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Re: [RFI] Low voltage lighting solid state "transformers" (long,somewhat

To: rfi@contesting.com
Subject: Re: [RFI] Low voltage lighting solid state "transformers" (long,somewhat OT)
From: Tim Groat <tcgroat@mesanetworks.net>
Date: Tue, 19 Dec 2006 21:49:34 -0700
List-post: <mailto:rfi@contesting.com>
>"Cortland Richmond" <ka5s@earthlink.net>:
>
>I see from the UL site they are made by
>PILOT INTERNATIONAL LTD E185630
>ROOM 1708-09, 17/FL
>TOWER A, REGENT CENTRE
>63 WO YI HOP RD
>KWAI CHUNG, NT HONG KONG
>and they have a valid UL listing

Not quite! They are *recognized components*, but that is not the same as a 
Listed finished product. Note the backwards "RU" (USA) and "cRU" (Canada) 
approval logos in the photo 
<http://www.hrelampparts.com/files/Cat/HRE/Ballast_Transformer/M_LVT_60N.jpg>. 
That is a component recognition mark--not the listing mark (UL and cUL in a 
circle for USA and Canada, respectively).

 From the UL web site: "The devices covered under this category are 
incomplete in certain constructional features or restricted in performance 
capabilities and are intended for use as components of complete equipment 
submitted for investigation rather than for direct separate installation in 
the field. THE FINAL ACCEPTANCE OF THE COMPONENT IS DEPENDENT UPON ITS 
INSTALLATION AND USE IN COMPLETE EQUIPMENT SUBMITTED TO UNDERWRITERS 
LABORATORIES INC." (emphasis in the original)

According to the details of their UL file, the output is not Class 2 (OC = 
4; it would be 1 if it was Class 2 output). That does not agree with the 
seller's web page 
(<http://www.hrelampparts.com/CatPages/ADL/Hardware/H039.html>, about 3/4 
down on the right side). The output cannot be connected to CL2 or similar 
low power wiring. It is not suitable for field wiring (FC = 0). It has only 
functional grounding rather than safety grounding (GC = 0), though it 
appears to have a non-conductive plastic enclosure. The supply must operate 
within safe temperature limits in the final product (adequate ventilation, 
etc.). None of this means it's defective, only that the supply must be 
*factory assembled* into a finished, Listed product ready for installation 
and use.

 From Steve's Dec 16 post, "..the electrician put them in small 
receptical-sized boxes." If the *electrician* installed them in the box, 
that could be improper application of a recognized component where a Listed 
product should be used. If the *lamp manufacturer* installed the power 
supplies in the boxes and earned their own Listing mark for the complete 
product, there is no issue. So look for a Listing mark on the complete 
lighting system.

The ultimate manufacturer also is the responsible party for FCC compliance. 
For RFI, selling a *component* is comparable to the recognized component 
safety situation (in most cases). Manufacturers legally can and do sell 
non-compliant power supplies to manufacturers, per FCC rules 15.101(e)(3). 
The final manufacturer is responsible for including the necessary 
filter(s), shielding, and for emissions testing. The combination of 
component recognition for product safety and the lack of FCC markings 
suggests--but doesn't prove--that the power supply was designed for use 
with external filtering.

The usual disclaimers apply. This is not professional advice; if you need 
some hire a PE, which I am not.

--Tim (KR0U)


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