Steve Rood, Director of Codes and Standards, Legrand/Pass & Seymour
Manufacturers absorb significant expense for the creation, control, maintenance, and production of product markings, packaging, and instruction sheets that have traditionally been used to convey required certification or conditions-of-use information. Dynamic regulations and standards often result in necessary changes to the markings or usage information, driving significant non-recoverable costs and lost productivity in the form of waste and market confusion as generations of product are rolled out with current markings or information.
A new marketplace initiative for conformity assessment and certifications could enhance NEMA member companies’ ability to share product information while seeing longer-term cost savings associated with marking and labeling. It is being evaluated by a joint task force of NEMA’s Codes and Standards Committee and the International and Regional Standardization Committee.
Conformance labeling typically identifies performance criteria and compliance marks for a specific product or system of products. This labeling or marking serves to formally claim compliance with governmental or private standards of performance regulations, as well as other requirements of authorities having jurisdiction. Examples include paper or film flexible adhesive-backed labels, metallic nameplates attached by rivets or similar hardware, and permanent markings engraved or stamped directly on the product during the manufacturing process.
But many electrical products are shrinking in size even as their performance capabilities and worldwide market reach expand. The demand for additional certification marks to reflect the endorsements of more organizations in more countries is driving the search for solutions that better lend themselves to more and frequent changes, while being less dependent on the physical label to accommodate this growing number of marks. Figure 1 illustrates compliance labeling provided on a laptop computer power supply as well as via QRC (quick response code).
Electronic labeling (e-labeling) has been suggested as a solution to enable conformance labeling requirements that are increasingly numerous, physically larger, and subject to wider variation.
The joint task force, which has met numerous times to develop an industry position and recommendations on membership direction pertaining to e-labeling, is addressing:
- the priorities of e-labeling global regulations, standards, and practices;
- how e-labeling relates to marks on equipment and equipment packaging; and
- how e-labeling pertains to compliance markings, typically consisting of agency marks, equipment ratings, and instructions for use.
Surveys are being developed by the task force in conjunction with NEMA/BIS to solicit member companies and other stakeholders within the industry to:
- gauge familiarity and acceptability of e-labeling
- outline current or anticipated benefits
- estimate incremental investments associated with NEMA members' ability to offer e-labeling features or options in addition to current labels and markings
- voice concerns
Current e-labeling methods that exhibit compliance information include electronic displays on devices and products with integrated display screens and QRCs accessible by a code reader.
In a parallel effort, the U.S. National Committee's Conformity Assessment Policy Coordination Committee has established a Working Group (WG) on e-Labeling, which is considering the entire subject of electronic labeling design, including internet-based options and adoption strategies.
The group will develop recommendations to help advance the concept. WG Chair Gary Schrempp, Director of Global Regulations and Product Safety Investigations at Dell, said, "While current work is focused on menu-driven e-labels that are appropriate only to products with built-in displays, we would like to see full consideration given to options which take advantage of the power of the internet, options that could apply to all product types and provide consumers and regulatory authorities far more information than today's physical labels."
A joint task force report summarizing e-labeling as it relates to current or emerging regulations, standards, and practices pertaining to compliance markings on equipment and packaging will be submitted to NEMA's Standards and Conformity Assessment Policy Committee at its fall meeting.
Mr. Rood is credentialed as a construction documents technologist and LEED green associate.