Possible alternative we could push instead of FDA Regulations?

[ScottP]

While I understand how the FDA has the purview to regulate juice as a nicotine based product, I just can't get past them being able to regulate mods which are electronic devices and are neither made of nor contain nicotine. I was thinking maybe they could be appeased to drop their regulations on these devices if CASAA and the product manufacturers agreed to get all products UL listed.

UL (Underwriters Laboratory) is a safety testing organization that tests electronic products to guarantee a minimum level of safety. If you look at nearly any electronic device in your house it probably has a UL sticker on it somewhere. They are better equipped to understand the devices than the FDA, and we would get potentially safer products while keeping the market open and less regulated.

Thoughts opinions?

 

[Izan]

UL certification is optional, and VERY expensive.

IMO: I don't think the FDA cares one way or the other.
But I think the BT/BP products that DO get approved will get any and all certs needed.

Cheers
I

 

[stols001]

It's an interesting idea, I doubt the FDA would go for that, however. I think they really do wish to have regulatory power over these devices, regardless of the fact that it doesn't make a lot of sense.

Anna

 

[VNeil]

The FDA's Deeming regulations are a purely political decision, not based on any facts of the matter. Otherwise they would not have spent a billion dollars issuing research grants to "prove" vaping is worse than smoking.

If all vape mods had to be UL approved it would drastically change the vape market. For starters, there would be no mechs, period. They would never approve a high power, potentially explosive device lacking even a fuse. Nor would they approve 200W dual battery box mods, pulling up to 31 amps each out of user selected 18650s. There may be other things that would not cert but those are the really blatant ones that you don't need to be an EE to figure out. Personally I think it would be a good idea, overall, but I suspect I would get a lot of grief here over that. It would be far more productive and more efficient than having to prove some social benefit for vaping, and forcing the vape market to prove a huge negative.

 

[Beamslider]

FDA will never agree to that. They will take the position that a device whose only purpose is to vape is a delivery device.

They regulate medical equipment under the same premise.

A UL approved device would no doubt be one most vapers wouldn't want either. Would probably be sealed battery built in unit.

 

[ScottP]

All good points. Considering UL has never certified a mod or ecig of any kind before, we really don't know what their standards would be. I still suspect that it would be easier and faster to pass UL than getting an approval from an agency (FDA) that doesn't want to approve it in the first place.

The current FDA administration is more open minded than the previous one, but a changing of the guard could reverse that. All a new Commissioner would have to do, is decide that due to budget concerns, the staff who's job it is to approve ecigs have to be cut, and that would effectively close the gate. They might legally have to keep 1 part time person just to say they are still approving them "as fast as they can" while still essentially killing the market.

 

[Beamslider]

Well you can get a pretty good idea if you look at UL lithium battery standards. Doubt they would even certify a battery for vaping.

Standards Catalog

here are the user replaceable battery standards for lithium
Standards Catalog

You are going to end up with one very expensive device.

 

[Beamslider]

And there is this....They have e-cigarette listing requirements
UL Announces Certification for Electronic Cigarettes | UL

 

[VNeil]

A UL approved device would no doubt be one most vapers wouldn't want either. Would probably be sealed battery built in unit.

This thread got me thinking about that. But I think they do certify open system devices like flashlights, where a user can put any combination of bulb, battery and flashlight together into a system. I assume their standard is that any idiot may be putting that together, so the system needs to have enough protection to keep any idiot from blowing himself up.

There are lots of mods that are conservatively rated, and have enough protection to keep any idiot from blowing themselves up. Power limiting, reverse polarity protection, short circuit protection, internal thermal protection make it really hard to blow up a modern regulated mod. Except...

The problem of user selected batteries. Using 18650 as an example, there are a lot of different 18650 variants. It's hard to blow up an IMR/INR 186560 in a good mod. But people can put other non-recommended batteries in them and I'm not sure how UL would deal with that. And I suspect that is one reason you don't see power tool battery packs with user replaceable 18650's. and I'm sure the makers are happy with that since they can sell more overpriced battery packs without a competitor adding a greatly desired feature like user replaceable cells.

A solution to that would be to make a new proprietary (to the vaping industry) battery format that would basically be an 18650 that is certified to work at the discharge rates required, that only fit vaping mods. It might also require newly designed recessed contact pins that are difficult to short out, like was done with DSLR camera systems.

 

[ScottP]

Well you can get a pretty good idea if you look at UL lithium battery standards. Doubt they would even certify a battery for vaping.

Standards Catalog

here are the user replaceable battery standards for lithium
Standards Catalog

You are going to end up with one very expensive device.

Yeah I read that stuff, the recommended batteries that we already use should pass those tests with flying colors. There is no "fitness of purpose" test for just batteries.

