David Geldart, Lumicrest Lighting Solutions Inc.

Regulations & laws from 3 levels of Gov’t (moreso in USA)

CE not recognized at all

Two primary concerns of regulations:•

Electrical safety

•

Fire safety

Why not CE?

Concern that “self-declaration”

may be more open to abuse

North American construction uses more wood products and insulation than typical European, so there are different standards

Resistance to change from existing system

Before NAFTA (North American Free Trade Agreement) had to have CSA approval (only)

After NAFTA, harmonized (almost) with USA regulations, based on UL standards

Now use mainly variants on UL (ie. CUL)

Products must be tested by 3rd

party labs

to these standards. Several different labs are recognized.

Any Nationally Recognized Testing Laboratory can perform the tests.

Most well known are UL, CSA & Intertek (ETL)

In Ontario, electrical safety regulations are enforced by the Electrical Safety Authority (ESA).

Known as an AHJ (Authority Having Jurisdiction)

ESA is a private, for-profit company.

Understanding the system“component”

certification vs. “whole

product”

& allowable usesDealing with foreign manufacturers who

don’t understand/respect the systemFinding products that are properly certifiedDetermining if manufacturer’s certification

is real or fake Certifying uncertified products. (High cost,

no assurance of success)

Canadian Electrical Code C22.1-02, Nineteenth Edition (Canadian Standards Association). All electrical products sold, displayed or connected to a source of power shall be approved by a recognized certification agency in Canada.

Electrical product standards in Canada are considered part of the Canadian Electrical Code and thus are federally regulated. Compliance with Canadian product standards must be evaluated by a Certification Organization accredited by the Standards Council of Canada. Certified equipment is typically verified through the presence of a mark from an accredited organization Source.

Canadian Provincial Laws: Ontario Electrical Safety Code is mandatory. The OESC is passed into law by the provincial Government.

Use as many certified UL recognized components as possible. Otherwise each piece tested from scratch. Very slow and expensive!

Some critical parts MUST be UL recognized components

Importer cannot know if product is designed this way (probably not)

Too risky for importer to submit for certification on their own

Testing lab may require manufacturer to make changes to the product to meet requirements.

Importer has no assurance manufacturer would comply.

Annual fees for maintaining certification, quarterly factory inspections etc. Again, manufacturer must be a willing player.

Some foreign manufacturers say:“if an importer generates a big pre-order

for my product, THEN I will get it certified”

However it will take 3-6 months or more for a product to go through the process. Client may lose interest.

So: importers reluctant to make effort to “pre-sell”

products based on this.

Look for the number near the mark. Look up on UL, CSA database etc.See if manufacturer, model # are thereSee if description matches productSee if mark is properly designed. Ie. is it the

real mark, or an altered version of it.Sometimes certification is real

but foreign

factory does not understand need to use specific graphic art when applying the mark!

Looking for power supply for LED productsSearched UL database for suitable productsSearched websites online alsoFound product sold by US company, very

inexpensive but seems solidPurchased sample, has CSA mark & numberLooked up the number; the model is not

listed

Emailed CSA to ask them to clarify if the product is actually approved

Several days later, receive response requesting photos of the unit, as they are unable to determine without looking

THUS: Hard to know if you are getting a certified product, even when labeled -

and even for the certifiers!

If certification is fake & product causes hazard or damage:

Insurance company may (will) sue

Send samples to importers etc. to get feedback if product would be accepted in market (if it were certified)

In some cases, can have “limited batch certification”

or “field evaluation”

to

allow up to 300 (or 500 in some provinces) units annually to be sold.

Then pursue full certification if successful.Cost: 10-20K to certify, plus annual fees

and inspections.Need to ensure product likely to pass or

need minimal changes before submittingCan purchase UL standards online for

several hundred $ for engineers.

David Geldart, Lumicrest Lighting Solutions Inc.