White Paper: The Acceptance of the CSA/US Product Certification Mark

For over 100 years, products have been tested and listed by independent testing laboratories for use in North America to assure public safety. Product certification marks are the result of an independent, accredited third party testing and certification process. Today, the largest three product-safety testing and certification laboratories in North America are UL, CSA and ETL. Although UL is often thought of as the Kleenex of certification laboratories, the acceptance of the CSA/US mark has grown tremendously in the past decade, to the point where UL and CSA/US marks are virtually interchangeable today. The Most Important Thing to Understand There are actually two considerations, the standard to which a product is tested and the independent testing and certification laboratory that tests the product and certifies its compliance, authorizing the manufacturer to apply its certification mark. All listed luminaires in the US are tested to the same standard, regardless of whether they are tested and certified by, and carry either a UL or CSA/US mark. Hence, UL and CSA/US marks are interchangeable and are generally equally accepted today. History of CSA CSA is an independent, not-for-profit organization supported today by more than 8,000 members in the US, Canada, and around the world. Although UL pre-dates CSA by 25 years, CSA has a rich history of leadership, established in 1919. While CSA may still be perceived by some as a standards organization for the Canadian marketplace, CSA also has a certification and laboratory division that provides services globally. CSA changed the name of their certification and testing division to CSA International in 1999 to reflect this international focus. Since 1992, CSA International has been accredited by the Occupational Safety and Health Association (OSHA) to test and certify products to over 400 US Standards (including ANSI and UL Standards). To view the OSHA listing go to: http://www.osha.gov/dts/otpca/nrtl/csa.html CSA International is accredited by other organizations including ANSI, IAS, ASTM, IAPMO, and others. As a National Certification Body (NCB) in the IECEE CB and Ex Schemes, CSA can test and certify to IEC Standards for the international marketplace. CSA participates in the harmonization of standards (UL, CSA and NOM) for North America. CSA maintains offices across the US and Canada. CSA also has offices in Europe and the Far East. CSA Mark Acceptance The National Electrical Code (NEC) frequently calls for listed equipment. Listed: Equipment or materials included in a list published by an organization acceptable to the authority having jurisdiction and concerned with evaluation of product or services, that maintains periodic inspection of production of listed equipment of materials or periodic evaluation of services, and whose listing states that the equipment, material or services, either meets appropriate designated standards or has been tested and found suitable for a specified purpose. - NEC Article 100: Definitions For lighting equipment, the Authority Having Jurisdiction (AHJ) is usually the local electrical inspector that may use the NEC, applicable building code or local codes as a guide. Thousands of AHJs nationwide require that products be certified by an accredited laboratory. US AHJs including the cities of New York, Los Angeles and Chicago, as well as the states of Washington, Oregon and North Carolina specifically, require certification marks as mandatory and have formal recognition programs. CSA is recognized by all of the above-named city and state AHJs as well as many other local jurisdictions. In other jurisdictions, certification marks may be voluntary. In either case, the presence of a reputable certification mark on the product is important because it shows that a product has been independently tested and certified to meet recognized standards for safety or performance. We feel, and have always felt, that CSA is already a nationally recognized testing agency, a name that is well known and respected throughout the industry. - Reedy Creek Municipality, Gwinnett County, GA

