[RFI] Low voltage lighting solid state "transformers" (long, somewhat OT)

Cortland Richmond ka5s at earthlink.net
Thu Dec 21 03:21:50 EST 2006


An acute observation, and thanks, too for diving into the UL site. 
"Factory assembled", eh?  

The thot plickens!


Cortland
KA5S



> [Original Message]
> From: Tim Groat <tcgroat at mesanetworks.net>
> To: <rfi at contesting.com>
> Date: 12/20/2006 10:15:57 PM
> Subject: Re: [RFI] Low voltage lighting solid state "transformers"
(long,somewhat OT)
>
>
> >"Cortland Richmond" <ka5s at 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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