Comment Log Display

Underwriters Laboratories Inc. (UL) would like to comment on the
Proposed Regulation Order – Regulation for Limiting Ozone
Emissions From Indoor Air Cleaning Devices.  UL’s comments address
two issues we would like the California Air Resources Board (ARB)
to consider prior to final publication of the regulation. 

UL is concerned with the signature requirements of the Indoor Air
Cleaning Device Certification Application (“Appendix D”).  Within
our organization, the project reviewer is the staff responsible
for determining compliance with applicable requirements and for
authorization to use the UL Mark.  Laboratory technicians are not
authorized to determine if an air cleaning device complies with
the electrical safety requirements of ANSI/UL standards.  UL
recommends modification of Appendix D to include the signature of
those individuals or job titles responsible for determining
compliance with regulatory requirements.
 
UL would also like to express concern about the timeline for
implementation of these regulatory requirements.  We are currently
working to establish a new service offering, testing products to
these requirements, but with many variables still outstanding, we
anticipate not having a program ready until September 2008. 
Recognizing that certification bodies do not currently have a
program or infrastructure in place to certify products to these
new regulatory requirements, UL believes that a January 2009
effective date may pose a market barrier for products being sold
in the state of California.  

We thank you for your consideration of these comments.  Please
feel free to contact us should you have any questions or require
any additional information.  


Sincerely,
Claire A. Kammer
Manager, Government Affairs