Why Getting Your Robot a UL Mark Should Be Considered an Enabler and Not a Cost
A quick Q&A guide on how to work with UL.
Part of my mission with OttOmate is to better equip food robotics startups with the information, resources and tools they need to develop and get their products to market.
A couple months back I did a Q&A with NSF International to provide startups with a quick primer on the process of getting the much-needed NSF food safety certification. That piece resonated so well with readers that we’ve turned it into an ongoing series (plus a live event happening early next year).
But another important mark any bit of food automation should have is provided by UL. A simple way to think about it is that the NSF makes sure your robot safely handles food, getting a UL mark means your actual machine is safe to use.
To find out more about what UL does and how to engage with them, I recently sat down with Glory Ko, Business Development Manager for Consumer, Medical & Information Technologies at UL; Jonathan Brania, Primary Designated Engineer and a Manager for Appliances, HVAC & Lighting at UL, and Ibrahim Jilani, Director & Global Industry Leader at UL.
In the following Q&A, which has been lightly edited for clarity and concision, we talk about what UL does, how to work with them, the importance of operationa domain design, and why getting the UL mark should be considered an “enabler” and not a cost.
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Let's start with a baseline. What does UL do?
Glory Ko: UL is a testing and inspection certification company. But beyond that, we also define the standards for product safety and some performance standards as well. So for a robotics company, we are really here to help because when they want to add a product, a new design, to their customer and their buyers, they are always asked, ‘Who is backing you on your productivity performance side and other aspects?’ So UL helps them get suitable certification, or report or test data to support their new product development.
So UL will cover, for example, fire or electric shock for robots. Beyond that, we cover safety concerns for robots — whether or not it can do both [collision] avoidance and whether or not it will hurt people, or crash into something else around the robot. For example, in a restaurant, there may be kids, there may be an elderly person alongside the robot when doing delivery. So UL is here to help those companies to make sure their robot wouldn’t collide into any objects. So for robotics, the UL standard and UL will help them to identify what's the safety operation and help them to identify the kind of design.
And we also engage with other stakeholders in this industry, for example, we we engage with many robotic Association in different countries with respect to a friend and their members.
We also come out with new standards for robotics. For example, UL had one standard published this year for the ANSI UL 3100, it covered automated mobile platform. And beyond that, we are also working on UL 3300. This one will be another ANSI and SCC national standard for US and Canada.
Why is it important for a company to get UL certification?
Jonathan Brania: In some instances, it's a matter of market access that somebody would want UL certification. An inspector might be enforcing the code in some jurisdiction. We call them AHJs (Authority Having Jurisdiction). There might be an operator or some other user that may have internal policies like chain restaurants — they might require certification as well. And in both instances, really the main interest is to provide additional assurance beyond what the manufacturer might provide that the product is safe and that basic hazards are going to be addressed. So UL has a global network of people and laboratories in more than 100 countries and we devote those labs and those people to helping customers that need to get access to a market or meet the AHJ’s expectation.
And at the same time, it's not always about market access. There’s manufacturers in general, they have a responsibility, and it's really deeper than that they've got a desire to bring safe products to the marketplace. So if you're designing a robot or automation process, you know that the primary focus when you're designing that process is is to complete a task and to do that task better than really anybody else can do it. So, really designers obviously have a good sense for how the product can be made to operate safely, but sometimes there's blind spots that can be addressed. They can be the product itself or how the product operates. Aspects of certain components or materials or could be how the components or materials can interact with each other. That can that can kind of create issues. So where best practices exist, and generally their standards and standardized requirements — we want to help manufacturers ensure that their products meet those requirements.
Products that are evaluated by UL, that are able to use our mark or UL marks, they get access to one of the most widely recognized and trusted symbols of safety for consumers globally. So if you're making a new product, you want buyers to have confidence and we want to help them succeed in the marketplace, that's that's why it's important to get our certification.
If I have a food robot startup and I want to get started with UL, is there a specific place to start?
Ko: We have mailbox, email@example.com. So they can simply send to that mailbox and we can distribute internally and help them navigate and find the right contact. We also have a website, and feel free to contact myself as well. There are some forms later to tell UL what kind of product and spec. But for robotics, we also will discuss with manufacturers in the early stage. What is the operation design demand (ODD). It's a concept originally from automotive industry. And now robotic industries start to consider it because robots are going to work in a complicated environment. And most environments are more complicated than they used to be. For example, robots used to be in your factory. Now we want to put robots in people's houses, in kitchens, in different environments. So, the operational design domain will help them define what kind of environment this product is going to be used. So that will be something in addition to an essential application form, but don't worry, we can spec step by step, and lead the manufacturer to get through and find out how to define those parameters for safety evaluation.
What stage should someone start engaging with UL? Should I do it when I’m at the CAD stage or when I have a prototype?
