UL-291-BULLETINS-2004.pdf
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1、Subject 291 TO: SUBJECT: 1655 Scott Blvd. Santa Clara, CA 95050 November 3, 2004 Standards Technical Panel (STP) for Physical Security Devices, STP 687 Subscribers to ULs Standards Service for Public Review Participants Automated Teller Systems Comments received on, and substantive changes to, the A
2、NSI Ballot of the Fifth Edition of the Standard for Automated Teller Systems, UL 291; SUMMARY OF TOPICS This bulletin Circulates the comments received with the negative ballots in response to the UL 291 proposal bulletin dated June 30, 2004. In addition, UL is withdrawing the proposals under Topic 4
3、 of the June 30, 2004 bulletin. COMMENTS DUE: December 3,2004 ULs June 30, 2004 proposal bulletin contained the following proposal topics: 1) Certification Issues; 2) Grounded Conductor Insulation Color; 3) Editorial Changes; and 4) Level 1 Security Container Alternate Material Requirements. Balloti
4、ng was concluded on July 30, 2004. Out of 41 vote-eligible STP members, 24 ballots were returned. The initial ballot count is 14 yes, 8 no, and 2 abstain. While the majority condition* was met, the two-thirds condition* was not satisfied. Therefore, consensus was not achieved. (* Majority condition:
5、 a majority of the vote-eligible STP members must return a ballot; Two-thirds condition: two-thirds of the returned votes, minus abstentions and ”negatives-without-comments”, must be affirmative.) Based on the comments received related to the proposals under Topic 4, UL is withdrawing these proposal
6、s. A Working Group will be formed to rework these proposals. The reworked proposals will be balloted at a later date. Individuals interested in serving on the Working Group should contact the STP Chair, Mr. Dan Ryan at Daniel.P.R, no later than December 3, 2005. The attached matrix contains all of t
7、he comments that were received in response to Topic 4 of the June 30, 2004 bulletin. Aside from indicating general agreement with the proposals under Topics 1 - 3, no other comments were received regarding Topics 1, 2 or 3. Request for comments If you wish to change your vote in light of the attache
8、d comments or ULs resolution (withdrawal of Topic 4 proposals), please respond to us in writing by December 3, 2004. If we do not hear from you by this date, your original vote will stand. Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7
9、838506130, User=abc, abcdd Not for Resale, 09/10/2006 02:32:47 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 291 -2- NOVEMBER 3,2004 Please note that no ballot form is attached. If you wish to change your vote, please submit your vote by regular mail, fax, or e-ma
10、il to the attention of Sue Contreras at ULs Santa Clara office, 1655 Scott Blvd., Santa Clara, CA, 95050. After review and consideration of any vote changes, if it is determined that consensus is achieved, regarding the ANSI approval of the standard and proposed revisions to UL 291 (as discussed und
11、er Topics 1 - 3 of the June 30, 2004 bulletin), and the STP concurs with the actions/dispositions, UL plans to adopt the revised version of UL 291 as an ANSI standard - without the revisions proposed under Topic 4. The effective dates will be the same as stated in the June 30, 2004 proposal bulletin
12、 (.e., all revisions will become effective upon publication). Anyone who submits an objection has the right to appeal this action on a procedural basis through ULs Appeals Process. If you wish to appeal, please respond by December 3, 2004. Please note only appeals based on procedural issues will be
13、heard, technical issues should be resolved at the consensus body level. Guidelines on how to register an appeal can be obtained at http:/ ulstandardsinfonet.uI.com/stp/appeals.html or by contacting the STP Project Manager. UL appreciates the time and effort you have put forth to review this standard
14、, and looks forward to your continued participation in this UL/ANSI standard activity. UNDERWRITERS LABORATORIES INC. REVIEWED BY: SUE CONTRERAS STP 687 Project Manager Standards Department SANTA CLARA OFFICE Fax: (408) 556-6247 E-mail: Sue.B.Contrerasus.UL.com http:/ Ph: (408) 876-2484 DAN RYAN STP
15、 687 Chair Corporate Standards RTP OFFICE Fax: (919) 547-6399 E-mail : Daniel. P. Rya nus . U L.com Ph: (919) 549-1658 Copyright O 2004 Underwriters Laboratories Inc. Copyright Underwriters Laboratories Inc. Provided by IHS under license with ULLicensee=Army Northwestern Div./7838506130, User=abc, a
16、bcdd Not for Resale, 09/10/2006 02:32:47 MDTNo reproduction or networking permitted without license from IHS -,-,- SUBJECT 291 -Al- NOVEMBER 3,2004 APPENDIX A COMMENT MATRIX The table below provides the comments received from the Ballot of BSWUL 291, proposal bulletin dated June 30, 2004. The Standa
17、rd for Automated Teller Systems The rows in the comment resolution matrix are defined as follows: Comment Submitter Name and affiliation of the person who submitted the comment. Comment The verbatim text of the comment. Comments Received Except those noting general agreement with Topics 1 - 3, all o
18、ther comments received were in response to the rationale of and proposals covered under Topic 4, Level 1 Security Container Alternate Material Requirements, in general, as discussed in the June 30, 2004 proposal bulletin. This Topic proposed revisions to paragraphs 13.2.1 - 13.2.5, 13.3.2; and propo
19、sed new Section 35.6 consisting of paragraphs 35.6.1 and 35.6.2. Topic (1 2omment Submitter 2omment 1. ProDosal Rationale - first DaraaraDh The majority of safes for ATM use are designed specifically for a particular application. The rationale that applies to UL 687 safes does not necessarily apply
20、to UL 291 Security Containers. The applications are so different that separate requirements for the two standards can be justified. 2. ProDosa I Rationale - second DaraaraDh The incorporation of %“/100,000 psi steel into the Standard, as an alternative to 1“/50,000 psi steel, reflects the current st
21、ate of the market, and it is logical to include this material in UL 291. This is acceptable. 3. ProDosal Rationale -third and fourth DaraaraDhs The application of an eight (8) minute equivalency test in UL 291 to constructions other than 1“/50,000 psi and %“/I 00,000 psi steels cannot be supported.
22、With the grinding disc allowed in the TL30 tool list, as used by UL, a 6sq.in aperture can be created in %“/100,000 steel in no more than three (3) minutes. Tests using free-hand grinding machines as used in testing to European Standard ENI 143-1 have produced times of less than two (2) minutes. An
23、eight minute equivalency test, using TL30 tools, discriminates unfairly in the market against alternative constructions, many of which have shown significantly more resistance to grinding disc attacks than the steel plate constructions accepted by UL 291. Disc grinding is currently the fastest- grow
24、ing form of physical attack on ATM safes in Europe. The changes proposed are in conflict with the requirement in par 32.3 of UL 291, which specifies that I. . . successful attack shall consist of the removal of 10% of the currency indicators in the product within the specified time. . . “ Will this
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