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Electronics Forum / Electronics / September 2007



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US consumer products design reference - what inventors should know

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tns1 - 25 Sep 2007 21:06 GMT
What safety or design codes are required in US consumer products?
To narrow it down lets say home appliances using either wall or battery
power 120vac max with digital/analog circuits but no intentional
radiators. For example: food processors, foot massagers, stereo equip.

If I were the inventor of the Vego-Pedi-Pod(tm), and wanted to mass
market them, how would I find the applicable laws and codes? Any books
that walk you thru the process?

I am aware of a few safety and regulation agencies such as CE, UL, CSPC,
FCC. While CE codes seem to be the law overseas, UL and CSPC codes
appear to be only suggestions, and afaik, not requirements. In the case
of the UL, they are expensive requirements since the cost to even read
them approaches $1k per document (what a scam).

So far the only real requirements I have seen for this category of
product is FCC part 15. Surely there are more?
Charles - 25 Sep 2007 22:23 GMT
> What safety or design codes are required in US consumer products?
> To narrow it down lets say home appliances using either wall or battery
[quoted text clipped - 13 lines]
> So far the only real requirements I have seen for this category of product
> is FCC part 15. Surely there are more?

If it is not a medical device or a device to be used in an explosive
environment (or other iffy situations) and does not radiate so as to
potentially interfere with other applications/devices and is line-operated,
the biggie is UL Approval.

Then, of course, there is the area of potential liability.  Infant
monitoring devices are just one example.  One must tread carefully in such
areas.
tns1 - 26 Sep 2007 05:31 GMT
>>What safety or design codes are required in US consumer products?
>>To narrow it down lets say home appliances using either wall or battery
[quoted text clipped - 22 lines]
> monitoring devices are just one example.  One must tread carefully in such
> areas.

Yes, it wouldn't do to have the Vego-Pedi-Pod(tm) remove someone's
toenail while they are tuning the equalizer! But you are right, toddlers
and lawers go hand in hand. Potential liability has kept more than one
great product off the market.

I was wrong about the CPSC. Some of their recommendations have become
law, but they cover a very limited range of products (bicycles, lawn
darts, power cords). While the UL seems to have categories for a wider
range of products, the website states that submission of products to be
tested is strictly voluntary and that if there are any laws requiring
compliance to UL code, they can't be bothered to keep track of them. Too
busy counting money ya'know.

It does seem like lots of products have the UL mark, but then again,
many don't. With 1000's of products on the market I have to assume there
is some publication or source these designers and manufacturers have
followed to meet just the regs applicable to their product for the
markets they want to sell in. I just haven't found it yet.
Chris Jones - 26 Sep 2007 21:41 GMT
>>>What safety or design codes are required in US consumer products?
>>>To narrow it down lets say home appliances using either wall or battery
[quoted text clipped - 41 lines]
> followed to meet just the regs applicable to their product for the
> markets they want to sell in. I just haven't found it yet.

This standards thing has gone beyond ensuring that products are safe, has
become a whole parasitic industry.  By making it complicated enough, you
now probably have to hire some consultant, just to tell you which $1000
standards you need to buy, which will then tell you to do things you were
going to do anyway, and then you can look forward to the cost of the
testing.

If this product is for technically minded users, maybe you could do it as a
semi-assembled kit, which probably avoids some of the difficulties, at the
expense of requiring a lot more customer support.

If there were a government that really wanted to have a lot of start-ups,
then that country would either buy outright, or create from scratch a
complete set of standards, make them as strict in every respect as the
strictest of the widely used standards in the rest of the world, declare
that they are legally adequate standards for products sold in their
country, and then place the lot in the public domain.

I think that it would be interesting if someone were to compile a list, by
country, of the overhead cost of starting company and selling an electronic
product, the "null product" - where we assume that the design itself is
trivial, but just count the cost of buying standards, health and safety
audits, compliance testing fees, government bribes^H^H^H^H^H^Hregistration
fees, WEEE registration etc.  If this list were published every year, it
might focus the attention of certain politicians on the reason why they
seem to have so much trouble reducing unemployment and achieving positive
balance of payments.

