I remember when we proudly made downlights from coffee cans. A porcelain socket, a little black paint, some zip cord, and a hole saw was all there was to it. With a little deftly applied spackling compound, you could have a trim-free, zero sight line, low-cost flangeless downlight. Those were the days. Dangerous, perhaps, but do not worry about that brown spot on the ceiling.
Back then, do-it-yourself lighting was not code complying. Today, that has not changed. Basic electrical code requirements in the United States require that every product must be listed for its intended use. Listed means tested by a qualified laboratory for conformity to a set of standards that ensure safety under all conditions of use and abuse.
That is the point of Underwriters Laboratories (UL), the 114-year-old widely recognized testing company. UL sets the standards for design and testing that affect every luminaire in the U.S. and Canada. UL is one of a number of companies that perform the actual testing and listing of products. Another testing service that has a good portion of the lighting market is Intertek Testing Services NA, which offers the ETL mark. However, whether the product bears the UL label or the mark of another testing lab, the standards being met are still UL.
Worldwide, similar organizations play this role. In the European Union (EU), products must meet European Directive requirements, and those that pass receive the Conformité Européene (CE), French for “European Conformity,” label. The difference between the EU and U.S. is that the U.S. requires independent testing and CE allows manufacturers to self-certify.
The real issue surrounding UL is whether its standards are current, necessary, cost effective, and fair. Most U.S. fixture makers (including those with offshore manufacturing) are resigned to meeting UL and many have set up in-house UL testing labs to do the work, keeping costs low. But for designers, inventors, and offshore lighting companies, UL can appear as a huge obstacle to bringing new lighting products into the marketplace. Moreover, with the threatened onslaught of new light-emitting diode (LED) technology, getting through the UL process threatens to become a barrier because of UL's deserved reputation for being intransigent and slow to accommodate new materials, concepts, and techniques.
The Good Dr. U Those with an understanding of the breadth of the lighting industry realize how many different lamps, ballasts, and materials are used. Combine that with the limitless supply of design ideas, and it is easy to understand why a very complex set of standards and rules are needed to ensure safety. The situation is further complicated by the need to anticipate the likely abuses of each luminaire, ranging from wide temperature swings to improper installation, physical abuse, and the prying fingers of children. UL's lighting standards respond with requirements that are surprisingly consistent, if not a bit conservative. In general, UL standards consist of two principal groups: design and manufacturing requirements, and testing requirements. Design and manufacturing requirements specify wire gauge, insulation class, sockets, ballasts, wireway cross section, terminal clearance, terminal safety, ground terminals, and a host of other things that over the years have proved to provide safe and reliable measures. Testing requirements mostly are focused on thermal safety and check to make sure that safe temperatures are not exceeded, especially where luminaires can be touched or come into contact with other building materials.
Larger manufacturers often have UL-certified testing labs in-house, subject to unscheduled spot checks by UL inspectors and periodic audits of their testing procedures and equipment. Smaller manufacturers face the higher costs of submitting products to an independent test lab. In some cases, luminaires can be listed with little or no actual testing. If built according to specific rules concerning wiring, sockets, physical connections, and other characteristics, a product can be listed without a test. Generally, this is limited to incandescent fixtures with open tops and limited wattage, such as table lamps, sconces, and chandeliers. This allows for low-cost listing of decorative and custom lighting.
The Bad Mr. L But despite the safety checks that UL procedures ensure, manufacturers outside the U.S., particularly European-based companies, have expressed concern about the process itself. They question whether different “rules” are being applied to non-U.S. lighting manufacturers. Of concern is what appears to be a more elaborate bureaucratic process, including inspections before each individual shipment is sent overseas that adds another step in the process for these non-U.S. manufacturers trying to bring their products to the U.S. marketplace.
To address some of these concerns, non-U.S. lighting companies often will partner with U.S. manufacturers in a distributor-like relationship. The U.S-based company takes responsibility for obtaining the UL listing and assembling the fixtures in a U.S. facility. It also enables product stock to reside in the U.S. and a faster delivery time to the customer. For instance, Energie Lighting, located in Golden, Co., specializes in bringing some of the most preeminent European lighting manufacturers to a North American audience.
Then, there is LED lighting. With its low-wattage, low-voltage, and low-heat, the LED begs the necessity and cost of UL. Overall, the process of listing and testing has proved its worth. The key is that it remains true to its independent “third-party” roots and not hinder the delivery of new products to the marketplace.