Aren't the old central office Part 15 exemptions going away? You can't grandfather new equipment. And Bellcore has its own too; with today's equipment, I suspect the 20 dB open-door limitation makes things difficult.
Cortland ====================== Original Message Follows ==================== >> Date: 06-Feb-97 06:34:05 MsgID: 1044-103166 ToID: 72146,373 From: >INTERNET:[email protected] >INTERNET:[email protected] Subj: Re[2]: OSHA-29 CFR 1910 Subpart S Chrg: $0.00 Imp: Norm Sens: Std Receipt: No Type: Text Sender: [email protected] Received: from ruebert.ieee.org (ruebert.ieee.org [199.172.136.3]) by dub-img-7.compuserve.com (8.6.10/5.950515) id JAA04459; Thu, 6 Feb 1997 09:26:54 -0500 Received: (from daemon@localhost) by ruebert.ieee.org (8.7.5/8.7.3) id IAA20410 for emc-pstc-list; Thu, 6 Feb 1997 08:25:37 -0500 (EST) From: [email protected] List-Post: [email protected] Date: Thu, 06 Feb 97 08:22:58 EST Encoding: 3212 Text Message-Id: <[email protected]> Cc: [email protected] Subject: Re[2]: OSHA-29 CFR 1910 Subpart S Sender: [email protected] Precedence: bulk Reply-To: [email protected] X-Resent-To: Multiple Recipients <[email protected]> X-Listname: emc-pstc X-List-Description: Product Safety Tech. Committee, EMC Society X-Info: Help requests to [email protected] X-Info: [Un]Subscribe requests to [email protected] X-Moderator-Address: [email protected] 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 %ate: 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. ************************************************************ ------------------------------------------------------------ The comments and opinions stated herein are mine alone, and do not reflect those of my employer. ------------------------------------------------------------ ************************************************************ ====================== End of Original Message =====================
