Hello from clear and sunny San Diego:
George Alspaugh asks about field-replacement of parts bearing a certification mark. Supposedly, the certification mark can only be affixed in the factory. The problem with field replacement of certification marks is that the certification house has no control whether the product receiving the mark is truly eligible to bear the mark. Indeed, if a certification house should respond to this question, I would expect that they would say, officially, that the mark cannot be affixed in the field unless the sites where the mark is affixed are treated as factories. A similar question occurs when the mark is molded into a plastic part. Supposedly, the certification mark cannot be affixed to the product until the product is fully assembled and the production-line safety tests have been successfully completed. A molded-in mark cannot meet this test. But, we do mold marks into parts. Likewise, if you use a label, the certification house requires you to control those labels such that they cannot be inadvertantly affixed to a non-certified product. I remember a situation where some labels had found their way onto the factory floor. Mercy! The inspector was upset! For some kinds of things, and this is one, we just look the other way. There is no good answer. The certification house knows this. I believe they don't want us to ask the question. Do you really want an answer? Are you prepared to live with every possible answer? If the certification houses were really concerned about this issue, they would have published rules for this a long time ago. What's the best answer? Do what makes sense for your business! Best regards, Rich ------------------------------------------------------------- Richard Nute Quality Department Hewlett-Packard Company Product Regulations Group San Diego Division (SDD) Tel : 619 655 3329 16399 West Bernardo Drive FAX : 619 655 4979 San Diego, California 92127 e-mail: [email protected] -------------------------------------------------------------
