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same year.  Moreover, UL pays its employees out of revenues

it earns from providing valuable services for its customers,

whereas FDA staff are paid out of tax dollars that all con-

sumers are required to pay.

Manufacturers pay for UL's services.  UL charges a fee

based on a cost-of-testing approach then bills out its on-

site inspectors at a flat rate.  Consumers who do not bene-

fit from UL's services do not have to pay for them.  UL is

free from pressures to comply with special interests; it

must satisfy customers directly.  In other words, it is not

detached from the people who use its services as tax-sup-

ported government agencies are.

For their fees, clients get follow-up services that

include frequent, unannounced visits to their production

facilities worldwide.  In 1994, more than 481,000 on-site

follow-up-service visits were conducted for the benefit of

UL clients, the manufacturers and merchants who pay for UL's

services.20  During such visits, UL personnel check produc-

tion controls, observe on-site testing, conduct inspections,

and select samples for further testing at UL labs.  They

even check to see if the certification program is posted on

the wall.  If the facility does not pass inspection, the

manufacturer has two weeks to correct the mistakes.  After

that, UL pulls its certification.

Competition

UL can perform its tasks efficiently because of a sim-

ple, understandable reason.  Unlike the FDA, UL operates in

the private market, and it is not legally protected from

competition.  Competition in the market for high-quality

product safety information has the same effect that competi-

tion has in any market.  Goods and services produced in a

competitive market are produced efficiently, at the lowest

cost.  Though UL enjoys the widest name recognition in the

marketplace, its market is competitive, and UL has competi-

tors.  Among many others, these competitors include Elec-

tronics Testing Laboratories, a subsidiary of the British

conglomerate Inchcape; Factory Mutual of Norwood, Massachu-

setts; and Canadian Standards Association of Rockville,

Ontario.  Some competitors use UL standards as the basis of

their certification, but others write their own.  Some of

UL's competitors are for-profit organizations.  Others are

subsidiaries of other corporate entities.  Though UL uses

the term "friendly competition,"21 the competition is there.

If UL's standards are inappropriate, or if the

public loses confidence in the good name of UL, then there