Chris
tns1 - 27 Sep 2007 22:58 GMT
> This standards thing has gone beyond ensuring that products are safe, has
> become a whole parasitic industry.  By making it complicated enough, you
[quoted text clipped - 25 lines]
>
> Chris

Well said. How can it be that a private company, and a claimed
non-profit organization, has managed to appoint itself as the sole
arbiter of product safety, yet keep the standards themselves such a
well-guarded secret? Our laws are not secret, public safety should not
be either. The document pricing, restrictive licensing, and secretive
way the UL guards their IP, all show the goal is more profit oriented
than safety oriented. Heck, maybe Microsoft should apply for
not-for-profit status.

I have no doubt that consumer products are safer having been designed to
set standards, but once those standards become a requirement (in
essence, the law) the text should be freely available, or at least
reasonably priced. Even thick technical books rarely cost more than
$100, mainly due to competition. Only a monopolistic entity could get
away with charging so much more for similar information.

I noticed my latest monitor has at least a dozen certification marks on
the back. Why so many, since I believe CE meets or exceeds most of them.
Maybe its time for a comprehensive set of open standards?
Chris Jones - 28 Sep 2007 20:43 GMT
>> This standards thing has gone beyond ensuring that products are safe, has
>> become a whole parasitic industry.  By making it complicated enough, you
[quoted text clipped - 46 lines]
> the back. Why so many, since I believe CE meets or exceeds most of them.
> Maybe its time for a comprehensive set of open standards?

Yes, but you'll need a bunch of "lobbyists" with sufficient cash to grease
the right politicians, or it will never get adopted, and therefore will not
allow you to sell products.  I think there is something called the
"official journal" or something like that in the EU, which is a list of the
standards that the governments will admit to having heard of.  I think it
is probably expensive to get on that list.  There would be enough competent
people and companies who are sick of being ripped off, that actually coming
up with the technical content of the standards would probably not be the
hard part.

Chris
Charles - 26 Sep 2007 23:57 GMT
> It does seem like lots of products have the UL mark, but then again, many
> don't. With 1000's of products on the market I have to assume there is
> some publication or source these designers and manufacturers have followed
> to meet just the regs applicable to their product for the markets they
> want to sell in. I just haven't found it yet.

I too have no idea about a single source that is reliable and up to date.

I worked for a small company years ago and we went for UL approval (and
eventually received it).  We were forced to do so because most retailers
will not even consider a line-operated gizmo that lacks UL approval.  They
feel that if they sell such a product they would be vulnerable to a wide
range of litigation.  I really can't blame them.  By the way, I honestly
felt that the UL approval process added not one tad of safety to the product
we had designed.  They demanded some picayune changes that were silly.

The UL approval process (back then) was torturous, bureaucratic and fraught
with delays.  It was very frustrating.

It is becoming more and more difficult for a small enterprise to enter the
manufacturing sector.  This is not a good thing.  However, it is also not a
good thing to have blatantly dangerous products.  I have mixed emotions
about this whole thing.
JANA - 30 Sep 2007 02:57 GMT
Your best bet is to have an patent attorney look after your interests. You
should be in contact with the various standards organizations. It is costly,
but this is part of the investment. Getting free information from various
non directly approved sources would not be considered legally admissible in
court when applying for a patent, or when fighting a defence case because of
an overlooked problem.

Signature

JANA
_____

What safety or design codes are required in US consumer products?
To narrow it down lets say home appliances using either wall or battery
power 120vac max with digital/analog circuits but no intentional
radiators. For example: food processors, foot massagers, stereo equip.

If I were the inventor of the Vego-Pedi-Pod(tm), and wanted to mass
market them, how would I find the applicable laws and codes? Any books
that walk you thru the process?

I am aware of a few safety and regulation agencies such as CE, UL, CSPC,
FCC. While CE codes seem to be the law overseas, UL and CSPC codes
appear to be only suggestions, and afaik, not requirements. In the case
of the UL, they are expensive requirements since the cost to even read
them approaches $1k per document (what a scam).

So far the only real requirements I have seen for this category of
product is FCC part 15. Surely there are more?
Mark Zenier - 30 Sep 2007 04:28 GMT
>What safety or design codes are required in US consumer products?
>To narrow it down lets say home appliances using either wall or battery
[quoted text clipped - 13 lines]
>So far the only real requirements I have seen for this category of
>product is FCC part 15. Surely there are more?

You might want to go to groups.google.com and read back through
the sci.engr.electrical.compliance newsgroup.  It's not very busy
right now, but there's been a lot discussion in the past couple
of years.

Mark Zenier  mzenier@eskimo.com  
Googleproofaddress(account:mzenier provider:eskimo domain:com)
 
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