Everything You Wanted To Know About UL,
But Were Too Afraid To Ask

The Editors of The PEI Journal sat down with two representatives of Underwriters Laboratories, Consumer Affairs Manager John Drengenberg and Standards Technical Panel Chair Dan Ryan. Both men are engineers who have devoted their careers to product safety. Dan Ryan is familiar to many PEI members from his work overseeing the standards process for gas, oil and fire-related products, security, signaling and hazardous locations.

The PEI Journal: How did UL get started?
John Drengenberg: UL got its start during the 1894 World's Fair in Chicago. Electricity was a highlight of the fair, and a new invention, the light bulb, was being showcased. Unfortunately, a lot of fires were starting in the buildings, and the fair promoters became very concerned. They brought in an expert from Boston who worked for the Board of Fire Underwriters to investigate the fires. In those days, the concept of running a wire and putting a nail through it and holding it in place was rocket science. Today, nobody would do that. After the fair ran its course, this gentleman stayed in the area and ran tests for the national Board of Fire Underwriters.

Dan Ryan: For the first 20 years of UL's existence, we were fully funded by the insurance industry, and were the lab for the underwriters; thus the name “Underwriters Laboratories.” Our activities have certainly expanded since those early years. Our focus and our mission is facilitating the delivery of safe products to the marketplace through effective minimum safety standards.

JD: We test more than 19,000 types of products, everything from life jackets and hair dryers to roofing shingles, bulletproof glass and fuel dispensers. We conduct 100,000 investigations of products each year.

How many of those investigations are conducted on petroleum equipment?
JD: We've never broken it down. There are many products, such as the lighting under canopies and the roofing over them. We test breakaway devices, piping, tanks, flex connectors, leak detection devices and, of course, dispensers. We also test automatic lifts, car washes, light poles and fixtures in a service station, the underground wire that feeds the lights, fuel dispensers and vending machines. We test air compressors, lubrication equipment, tire balancers, POS terminals, cash registers, heaters, commercial cookers, lottery machines and popcorn cookers. And that's just a small part of the list of equipment UL lists for service stations.

What is UL's organizational structure?
JD: UL is a not-for-profit, independent corporation headed by a president, Keith Williams, who oversees 6,200 employees. UL has 66 laboratories, testing and certification facilities around the world. At UL's headquarters in Northbrook, Illinois, there are 1.5 million square feet of lab space. Other locations include Hong Kong, Singapore, Taiwan, Japan, Germany, Denmark, the UK and Italy. Three are in China; five are in the U.S. Facilities are located where manufacturing takes place.

Is the UL mark accepted around the world?
JD: No, only in the United States, so UL's China facilities are testing products that will end up here in the United States.

Are you saying that fire marshals in other countries do not require equipment to be listed?
JD: The equipment generally does meet requirements of other countries, but it does not carry the UL listing.

Who are your competitors?
JD: People think UL is a monopoly. We're not. Never have been. UL is one of thousands of different testing labs in the United States. One of our main competitors is the Canadian Standards Association.

Are there alternatives to UL? In other words, since the word is “listed,” can Factory Mutual, Southwest Research, ETL, or another group certify equipment to a safety standard?
JD: I don't know if those groups list the type of equipment PEI members are involved with.

The state of California recently hired a chemist to review equipment. What could be the benefit of doing that?
JD: California has been a leader in that for several years. But the fact is, the UL standard is the requirement that everyone else tests the product to. These other companies do not develop standards. They are also for-profit entities. They apply the UL testing and then put their own mark on the product. Of course, they can test to the standard, because the standard is public information. Every state and municipality has people who have the final say on equipment. It's not UL. We test product to the requirements, doing the most thorough job anyone can do. Yet the ultimate decision rests with the state or municipality. They are the ones who decide whether or not that dispenser can be turned on and pump fuel. Keep in mind that most of those local people rely on UL. They want to see the UL mark on the product, just like the retailer does.

How do you make money?
JD: UL is a not-for-profit, and it does not receive funds. We charge manufacturers based on the services we provide. Cost is determined by how many hours we believe it will take our engineers and technicians to evaluate a product. It could range anywhere from several hundred dollars for a minor change in the product, like color, to tens of thousands of dollars for something more complex. But keep in mind that the manufacturer makes many, many copies of that one product, so that cost is amortized quite a bit.