Ko: When we engage with manufacturers, we did find there are times when it's a bit late to contact UL, because when they fix their design, if there's any hardware in not complying with the requirement, it will be a huge effort to [re]do your design. So we do encourage an early engagement with UL. If they are in CAD stage, they definitely can ask UL what is the appropriate standard for this product in the future. But after they have some prototype, it will be the right time to contact UL. We have some service of preliminary investigation. We can help manufacturers review their early stage of design, the construction component, how they define their control in that preliminary investigation stage. We can provide feedback based on the standard requirements, what is compliant, what could be non-compliant and what kinds of items may need further testing.
I understand that each project is different, but can you give me a sense of how long just on average, how long UL certification takes and how much it might cost to get it?
Brania: What we strive for with a new a new manufacturer coming to UL, is to try to start with something around eight weeks. And we would have to take into account a lot of variables that would be going into the evaluation. One of the key things that a manufacturer can do is that we have a whole network of related components standards and component engineers, materials engineers and standards. If you can use listed or recognized components and materials, that tends to streamline things where even eight weeks can get compressed to something something shorter.
If you have some sort of component that you just can't live without, then that component might require some level of evaluation and sometimes those evaluations might take 100,000 cycles of operation through to prove that they’re safe. They might require weeks of conditioning. So there are certain considerations that wherever possible, if we have these things evaluated, understood, it can it can definitely help to streamline the overall process.
Other aspects — there's test failures throughout the evaluation of components and materials, the end product itself and design challenges. Sometimes the standards do not adequately address the products that we're seeing, and we have to stop and ask ourselves, do we need additional requirements for the standard so that we can adequately address the product? So we we have a whole process we've called our New and Innovative Process — where it's just like it says, it’s something that's new, and it's novel — to try to help you understand the additional considerations that we think need to be made and how we can get hopefully from a gap to something that has some standardized requirements and compliance for it.
In terms of costs, can you give me a sense of how much startups should ballpark to get UL certification? As they are out raising money should they budget $10,000? $100,000?
Ibrahim Jilani: The way to think about that is it depends on that operational design domain. It depends on specifically what kind of components and other materials have been sourced by the manufacturer. Maybe some of the requirements have been met because of the materials and components that have been sourced, but if let's say there was nothing sourced that was meeting requirements, as well as the end product itself needing to meet its full evaluation. To get going, that doesn't cost much — that's a few thousand dollars, up to ten maybe, depending on design complexity. That's engineering time. An engineer would sit down and review every document that the manufacturer had. When it comes to the actual ‘now we're going to do some testing and do full product compliance checking of various different components standards,’ and then of course, the end products like the UL 3300, it can get up to the six figures [assumes no component or material has met its requirements but if it has, its substantially less].
So the best way to think about it for the startups is as they're raising capital, as they're looking at their venture capitalists or other types of forms of funding, they should be putting that as part of their business enabler. That if they get the UL certification, they have a lot more markets that they can offer their product to. That is a big deal for any investor or manufacturer that not only do you finish your product, but you're not going to have a road bump when you put products on the market — that all of a sudden you can't sell it because somebody like the workplace safety inspector, health official electrical inspector, or some other stakeholders have no evidence or track record of safety. Even some of the associations for elderly or for children, they're going to start looking at: well wait a minute, was that robot designed with the elderly and/or children in mind?
I think to answer it in just one number, it's very difficult. It needs to be looked at in the lens as part of the story for how you raise your funds for a consumer or commercial robot business. It’s not a cost to your business, it’s a long termn enabler for market mass adoption.
Can you tell me a little bit about the UL 3300? Does that apply to autonomous vehicles like delivery robots?
Ko: We do cover a lot of kinds of delivery robot. For example, last mile robot and also cover indoor delivery robots. We have companies already compliant with last standard, which is that the food delivery robot can be used in the coffee shop or in the restaurant. And we have more coming. So the last standard cover various types, from small size, you know, some robot pets, very small size, all the way to medium size. A last mile delivery robot could be up to around 100 pounds. So something smaller than that, we’ll try to use existing safety standards. Something larger than that may be covered by our vehicle standard. So, UL 3300 is to cover anything from small size to medium size, and in interacting with people around it, for example, a third party. A third party means — I'm the operator am sending a robot to a customer. I'm first party and the customer is the second party and any other people in this environment will be third parties.
But as well, if there's a robot designed only to operate in kitchen, it won’t go out of the kitchen which is fine, we can limit some of the requirements that do not apply. So that’s why I mentioned that operational design domain will be a critical step for the company to define what this robot is going to operate in when it's going live.
What is the one piece of advice you would have for startups who are beginning their UL certification process? Are there common mistakes you see?
Ko: Yes, we do see some robot when it's completed, we find all kinds of components inside is don't have any safety consideration. For example, if a huge part is lithium batteries and those lithium batteries do not have a certification. That is very dangerous.
If some basic components inside do not have safety consideration, that will be a huge roadblock when we actually start a evaluation. So if they contact UL early, we can also provide them a database. UL has a tremendous database, and manufacturers can easily find a certified component. They can then purchase the component which is safe or evaluated by third party safety lab and build up those safety components into their design. So robust safety is like building blocks. You can’t jump to the head and say okay everything is safe. It’s basically block-in-block, some [blocks] are software safety, some are hardware safety.