The CSA/US mark is widely accepted by US electrical inspectors. CSA has a close relationship with the International Association of Electrical Inspectors (IAEI) dating back to 1931. In fact, CSA Director of Audits and Investigations Doug Geralde is an IAEI board member and past-President. IAEI Executive Director James Carpenter is also a member of CSA Internationals Board of Directors. The CSA/US mark is widely accepted by US specifiers. Through collaboration with CSA, The American Institute of Architects MASTERSPEC template has been revised to reference OSHA recognized NRTL labs (like CSA) as acceptable testing laboratories. The MASTERSPEC specification system is used by Engineering and Architectural companies throughout the US. The CSA/US mark is widely trusted by manufacturers. CSA marks appear on over 1 Billion products worldwide including products from leading US manufacturers including Apple, Compaq, HP, IBM, Lennox, Mitsubishi Electrial & Electronics, Black & Decker, Delta Faucet, GE, IBM, Sanyo, Whirlpool, Moen and others. Luminaires from numerous leading manufacturers also commonly feature the CSA mark. The CSA/US mark is widely accepted by retailers. CSA marks are found on many products sold in leading US retail chains today including Ace Hardware, Best Buy, Circuit City, JC Penney, K-Mart, Lowes, Sears, the Home Depot, Costco, Wal-Mart and others. Most distributors of electrical products, including Graybar and WW Grainger, sell CSA marked products. CSA is a trusted partner and were confident that products bearing the CSA mark have been rigorously examined and tested to standards that are constantly reviewed and adjusted. - Dan Kamykowski Ace Hardware Merchandising Manager, Plumbing & Electrical Demystifying Certification Marks The certification mark provides visual evidence that the product was tested and certified to meet the applicable standard. All listed luminaires for the US market are tested to the same standard, regardless of whether they carry a UL or CSA/US mark. Hence, the following UL and CSA marks are interchangeable and are generally equally accepted today. Marks for the US CSA US A CSA mark with the indicator US or NRTL means that the product is certified for the U.S. market to the applicable U.S. standards. Marks for US and Canada CSA mark with the indicators C and US or NRTL/C means that the product is certified for both the U.S. and Canadian markets, to the US applicable U.S. and Canadian standards.

NRTL UL This is one of the most common UL Marks. Products with this mark are certified for the US market to the applicable US standards.

NRTL/C UL mark with the indicators C and US indicates compliance with both Canadian and U.S. requirements. The Canada/U.S. UL Mark is optional. UL encourages those manufacturers with products certified for both countries to use this new, combined Mark, but they may continue using separate UL Marks for the United States and Canada

How US Product Testing & Certification Works Testing and certification confirms that products meet US standards by bringing three independent groups together: 1. Manufacturers: who make the products (ex: Prescolite). Manufacturers use the applicable US standards in the design process. 2. Standards Writing Organizations: who author US national product standards (ex: ANSI). These organizations include representatives from industry and other interested parties who define the specific standards for a particular type of product (e.g. a luminaire). In the US, responsibility for publishing, maintaining and distributing standards is often delegated to a standards writing organization such as ANSI, ASTM, UL, NSF, ASME, ASFE, etc. 3. Product Testing & Certification Laboratories: who test products to applicable standards and authorize product approval marks (ex: CSA). The laboratory is hired by the manufacturer to test and certify that their products meet the applicable standards.

Upon certification, the product is authorized to carry the appropriate certification mark licensed by the testing laboratory (ex: CSA/US). Sometimes, the name (or a portion of the name) of an organization well known for its testing and certification activities appears in the name of standards published by that organizations standards division (for example, UL standard 1598 for lighting fixtures or CSA standard Z21.47/2.3 for gas-fired central furnaces). This does not mean that a product must be tested and certified by the laboratory whose name appears on the standard. So-called CSA standards, NSF standards, UL standards, and others, are available to ALL qualified and accredited testing laboratories for use in testing and certifying products. What is a Recognized Laboratory? In the US, testing laboratories are recognized by the Occupational Health & Safety Administration (OSHA) as Nationally Recognized Testing Laboratories (NRTLs) that are qualified to test and certify that a product meets US standards, as governed by OSHA regulation 29 CFR 1910.7. All NRTLs test products against the same sets of standards, regardless of who wrote or published them. CSA International has been accredited (recognized) by OSHA since 1992 and is fully qualified to test electrical and lighting products for the US market. CSA is recognized by OSHA to test and certify products to over 400 US standards including ANSI and UL Standards. CSA Testing Standards Today, it makes no difference which recognized laboratory tests and certifies a product. This is a direct result of the North American Free Trade Agreement (NAFTA) as applied to third party conformity assessment procedures recognized by OSHA. CSA and UL luminaire testing is conducted in compliance with the same standard. This bi-national US/Canadian testing standard, called UL 1598/CSA 22.2 No. 250.0-00, went into effect February 1, 2001 as a replacement to such previous UL/ANSI standards as UL 1570, UL 1571 and UL 1572.

