D ATA A C C E P TA N C E P R O G R A M

UL Client Test Data Program

Investigations of products by UL typically involve the testing of product samples. While UL maintains
extensive facilities for these purposes, customers can also utilize their own testing facilities through
UL’s Client Test Data Program. UL established the Client Test Data Program to assist customers
wanting to use their own testing facilities.

With a few exceptions, the Client Test Data Program is offered

to all qualified UL customers with previous experience in the Applicable
ISO/IEC 17025:2005 Requirement
Witnessed Test Data Program. The Client Test Data Program Clause(s)

is not available for hazardous location product investigations,

1. Document control (critical technical 4.3.1, 5.4.1,
unless they are using ordinary location test methods, nor is it an
documents such as standards, methods, etc.) 5.4.2, 5.4.7
alternative to any required Follow-Up Services testing.

To participate, a customer must have in place a laboratory 2. Purchasing services and supplies (test
quality program, physical resources, equipment, qualified consumables such as cheesecloth, 4.6
personnel and procedures needed to conduct specified tests. UL thermocouples, etc.)
will assess these elements before data can be accepted.
3. Control of nonconforming tests or calibrations
Initial and ongoing validation of testing methods must be 4.9
(test instrument trace-back system, etc.)
performed. After the program is established, UL will reassess
a test laboratory annually. All data submitted is thoroughly 4. Corrective action (in relation to 4.11.1, 4.11.2,
reviewed and audited by UL before being used for certification. nonconforming tests) 4.11.3, 4.11.4

Requirements 5. Technical records (data legibility and

4.13
verification)
Assessment of laboratory operations

A customer’s laboratory operations must have documented 6. Personnel 5.2.1, 5.2.4

procedures and policies in place to assure accuracy and precision
performing tests, obtaining data and reporting results. 7. Accommodation and environmental conditions 5.3

A customer’s laboratory quality system shall be based on ISO/IEC 8. Equipment 5.5

17025:2005 and encompass test equipment, test environment,
personnel qualifications, test standards and procedures, and 9. Measurement traceability (calibration) 5.6.2.2
data recording and reporting procedures. The applicable clauses
of ISO/IEC 17025:2005 are summarized in the table below. 10. Handling of test Items (test sample
5.8
Additional UL requirements can be found at www.ul.com/dap > identification)
Resources > DAP Tools.
11. Reporting of test results 5.10

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 Document control Corrective action
(ISO/IEC 17025:2005 clauses 4.3, 5.4.1, 5.4.2, 5.4.7) (ISO/IEC 17025:2005 clause 4.11)

A participating customer must have and maintain up-to-date A participating laboratory must have procedures in place to
copies of the standards or other documents describing test implement corrective actions when nonconforming testing,
methods and procedures and containing information needed nonconforming calibrations or departures from the laboratory
for conducting tests. Standards and documents are to be readily quality system policies and procedures are discovered. These
available to personnel in the conducting tests. corrective action procedures are to include root cause analysis,
documentation of corrective actions and monitoring to assure
A participating laboratory shall have in place processes for
that corrective actions have been effective. UL is to be notified if
systematic checks of data that are transferred or calculated. A
any test data is impacted.
laboratory must also have procedures to validate any custom
software that is part of test and measurement equipment
Technical records
generating data to ensure the validity of the output. Whether
custom or off the shelf, this software shall be controlled with (ISO/IEC 17025:2005 clause 4.13)
test equipment and is part of the test equipment record.
Records are to be legible and stored and retained in such a way
that they are readily retrievable. Storage must be in facilities
Purchasing services and supplies that provide a suitable environment to prevent damage,
(ISO/IEC 17025:2005 clause 4.6) deterioration or loss. Retained records are to include quality and
calibration records and test data.
A participating laboratory must maintain procedures to
purchase, inspect and store critical consumables. Any UL requires submittal of original data. If copies of data are
consumables must meet technical specifications as noted in the submitted, a participating laboratory must retain records of
test standard. Please see UL document 00-OP-C0033 Laboratory original observations and derived data as well as sufficient
Consumables for Client Labs and 00-OP-C0037 Thermocouple information to establish an audit trail for each data sheet
Wire Validation for Clients Labs at www.ul.com/dap > Resources package sent to UL.
> DAP Tools for more information.
If an error is made in recording data, it is to be neatly lined
out, the correct information recorded, the change initialed
Nonconforming tests or calibrations
and a reason provided for the change. Erasures, correction
(ISO/IEC 17025:2005 clause 4.9) tape or correction liquid are not acceptable. Please see UL
document 00-OP-C0025 Data Recording and Reporting for
A participating laboratory is to have procedures in place
Clients Labs at www.ul.com/dap > Resources > DAP Tools for
to stop, evaluate and, when appropriate, resume testing
more information.
when nonconforming test methods have been used. When
nonconforming testing takes place, remedial action shall Customers must maintain all records supporting testing,
be taken, as appropriate. Based on the severity of the including equipment calibration records, for 5 years after
nonconforming tests, corrective action procedures may also withdrawal of any product certification utilizing the test.
be required to prevent a recurrence. This also applies to test
equipment found to be out of tolerance prior to calibration.
UL shall be notified of any impact to test data accepted by UL.