How does a product get a UL mark?
Ryan: There are three steps. First, the standard is established. Next, products are tested to that standard. Finally, the products are certified. The standards level is where the performance requirements are determined.

What's an STP meeting like?
Ryan: The Standards Technical Panel, or STP, is the voting group responsible for developing and maintaining requirements for a given class of product. The panel consists of all the stakeholders, including manufacturers, technical experts, regulatory authorities, even end- users. The panel often invites government agencies, trade associations, the press and consumers to meetings. We try to get the widest input on a standard and work toward consensus.

As you facilitate the panel, I imagine your consensus-building activities can get quite exciting.
Ryan: Very contentious, at times. There are individuals with very strong views, sometimes diametrically opposed views.

How do you keep everything and everyone under control?
Ryan: Sometimes I work with people privately to encourage them that they will be more effective by not trying to convince that one other person they are right. They have to convince two-thirds of the voting panel that they're right. So people focus on speaking to the public forum and offering persuasive arguments in support of their position.

How long does it take to develop a standard?
Ryan: The devil is always in the details. I've worked on some panels that took a few months, others that took up to four years. It depends on how much controversy there is. It's a consensus-building process. The average, from proposal to publication, is five months.

So after the standard is developed, the process moves into the testing or evaluation phase?
JD: Right, we look at representative samples, usually before the product is in full production. In fact, we encourage manufacturers to get their product to us while it is still in the design stage. We'll gladly go through the product and discuss various aspects of what might and might not be an issue. Once it passes all the tests and meets the requirements of the standard, it gets listed and the manufacturer goes into full scale production.

Is the evaluation completed by this point?
JD: Not really. Manufacturers are required to sign an agreement that UL's local inspectors can enter their facility and spot check the products that are on the production line. When we evaluate a product, we write a complete report and take pictures of it. Those descriptive reports are sent to wherever that product is manufactured, be it Hong Kong or Omaha. We have local inspectors on our staff who will drop into any factory on any given day and check to see if anything has changed.

Manufacturers are required to notify UL if there is a component change. Do they always?
JD: Sometimes things slip through. If there is a change, the inspector has one tool at his disposal, and that is to remove the UL mark. But that usually stops the production line because the manufacturer knows that there is very little likelihood that a retailer would want the product on its shelf, or in the case of a non-consumer product, like a fuel dispenser, it means the local inspection authorities would not accept the product in their jurisdiction.

So, in the PEI environment, unless the product is listed, it can't be installed?
JD: Local inspectors make the ultimate decision on whether or not the product can be installed and turned on and used in their jurisdiction. These folks—in some communities it's the fire marshal or the building inspector or the local inspector—have the ultimate authority, not UL, not the manufacturer. They are known as the “authority having jurisdiction,” or AHJ.

You must get pressure to hurry things up, perhaps pressure from a large group of end-users who want to use the product.
JD: We do, but we never compromise. That's the beauty of being independent.

What is UL currently working on related to the petroleum equipment industry?
Ryan: There's a great deal of activity with ethanol right now. UL is very active in developing requirements to evaluate petroleum products for compatibility with ethanol use.

Speaking of pressure...
JD: UL expects to complete the research and publish certification requirements for E85 fueling equipment by the end of fourth quarter 2007, and immediately thereafter, accept E85 dispensing equipment for investigation and certification.

Ryan: We are also gearing up for compatibility with other alternative fuels and trying to understand what they are going to be. Some of them seem to be moving targets. We're reacting to that, just like PEI members are reacting to that.

What is on the horizon?
Ryan: UL is currently working with the gasoline hose industry. The California Air Resources Board is looking at permeation rates of gasoline hose, with respect to CARB's air quality objective. Will that translate to other project types? I'm not sure.

What's the most interesting standard you've ever worked on in our industry?
Ryan: As an engineer, I find each and every one of them interesting. I'm always dealing with different end-uses of the product, different stakeholders, different perspectives, different technical issues. At the end of the day, every single one of them relates back to public safety. In other words, is there an unimportant standard? I don't think so. And none has ever been boring!

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The PEI Journal • Second Quarter 2007 • Volume 1, No. 2 • Contents are Copyright © Data Key Communications, Inc.
All rights reserved. • Nothing may be reproduced in whole or part without written permission of the publisher.