Rules are rules.  Because we let NVLAP into the situation we now have a more 
ridged and rigorous certification system in the US than in Europe for some 
applications.  If we are not careful how we implement the rules it will only 
get worse.  There are many people in the government who have not "been there 
and done that" who want to design a system by which we all must live. 
 Uncertainty is one of the issues.

Michael Barge is on the ball and he has a good perspective.  As I understand 
it most of you are applying Uncertainty too broadly.  The rules should be 
applied only as they pertain to the certification requirements.  For 
example, Europe has one application and the USA another.  For minimum impact 
they should not be mixed.

In the USA uncertainty only applies to calibration of test instruments and 
then only if you wish to become a NVLAP approved test lab.   If we easily 
accept it for the entire EMC test protocol, NVLAP will gladly apply it to 
the entire certification  procedure.  Before we go off and rant an rave over 
this net, we should read the rules, understand what they say and know what 
the limitations are.  Please read NIST Technical Note 1297 and note its 
applicability.

It seems only the test labs are preaching accreditation, certification and 
Uncertainty while most of the producing companies just quietly integrate the 
testing into the quality process and leave it at that.  I have news for the 
test labs.  Trying to create a closed association with licensing and other 
impedances to block competition only raises the price of service.  It does 
not improve quality of service and the competition will not be reduced.  Why 
make it hard on yourselves?

Dave George
Unisys Regulatory Compliance

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