may be geographically next to Germany, for example, but on specific items they could be miles apart.
Understand that components may be acceptable in one country but not in another.

Communicate. Leave nothing to chance and definitely nothing to interpretation. Whether they make sense to you matters not, in most cases, local laws and testing procedures are in place for a reason.

David Lustig is a contributing writer to Electronic Retailer magazine. We would appreciate your feedback. To submit comments, please e-mail the magazine at [email protected].


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