Conquering Your First Product Safety Evaluation
What you need to know about your first product safety evaluation
Whether you run a small start-up or you work for a huge multi-national; if you produce products that involve electricity, it’s likely that you’re going to be confronted with electrical product safety requirements. Almost every industrialized country has some sort of requirement for testing these products and they are going to require you to pay some attention to them.
In the United States, all products used in a workplace must be tested/marked/certified by a Nationally Recognized Testing Laboratory (NRTL). The legal language that governs this requirement is found in the Code of Federal Regulation (29 CFR 1910 Subpart S). Canada has similar requirements but doesn’t limit the area to the workplace; it’s for all products regardless of where they are used. European requirements are encountered when a company wishes to display a CE mark and putting a product ‘on the market’ often requires addressing electrical product safety.
Since properly labeling the product for sale can be one of the last considerations in the product development cycle (right or wrong) it is vital that the process be as quick and cost-effective as possible. The key element in the process is preparation.
Determining applicable standards
The first step is to determine which standards will be used to evaluate the product. This is accomplished by first determining where you wish to sell the product and then identifying what is required in those markets. For many categories, it’s likely that a harmonized standard exists and it’s also likely that having the product tested with a lab that participates in the CB Scheme is going to offer you the fastest and cheapest path to compliance across multiple economies (countries). The CB Scheme is a system in which over 50 countries participate (for more information: https://www.iecee.org/).
Once you determine the appropriate standard(s), buy them; it makes no sense to design a product without knowing the rules that determine its compliance (you wouldn’t attempt to build a home without investigating the local ordinances, would you?). Once you have the standard(s), perform an internal assessment in your own lab or factory. During this exercise you’re likely to generate questions, usually surrounding applicability. A version of these questions often takes the form of “Clause 2.3.1 of standard X says Y. In our product we are doing Z. What verdict is your lab going to render when you encounter that clause?”
Designing for compliance
When you are satisfied that you’ve completed a thorough review of the product in the context of the applicable standard(s), approach the lab you plan to work with and schedule some time to review these questions. In this way, you will likely avoid some of the ‘unforced errors’ that companies new to compliance usually commit. While most labs offer some paid version of this service, MET Labs, the world’s first NRTL, will engage in a limited way at no cost offering first-time clients a complimentary design review to address these very issues. Incidentally, one of the most common non-compliances we encounter with product safety assessments is in the area concerning documentation. We provide a Project Submittal Checklist to help ensure that you have the basics covered; click here to view details about Technical documentation – See item 4.
Almost every lab generates quotations that specify a cost and testing duration based upon the client submitting a compliant product. If the product that you submit is not compliant, you’re likely to encounter additional costs and inevitable delays. While a full investigation is required to determine the ultimate compliance of a product, engaging with a lab in the manner described is going to reduce the likelihood that you’ll encounter ‘show stoppers’ during the course of the assessment. Again, the key to a successful compliance program is preparation.
With 60 years of product safety expertise, we help you navigate growing complexities in product safety compliance. From testing & certification to global market access, we help you bring your product from development to end use faster and more cost-effectively. Eurofins | MET Labs performs product safety testing & certification for virtually any market and product safety standard to help you bring the best product to market quickly, responsibly, and cost-effectively.