UL pretty much checks if the device works as intended, within specified parameters, and can pass some basic stress and damage testing. Like they may drop it from various heights, is it broken? Did it do something that might be harmful?

 

[ENAUD]

The testing requirements for UL 8139 specifically evaluate the safety of the electrical, heating, battery and charging systems.

quoted from UL Announces Certification for Electronic Cigarettes | UL

If I understand this, they would require all components of the power device, so anything with user replaceable batteries, and all mechs would probably get a fail...am I understanding this correctly?

 

[ScottP]

And there is this....They have e-cigarette listing requirements
UL Announces Certification for Electronic Cigarettes | UL

OOOHHH I didn't find that when I looked earlier but I just looked up that specific specification now here is what they would be testing. Who wouldn't want their device to follow these guidelines? Especially the Performance section.

INTRODUCTION

• 1 Scope
• 2 Components
• 3 Units of Measurement
• 4 Undated References
• 5 Glossary

CONSTRUCTION

• 6 Enclosures
• 7 Resistance to Corrosion
• 8 Current Carrying Parts
• 9 Battery Chargers
• 10 Vehicular Battery Adapters
• 11 Universal Serial Bus (USB)
• 12 Battery Pack Compartments
• 13 Battery Packs
• 14 Switches
• 15 Atomizers
• 16 Printed Wiring Boards
• 17 Protective Circuits and Controls

PERFORMANCE

• 18 General
• 19 Single Fault Conditions Test
• 20 Normal Charge Test
• 21 Normal Discharge Test
• 22 Forced-Discharge Test
• 23 Overcharge Test
• 24 Abnormal Charging Test
• 25 Short Circuit Test
• 26 Temperature Test
• 27 Water Exposure Test
• 28 Drop Test
• 29 Crush Resistance Test

RATINGS

• 30 General

MARKINGS

• 31 General

INSTRUCTIONS

• 32 General

 

[Beamslider]

Battery packs is probably the key.....not loose batteries

 

[ScottP]

If I understand this, they would require all components of the power device, so anything with user replaceable batteries, and all mechs would probably get a fail...am I understanding this correctly?

Not necessarily. They test lots of devices with user replaceable batteries. Everything from flashlights, to portable music devices (including the old Sony Walkman cassette players), to multi-meters, to ... really everything else with changeable batteries. Many of which do NOT use battery packs.

 

[ENAUD]

Couldn't help but notice forced discharge test, and short circuit test in their performance category...

 

[ScottP]

I should add that a UL listing does not guarantee a product will not explode or catch fire. I know a guy that is covered in burn scars b/c a UL listed "boom box" caught fire while he was sleeping when he was in High School and burned his house down. Also the Samsung Galaxy 8 line were the FIRST cell phones to get UL under their newest standards and look what happened with the Note 8's.

 

[VNeil]

Not necessarily. They test lots of devices with user replaceable batteries. Everything from flashlights, to portable music devices (including the old Sony Walkman cassette players), to multi-meters, to ... really everything else with changeable batteries. Many of which do NOT use battery packs.

Most of those devices use standard AA/AAA type batteries that don't blow up if misused. The big question is if any HIGH POWERED flashlights that use 18650 batteries, for example, are UL certified. I stress high power because in order to be a good acid test of potential certification the flashlight would need to be capable of discharging at the same rates we discharge our mods. Or a reasonable rate (say 50W per 18650 battery).

 

[ScottP]

Couldn't help but notice forced discharge test, and short circuit test in their performance category...

Regulated mod usually advertise that they have short circuit protection. They would validate that claim. Not sure about forced discharging.

Also most regulated mods have charging capabilities even if they don't have built in batteries. PBusardo has even caught some in his testing that did not do it in a correct and balanced way. They will be testing that functionality as well.

I would also like to mention that when they evaluate a device they do SKIP standards that are not applicable to the device. For instance their Home Stereo standard may have a test for Component output or optical audio output, but if a device is missing those features they skip those tests, they don't fail it.

All that said, I cannot say with any degree of certainty how they would handle a pure mech mod.

 

[VNeil]

All that said, I cannot say with any degree of certainty how they would handle a pure mech mod.

Mechs: Instant Fail of the forced discharge and short circuit protection tests.

Regulated Mods: Pass if decent design. Regulated mods limit the max power. The issue would be what is an acceptable max discharge rate of a mod using user replaceable batteries. They could, for example, limit a single 18650 mod to only 10-20 watts, or even much less, some number that accommodates the stupidest battery selection any idiot might make.

 

[Izan]

quoted from UL Announces Certification for Electronic Cigarettes | UL

If I understand this, they would require all components of the power device, so anything with user replaceable batteries, and all mechs would probably get a fail...am I understanding this correctly?

I'm fairly confident my REO Grand would pass certification.

Cheers
I