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 Personnel qualifications Records maintained for each instrument and any automated
software are to include:
(ISO/IEC 17025:2005 clause 5.2)
• Full identification of equipment and records of its acquisition
Testing personnel are to have the education, training, technical
knowledge and experience to conduct tests. Testing personnel • Detailed history of damage, malfunction, modification,
must be familiar with and have an in-depth understanding of maintenance and repair
the requirements pertaining to a test being conducted. • Calibration certificates

• Records demonstrating that equipment complies with

Personnel must be sufficiently independent and specified tolerances

free from financial or other pressures that may • Current location of equipment
affect testing and reporting of results. • When appropriate, maintenance plan and all maintenance
carried out to date

• Current version of all software, regardless of source,

Accommodations and environmental conditions and validation records for any software developed and
(ISO/IEC 17025:2005 clause 5.3) maintained by the laboratory.

Test areas must have proper energy resources, lighting,

Measurement traceability
temperature control, humidity control and other environmental
conditions required to conduct tests. All participating laboratories (ISO/IEC 17025:2005 clause 5.6.2)

shall effectively monitor and control those factors that affect Measuring equipment must be calibrated to a nationally
testing. Please see UL documents 00-OP-C0035 Laboratory or internationally recognized standard of measurement
Ambient Conditions for Clients Labs and 00-OP-C0036 Laboratory or standard reference material. When traceability is not
Power Quality for Clients Labs at www.ul.com/dap > Resources > possible, other procedures must be used to assure traceability
DAP Tools for more information. in accordance with ISO/IEC 17025:2005 . The calibration
frequency shall be determined to assure required accuracy
Test equipment between calibrations. Generally, equipment shall be
(ISO/IEC 17025:2005 clause 5.5) calibrated at least annually. Any limitations of usage should
be clearly indicated.
A participating laboratory must be furnished with
test equipment sufficient to correctly perform tests in Note: Effective Jan. 1, 2009, test equipment calibration must be
accordance with the applicable test standard or procedure. conducted by an accredited calibration laboratory. Calibration
The equipment is to be at least as accurate as specified laboratories accredited by an ILAC, APLAC or EAC Mutual
or implied in the test standard, or procedure or meet UL’s Recognition Agreement Signatory such as A2LA, NIST/NVLAP,
minimum accuracy requirements as specified in UL document UKAS, SCC, NATA, JCSS, JAB, DKD, JNLA and IAS. Please see UL
00-OP-C0034 Equipment Accuracy Requirements for Clients document 00-OP-C0032 Calibration Certificate Analysis for
Labs at www.ul.com/dap > Resources > DAP Tools. Clients Labs at www.ul.com/dap > Resources > DAP Tools for
more information.
All equipment shall be in good working order and calibrated
appropriately. Each instrument shall bear a calibration sticker with For laboratories that conduct calibrations for their own
both the latest calibration date and the calibration due date. purposes, UL will assess traceability for compliance with
ISO/IEC 17025:2005. For details of UL’s requirements for

