At ACIL, the national trade association of testing laboratories and third-party product certification organizations, we read with interest the Nov. 24 front-page story on Underwriters Laboratories (UL) and its product safety services.

We believe The Post's readers need to understand the context within which UL functions, the overall reliability of the U.S. system for ensuring the safety of consumer products, and the corrective action that would reduce the likelihood of problems such as those identified in the article.

In this country, government regulators generally depend on the private sector to develop safety standards and to test products for conformance to those standards. Although UL holds a prominent position in this arena, several other qualified organizations develop standards and test and certify consumer products for safety and reliability. Many participate in ACIL and -- in the interest of public safety -- work closely with government regulators, such as the Occupational Safety and Health Administration and the Federal Communications Commission.

The primary flaw in UL's modus operandi that must be corrected concerns the way UL develops its standards. UL is, by far, the largest U.S. developer of electrical safety standards, yet it uses a process much less open than that of almost all other major U.S. standards developers. Participation in UL's process is by invitation only. Certain manufacturers and UL technicians provide the major input; other organizations capable of contributing are not included. In many cases, UL will adopt a standard and initiate testing of products to that standard before submitting it to the American National Standards Institute for public review.

In the spirit of its longstanding commitment to public safety, UL should open its standards development process and allow full participation by all interested parties. This would lead to greater public safety.


Executive Director



The article about Underwriters Laboratories was most disturbing. It drew upon a few, recent illustrations to imply a general level of incompetence at this highly regarded institution. While these errors in judgment were unfortunate, they were by no means representative of UL's performance. UL's high level of integrity and commitment to consumer product safety have allowed the American public to rely upon its seal for more than 100 years.

UL has developed more than 700 safety standards while conducting safety tests for more than 17,000 products. To suggest, as this article did, that UL acts as a tool of industry is without any evidence.

Since its inception, the Consumer Product Safety Commission has worked cooperatively and productively with UL. Indeed, even the issues the article cited ultimately were resolved as a consequence of this cooperation. Without the conscientious efforts of standards-setting organizations such as UL and others, the American public would be left vulnerable to the hazards posed by thousands of potentially unsafe consumer products.

This commission never could hope to effectively investigate, test and regulate such an enormous panoply of consumer products. And it alone could never achieve the level of product safety for the public that has resulted from this public-private partnership. Indeed, for this very reason, Congress has reiterated its strong preference for voluntary standards setting in the private sector.

Having standards set exclusively by the federal government would not be in the best interests of the American public.


Vice Chairman and Commissioner

U.S. Consumer Product Safety Commission