Keep in mind that the Phone Company has long been exempt from many regulations.
This includes FCC Part 15 as well as the OSHA. The Phone Companies themselves
require that all equipment to be used in the CO or customer Premise be listed
with a NRTL. On the EMC side they require a wider range of emissions tests as
well as several immunity tests. These regulations are found in GR-1089 and
GR-63. It seems that back in the MA Bell days they were able to convince the
Agencies that the Phone Company was better left self regulated.
Tom Whissel
Senior Compliance Engineer
Cabletron Systems, Inc.
______________________________ Reply Separator _________________________________
Subject: Re: OSHA-29 CFR 1910 Subpart S
Author: [email protected] (Doug McKean) at !INTERNET
List-Post: [email protected]
Date: 2/5/97 6:01 PM
Eric Petitpierre wrote:
> Doug,
> Please elaborate regarding your statement "I eventually won in the
> end, but it was not easy. "
> I've run across this OSHA loophole as well and I am curious to find
> out what made it go your way.
> Was the telco equipment Customer Premise as well as CO?
No customer premise for this scene. Only CO.
I had to use several different things. Now, in the past,
scare tactics, i.e. 'liability', tended to put me into the
role of company 'cop'. Something of a no-win situation.
And a role I'm convinced neither side appreciates.
So, if I can remember well enough, the whole trick was to
keep cool and just speak matter of fact.
First - I just went ahead with a cost estimate that included
the 48vdc model in with the AC model without asking anyone.
Second - when this was discovered and I was challenged, I
just said something to the effect that we get a break in
price for doing the same model with two different power
supplies at the same time, etc, ... which was true due
to the fact that I had the quote from the lab itemize
both models tested 'seperately' [two seperate times for
testing with two seperate reports] as well as 'combined'
[one test one report].
Third - when this was challenged by the above, then that's
when I asked something like, "can I get back to you on
that?" What I really did was write out a memo stating that
although this particular part of the standard does indeed
address certain types of exempt equipment, OSHA in general
concentrates on workplace safety and end user safety and is
ultimately decided by an OSHA inspector to the tune of
$10,000 for each non-compliant product. If anything were
to happen, I could not vouch for safety even in a case of
similarity of design. I attached the quote to the memo,
made it "TO:" the idiot, and "CC:" to his boss and made sure his boss
got it first.
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The comments and opinions stated herein are mine alone,
and do not reflect those of my employer.
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