Hi Richard:
There are three kinds of "rules" that you need to know
and keep separate:
1) EU Directives.
2) Standards which satisfy the directives.
3) Test house "rules" for satisfying the standards.
Maintaining samples is in regard of (3).
(Also in this area is the test house interpretation of
the standard. For example, see the UL "guide" to UL
1950. This "guide" documents the UL policies and
interpretations of the various UL 1950 and IEC 950
requirements.)
The various test houses (whether or not they are "Notified
Bodies") have their own rules regarding samples.
With regard to samples, the objective of the test house
is to have a "reference standard" by which they (and you)
can judge whether any changes have been made between the
tested unit and the production unit.
There are three generally-accepted processes for the
"reference standard:"
A. Some test houses document the construction of the
submitted/tested sample (and then return the sample
to you). UL and CSA are among the test houses who
do this. The inspector compares a production unit
against the written description.
B. Others require you to maintain the sample. This is
in lieu of a document describing the construction. An
inspector will perodically visit your facility and ask
to see the sample. Then, he will inspect your
production, and compare with the sample.
C. Still others maintain the sample in their own facility.
Again, this is in lieu of a document describing the
construction. Usually, these test houses require you
to re-submit periodically. They compare the current
submittal with the original sample.
Any test house "rule" is readily negotiable.
As another subscriber has already commented, B and C are not
very desirable, especially if the unit is very expensive,
or if you certify many different units (cost of warehousing).
I suggest you simply tell your test house that maintaining
a sample is unacceptable. Ask them why they are requesting
this of you, and ask them for other means for accomplishing
their objective. They may accept photos or videotape.
Best regards from sunny San Diego,
Rich
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Richard Nute Quality Department
Hewlett-Packard Company Product Regulations Group
San Diego Division (SDD) Tel : +1 619 655 3329
16399 West Bernardo Drive FAX : +1 619 655 4979
San Diego, California 92127 e-mail: [email protected]
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