The Unofficial Story and UL's Unpublished Standards

Missing from the official version of the adoption of UL 1482 are any details of what turns out to be the most critical step in the process: developing the "proposed" standard. Although the proposed standard was modified through UL's review and comment process, the changes were not significantly related to the safety implications of the standard. The most important provisions in UL 1482, at least from the point of view of safety, came from the original proposal and were not affected by the formal process that followed. The official story, then, picks up where the unofficial story ends—with the "proposed first edition" of UL 1482.

It is misleading to describe the standard circulated by UL in January 1978 as a "proposal." It was, in fact, both a proposal and a working (but unpublished) standard. UL had actually been certifying woodstoves for over twenty-five years when it circulated as a "proposal" the requirements it had been using. These provisions were contained in an unpublished UL standard (also referred to as a "desk standard"). Unpublished standards, the foundation of all UL standards, are not well known or understood. When the CPSC first began investigating woodstove safety, it operated for several months under the mistaken impression that there was no UL standard. In fact, there was an unpublished standard, just not a published one.

Unpublished standards and their method of development are one of the only blemishes on UL's otherwise excellent reputation. These standards are written entirely in-house by UL engineers and, true to their name, are not generally available to outsiders. Those who evaluate standards-writing by the extent to which the procedures are public and accessible are most critical of UL's unpublished standards.^[23] Leaving the merits of that debate aside until later, the fact is that unpublished standards are an integral part of UL and its standard for woodstoves. Relevant to the present discussion is how these standards take shape.