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 in-house calibration laboratories, please see UL document • Any chart paper, computer paper, printouts and similar
00-OP-C0038 In-House Calibration Requirements for Clients resources must include the same information as specified
Labs at www.ul.com/dap > Resources > DAP Tools for more above.
information. • Clear identification of which samples were used for testing.
When multiple samples are used for one test, data sheet
Handling of test items must clearly indicate result for each sample. When multiple
samples are used for a test program of one model or type,
(ISO/IEC 17025:2005 clause 5.8)
unique identifiers must be used to distinguish between
Samples are to be clearly identified and correlated to the test tested samples tested. These unique identifiers are to be
conducted and data obtained. In the case of multiple samples noted on the test datasheet.
of one model or type, unique identifiers must be used to • Rationale for not performing a test. The rational should be
distinguish between tested samples. provided as part of the datasheet package submittal or as a
cover to the completed datasheet package.
Reporting of results Complete details can be found in UL document 00-OP-C0025
(ISO/IEC 17025:2005 clause 5.10) Data Recording and Reporting for Clients Labs at www.ul.com/
dap > Resources > DAP Tools.
Participating laboratories are to record all observed data as
well as a description of the test method or reference to the test
method used, e.g., standard name, standard number, edition or
Test method validation
issue date, latest revision date, clause and test name. Data are Prior to participating in the Client Test Data Program, a testing
to be recorded in ink on form or standard laboratory data sheets. laboratory should have established a history of testing under the
Personnel at participating laboratories should use form UL data Witnessed Test Data Program. Each test covered by the Client
sheets when available. Test Data Program will be verified through direct assessment
of the facilities, equipment, and personnel. Demonstrating
Use of non-UL form data sheets will require further review proper testing methods includes items such as placement and
by UL to assure compliance with UL data recording procedures. securement of thermocouples, use of instrumentation, use of
UL may apply additional fees for review of non-UL datasheets. appropriate environments including placement of the product
Data sheets must be reviewed for content prior to use by the in test jigs as described in standards, knowledge of situations
laboratory. that may produce erroneous data, etc.

• All instruments used to record test data or environmental Annually each test method is to be validated through direct
conditions must be recorded and correlated to tests demonstration during the annual assessment. At any time, UL
performed
can require repeat of testing at UL test laboratories or through
• Customer identification, including location where tests the Witness Test Data Program at the participating client testing
were performed laboratory. Some specific categories may require repeat testing
• Signature of the laboratory signatory or participation in a proficiency test program.

• Sequentially numbered pages with the total number of

pages recorded on the first page Oversight and audit
Customer responsibilities
• Typed or printed name of staff member performing the
test on each data sheet where results are recorded. For test It is a customer’s responsibility to notify UL of any changes in
data collected electronically, only the typed name of the equipment, personnel, etc., material to the program that take
technician is required

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 place between annual reassessments. Based on the changes, UL Agreements
may decide to reassess the facility to reevaluate conformance
To formalize the relationship with UL, each participant must sign
with the program.
and return the Client Test Data and Total Certification Program
Each laboratory shall name at least one signatory. The laboratory Agreement that covers all of a participant’s test facilities for the
signatory shall sign to each data package submitted to UL Client Test Data Program. This agreement will need to be on file
attesting that only qualified staff have been assigned to conduct at UL by July 1, 2008.
tests, and that consumables, equipment, environment, and data
recording and reporting meet UL’s minimum requirements as Advertising and promotional activities
specified above and in the documents located at www.ul.com/ Please go to www.ul.com/dap > Downloads for the latest in
dap > Resources > DAP Tools. how you can promote your participation in the Client Test
Data Program.
Under the Client Test Data Program further subcontracting of
tests is not permitted. If a laboratory finds that they cannot
conduct a test, they should return the work to UL. UL will make
How to apply
appropriate arrangements for the testing. Customers interested in participating in the Client Test Data
Program should contact UL Data Acceptance Program Customer

Assessments Service team for further assistance.

UL conducts annual assessments to the requirements detailed

above. These assessments include validating test methods
covered by UL’s scope of recognition. Assessments and
participation in the Client Test Data Program are test- and
standard specific. Participation is scoped by specific tests for
specific standards. Customers not submitting test data under
the Client Test Data Program for more than one year will be
reassessed prior to further acceptance of test data.

Test data submitted

All test data will be thoroughly reviewed and conformance with
requirements determined by UL. Reviews include:

• Accuracy of sample(s) tested

• Accuracy of test method used

• Test results

• Test equipment used

• Data recording procedures

• Completeness of required testing

• Appropriateness of justification for tests not conducted

UL retains the right to countercheck test data at any time.

Submittal of data does not mandate UL acceptance. Data can be
counterchecked at UL or through the Witnessed Test
Data Program.

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