Formal Interpretations

1 General - Formal Interpretations are intended to respond to requests on the meaning or intent of a requirement in the Standard. The STP is responsible for making a Formal Interpretation (hereafter referred to as Interpretations). A reasonable fee will be charged for processing a formal interpretation. This fee may be waived or reduced upon presentation of evidence by the submitter showing hardship.

1.1 Limitations - A statement, written or oral, that is not processed in accordance with this policy on Formal Interpretations shall not be considered the official position of UL’s Standards Organization or any of its STPs and shall not be considered to be, nor be relied upon as, an Interpretation.

1.2 Nature of Interpretations - Requests for Interpretations shall be clearly worded so as to solicit a Yes or No answer from the STP.

1.3 Editions to be Interpreted - Interpretations shall be rendered only on the text of the current edition of the Standard. Requirements that have been superceded by revisions are not eligible for interpretation.

1.4 Method of Requesting Interpretations - A request for an Interpretation shall be directed to the STP Chair. The request shall include a statement in which specific references to a single problem and the identifying portion (section, paragraph, table etc.) of the Standard on which an Interpretation is requested. Such a request shall be in writing and shall indicate the name and affiliation of the requester.

2 Processing - When an Interpretation is received by UL, the STP Chair shall determine the proper course of action.

2.1 Determination of Qualification - If the STP Chair, after consultation with the UL’s Director of US Standards and other individuals as appropriate, determines the request for an Interpretation is inappropriate in accordance with 2.2, the submitter of the request shall be notified of the reason and the interpretation request will not be processed.

2.2 Reasons for Not Processing - A request for an Interpretation shall not be processed if the STP Chair determines it:

a) Involves a review of a specific product, or requires judgment or knowledge that can only be acquired as a result of on-site inspection,

b) Involves text that clearly and decisively provides the requested information,

c) Involves subjects that are not addressed in the Standard,

d) Is not in a format that can be responded to with a “Yes” or “No” answer,

e) Is unclear or is structured in a way that it contains assumptions that aren’t directly supported by the Standard’s text,

f) Contains compound questions, where the answers to one or more questions are contingent on answers to other questions, that can be confusing or complicated, or

g) Involves the text of an IEC/ISO standard that has been adopted by UL.

2.3 Editing of Interpretation Request - A request for an Interpretation that is not clear or that is not worded so as to result in a “Yes” or “No” answer will be returned to the submitter for editing.

2.4 Balloting of Interpretations - If accepted for consideration, each request for an Interpretation shall be submitted to ballot of the STP having primary jurisdiction of the Standard under consideration. The ballot period shall be 30 days. The STP will not provide an official response to comments received during ballot.

2.5 Ballot Extensions - The ballot period can be extended by the STP Chair if requested or if more time is needed to obtain sufficient ballots to determine consensus.

3 Voting on Interpretations - An Interpretation requires consensus. Consensus is considered achieved if there is agreement of at least two-thirds of those members who have submitted a vote, excluding abstentions, and a majority of the STP has returned a ballot.

3.1 Recirculation of Interpretations - Where ballots contain substantive comments with regard to a position set forth in an Interpretation request, such comments shall be recirculated after the original ballot period to each STP Member, who may change his or her ballot at that time. The re-circulation period shall be two weeks. Comments received during recirculation will not be provided with a response. At the end of the recirculation period, consensus as defined in 3 must be maintained for the Interpretation to be issued.

4 Issuance of Interpretation - If the Interpretation decision achieves consensus (either “Yes” or “No”), the requester and the STP shall be notified by the STP Chair. The Interpretation shall be issued and shall become effective immediately. The decision by the STP is binding until it is withdrawn as noted in 5.1. If consensus is not achieved on an Interpretation, the requester and the STP shall be notified and no further action shall be taken.

4.1 Publication - Interpretations of text of the current edition of a Standard shall be published by UL’s Standards Organization and be made available with the Standard.

5 Action Following Issuance of Interpretation - It is the responsibility of the STP to maintain the standard and pursue the revision to the standard resulting from an Interpretation. When an Interpretation has been issued, the STP Chair determines who will be responsible to submit and take ownership of drafting the proposal. The STP Chair may choose to assign this task to (1) the requester of the Interpretation, (2) an individual, or (3) a task group. The proposal will then follow the standards process in accordance with these regulations.

5.1 Expiration of Interpretation - When consensus is achieved on the proposal addressing an Interpretation, then the Interpretation shall be withdrawn when the corresponding revision is published. After issuance of the next edition of the Standard, any remaining Interpretations shall be withdrawn.