The Benefits of Competition Because multiple laboratories are recognized by OSHA to test and certify products, manufacturers have the freedom to select among them based on turnaround time, price and convenience. Since all OSHA NRTLs evaluate products against the same standards, owners, contractors, distributors and specifiers can select products based on brand, price and quality rather than on who did the testing and whose certification mark appears on the product. A competitive testing and certification marketplace helps manufacturers bring products to market quickly and economically while also ensuring that they are subjected to the testing called for by the applicable standards. How to Write a Better Specification for Approval Marks Customers can take advantage of this openness and competition and ensure that they have access to the broadest possible selection of products only if they ensure that their product selection practices are not unduly restrictive. A purchasing or specification policy requiring products certified by a particular laboratory unnecessarily limits the range of products available whereas a policy that accepts products tested and certified by an OSHA Nationally Recognized Testing Laboratory (NRTL) protects against the use of nonconforming products without placing unnecessary limitations on product selection. To ensure access to a full range of qualifying, safe and high quality products, specifications should be written to accept products tested and certified by any Nationally Recognized Testing Laboratory (NRTL) as defined in OSHA regulation 29 CFR 1901.7. Prescolite Product Listings Since UL and CSA/US marks are virtually interchangeable today, Prescolite enjoys the freedom of pursuing whichever mark allows us to bring products to market the most swiftly. Hence, Prescolite products might carry either a UL or a CSA/US mark. No Prescolite products are ETL listed today. Frequently Asked Questions 1. Where can I get more information on CSA? Call CSA International at 800-463-6727 or visit www.csa-international.org. 2. Who can I call for help if I encounter a specification that prefers UL over CSA? Contact CSA International Business Development Manager at 416-747-4142. or Sue Dempsey, CSA International VP North American Sales at 216-524-4990. Can I obtain documentation of CSAs acceptance by my local Authority Having Jurisdiction (AHJ)? Over 10 years ago, CSA initiated their Recognition in the US program, visiting many state and local authorities to promote and obtain acceptance of the CSA/US mark. CSA retains many letters of acceptance from these jurisdiction as evidence of their acceptance of the CSA/US mark. Contact Len Mitchell at CSA International (416-747-4277) to check on your local jurisdiction and obtain acceptance documentation. How is it ensured that products continue to comply with the standard(s) against which they are listed over time? Certification agencies conduct a series of unannounced, on-site inspections as mandated by OSHA for products sold in the US and the Standards Council of Canada for products sold in Canada. I understand that a product can be tested to a UL standard yet carry a CSA mark. How can this be? If the standard is UL, doesnt the mark also have to come from UL? Companies such as UL and CSA are involved in both standards publication and testing. It is a common misperception that because a companys name appears on a particular standard, that companys laboratory must exclusively perform product testing against the standard. The fact is, the standards and testing roles are performed independently within companies like UL and CSA in order to avoid a conflict of interest. The standards are available for the manufacturers use in design and manufacturing and are also available to all accredited testing and certification agencies for product testing. If all listed luminaires in the US are tested to the same standard and it makes no difference which accredited agency tests and certifies a product, why doesnt Prescolite just list all of their products with a single agency? Since the quality and meaning of the listing mark is the same between UL and CSA, the differentiator in Prescolites agency decision is service. To meet the needs of our customers, we must develop products quickly. To meet the needs of our company, we must also do so cost effectively. At any given time, one agency might be more responsive than the other. We also negotiate competitive fee structures with both agencies. We try to leverage the universal acceptability of UL and CSA certification to work with the agency that allows us to develop high quality, safe products the fastest and the most cost effectively. Your acceptance of Prescolite products that carry either a UL or CSA/US mark give us the flexibility we need to do this.

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WP # 0001b March 19, 2008