Is non-islated mains LED lightbulb illegal?

[treez]

The following 13.5W LED bulb is mains connected but definitely non-isolated...........Is this illegal?

**broken link removed**

....At time 20:52 of the following, is the proof that its not isolated....
https://www.youtube.com/watch?v=YLlpoZaBx-g

..also, if you view from time 6:34 of the above video , you can see that the MCPCB that contains the (non-isolated) led circuit is literally lying right on the heatsink which opens out to the external of the bulb, where human hands definitely touch it....surely this is illegal?


The electric circuit used is as on page 15 of the following pdf ........

SSL2103 pwm controller from nxp
**broken link removed**

 

[FvM]

I don't understand the question? Why should the LED lamp be "isolated"?
It has to comply with applicable safety standards, I presume it does.

 

[treez]

I don't understand the question? Why should the LED lamp be "isolated"?

because its mains connected.

if you see in the video as discussed, you can see that when you touch the external heatsink, you are effectively about a few microns away from touching mains.


heres another bulb where you are literally a few microns away from mains live.......surely this has gotta be illegal?
https://www.youtube.com/watch?v=keaE7QTKTYE

 

[betwixt]

I have difficulty with streaming video because of my slow network connection but I managed to see most of the videos. The last one looks very dangerous to me and I would very much doubt it is legal to sell them in the EU when a live contact is exposed and can be touched, other regions may allow it. Incidentally, the resistor is almost certainly across the series capacitor, not in line with the power wire so it would be just as dangerous if the lamp was turned 180 degrees.

Brian.

 

[treez]

just as dangerous if the lamp was turned 180 degrees.

yes, I'm glad you brought this up...as it struck me too........he was sort of suggesting that mains neutral is safer than mains live...................oh no ...hold on.....you mean mains live is right at the pcb either way round?

 

[Mattylad]

If they are being sold in the UK and you think they are not conforming to our safety laws and can quote both the law and where they are not meeting it then contact trading standards about it.

The only thing the user can contact with is the finned heatsink body which is protected by the conformal coating (paint) on it, the rest are the internal bits and not normally user accessible.
This may be enough to pass the requirements - depends upon which country they are being sold in.

 

[treez]

Youre, right, it is whatever coating is on the heatsink, and of course, the heatsink is in direct metal-to-metal contact with the base of the led mcpcb, and the live mains is on top of that pcb, separated by a few microns of the insulator on top of the mcpcb.
If they can get away with this , then nobody would ever bother having proper mains isolation in a light bulb.
The bulb is sold in USA, but could presumably be shipped to UK.
I just emailed lightingsciences@ul.com but it came back address not found

 

[FvM]

O.K., I got your point. I was under the impression that the heatsink case is isolated from the metal base plate. In fact it can't be clearly seen from the video if it is.

In any case, air gap and creepage distances for 115 respectively 230 V, reinforced insulation must be observed.

P.S.: Reviewing the fact sheet, I see that the lamp is designed for 120VAC only, which slightly reduces the isolation distance requirements.

And it's said to be UL approved, means it must have passed respective safety inspections and tests.

The company seems to make only 120V LED lamps, so they are most likely not exported to the UK or other european countries.

 

[treez]

in the video at 6:34 you can see there is direct metal-to-metal connection between the base of the mcpcb abd the externally opening heatsink

 

[marce]

Take it up with UL (UL 1993)

A good quote worth taking a read off, as I worry about some of the comments when you have dangerous voltages all over your house (the mains) and the way some are reacting.

Electricity poses certain inherent dangers to human physiology, and few electrically-powered products or product standards can fully guard against all hazards while retaining the functionality desired by the market. Intentionally removing part of a required enclosure and continuing to use the product is an example of the type of hazard a standard typically cannot guard against, whether the product is a luminaire, a power tool, a cooking appliance, a computer, a television, or virtually anything else. The continued existence of medium-base screwshell lampholders, which allow direct access to hazardous voltage and current simply by removing the light bulb, is an example of how product safety standards still rely on sensible human behavior (and adult supervision) to protect people from themselves. Exposed cooktops (that can be very hot) and the blades of electric knives or reciprocating saws are examples of other types of hazards that rely on human behavior as the principal safeguard. We do not yet live in a perfectly safe world, but we are making strides to make it safer while keeping the door open for innovative new products, and functional legacy products, intended to improve overall quality of life.

So to put it succinctly, IF YOU CHANGE A LIGHTBULB WITH THE SWITCH ON YOU ARE A COMPLETE IDIOT.

