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relationship to Congress leads the FDA to concentrate on
approving only those devices that are extremely likely to be
safe. The consequence is that many safe and effective
devices never reach consumers. UL is a private organization
that receives no tax revenue. Its clients, mostly manufac-
turers, wholly support it. It has no legally created monop-
oly over market access; it cannot deny consumers choice; it
has no incentive to minimize the chance of a Type I error at
the expense of Type II errors. UL's market-created incen-
tives are to test products appropriately, minimizing the
probability of both Type I and Type II errors.
Underwriters Laboratories
William Henry Merrill, a fire safety inspector from
Boston, founded UL in 1894 as an independent, not-for-profit
organization. It provides certifications of safety for
thousands of products and writes standards for manufacturing
and performance for hundreds of others. It has been so
successful and its market acceptance so complete that con-
sumers scarcely ask themselves if many of the products they
buy are safe. They make the rational assumption that they
will be because UL and similar organizations certify them.
UL's stated, explicit mission is "Testing in the Public
Interest." As Inspector Merrill said in 1923, "We are doing
something for manufacturers, buyers, users, and property
owners everywhere. We are doing something for humanity."16
· UL certifies more than 14,000 different types of
products.
· Every year, UL issues over six billion individual UL
marks, the "trademark" symbol affixed to certified
items which are UL listed.
· UL has more than 40,000 clients, including manufac-
turers, retailers, insurers, code officials, archi-
tects, and government agencies.
· Among many other products, UL tests and certifies
electrical and medical appliances and equipment, auto-
motive and mechanical products, fire-resistant and
other "code" materials, bullet-resistant glass, Occupa-
tional Safety and Health Administration (OSHA)-desig-
nated "hazardous location" products, alarm systems, and
chemicals.
· UL writes and maintains 696 different end-use product