**broken link removed**

 

[betwixt]

You are absolutely right Marce but in this case, an exposed connection directly to an unfused direct live connection is present on the front facing surface of the lamp. In a ceiling where it's out of reach there is no immediate danger but if one of these was placed in say a desk lamp and inadvertently touched directly or through a conductive medium, it could kill. The danger is made worse by some fittings using single pole in-line mains switches which could break the neutral line and leave a live wire exposed even when the lamp is turned off in the normal manner. These lamps should at least have a plastic window over the wiring.

Brian.

 

[marce]

These are US voltage lamps, one could possibly say from a dodgy source! Having worked on products were we got UL registration I do suspect they may not be up to the full standard.
They are covered by some of the international specs such as IEC standards.
Without all the available facts though, it is very hard to say whether these devices do comply to all the available legislation, what I do know is that even on a desk lamp you should not be able to touch any conductive parts.
Looking again at the second video, the part is a £3 bulb probably from an unknown source via ebay, it does have insulation, but again the only way to determine how safe it is would be a proper investigation. What I will say is that quite often you can get cheep products from ebay, posted direct to your door, this bypasses other regulations that are in place to protect us, if people purchase these sort of products that way to save a few quid then they should be aware that what they are buying may not be safe and they to are at risk of prosecution for fitting an unsafe/unregulated product, should something go wrong.
Ul are more stringent than CE and proper UL products have to be tested and are safe, bypassing the systems and importing your own cheep alternatives is putting yourself at risk for a few quid, so anyone thinking about it, think of the consequences, not only the threat of electrocution but also of fire.
With insulation you can actually be 0.4mm away from the mains...

 

[FvM]

Ul are more stringent than CE and proper UL products have to be tested and are safe, bypassing the systems and importing your own cheep alternatives is putting yourself at risk for a few quid, so anyone thinking about it, think of the consequences, not only the threat of electrocution but also of fire.
With insulation you can actually be 0.4mm away from the mains...

I have been supporting UL approval of instruments, and I won't say that UL is generally more stringent. According to US mains voltage level and typical wood building style, it puts more emphasis on overcurrent respectively fire protection but regarding exposed dangerous voltages, it's based on the same technical standards as CE declaration or VDE approval.

 

[marce]

Yes but to get a UL registered part or assembly they actually test the product, and will visit and assess you facilities, whereas CE you just plonk it on. Not that it stops people just putting the UL or CE logo on.
Don't know about general UL, but when we got UL registration they tested everything including the temp rise of the high current areas of the PCB.

 

[betwixt]

I'm not naming names but I have been to a UK based assembly plant where "made in the USA" and UL stickers were put on products which had never seen the States and were not destined to ship there. The same factory shipped a product which had "assembled by robots" on the packaging - it nearly caused a riot from the girls on the production line, they were the 'robots'.

Brian.

 

[marce]

I have seen assembled in the USA used, where everything was shipped to the USA and put in boxes there. This is legal and quite often the only way to get products into the USA market. I have also bought American products (made in the USA) with the contents of the packing box being made originally in China. Using the UL logo when not allowed is very dodgy and can get you in trouble same with CE marking if they are not up to spec.
Like all things in life people will bend break rules.
When I buy anything I always use the motto:
caveat emptor
And as I don't believe in anything for free or mankind's general altruism I tend not to buy these sort of electrical good from a certain online place, the quality I have seen is not up to the standard I want.

 

[123jack]

Just curious FvM - would you know if any random checking is done on self certified CE goods
or do they just wait for a problem to be reported?

I do find it interesting the number of people on the forum suddenly asking about transformers
for all manner of odd reasons.

 

[FvM]

If an authority has doubts about the CE conformity of a product, e.g. caused by competitors or customers complains, it would primarly check the manufacturers declaration. Secondly it would ask for documents substantiating the declaration like test reports.

Routine checks of product documents without suspicion might be performed for sensitive products, e.g. wireless equipment.

 

[yassin.kraouch]

If an authority has doubts about the CE conformity of a product, e.g. caused by competitors or customers complains, it would primarly check the manufacturers declaration. Secondly it would ask for documents substantiating the declaration like test reports.

Routine checks of product documents without suspicion might be performed for sensitive products, e.g. wireless equipment.

interesting information, i have one question about regulation : do europe have requirement on luminaire for a power below 25 W ?
because we have a lot of product in the market that have very low power factor,

 

[treez]

below 25w doesn't have to be pfc....not at all (in Europe).
However, led lightbulbs with significant capacitance following the mains diode bridge are damaged if connected to a triac dimmer (due to resonance of the emi filter inductances and the electrolytic cap.)...therefore, even low power led lightbulbs (eg 7w) are made fully power factor corrected as then they don't have much capacitance after the diode bridge.........

so, due to these triac dimmers (which , incidentally are only actually meant for use with incandescent), virtually all led lightbulbs are made with pfc, apart from the really really cheap ones.