Hi Doug:
> 1) "Designed to meet (safety standards list) ... "
>
> ___ highly acceptable
> ___ acceptable
> ___ no opinion
> ___ unacceptable
> comments:________
In my experience, this represents wishful thinking on the
part of the party making the statement. Too too many
vendors have made this statement that, for me, there is
no validity whatsoever even when used by reputable
organizations.
> 2) "Designed to meet (safety standards list) and tested by (self) ... "
>
> ___ highly acceptable
> ___ acceptable
> ___ no opinion
> ___ unacceptable
> comments:________
First, the phrase "designed to meet..." implies no testing
or other proof of conformance. To me, it means, "read the
standard, look at the design, and decide that it complies."
The addition of the testing statement doesn't help -- UNLESS
it is accompanied by a test report. Many of the tests can
be "dry-lab'd." And, many of the tests can be done in a
short-cut manner so as to invalidate the results.
> 3) "Designed to meet (safety standards list) and tested by (third party)
> ...
> "
>
> ___ highly acceptable
> ___ acceptable
> ___ no opinion
> ___ unacceptable
> comments:________
Same problem. I can't get by the "Designed to meet..."
statement.
If I can read the test report, regardless whether first party
or third party, I feel a lot better about whether or not it
complies. In many cases, the test report itself can exude
confidence in its presentation. If not, then careful reading
of the test report should provide enough info so that you can
decide whether or not it meets the requirements.
Indeed, isn't this the point of your questionnaire? What does
it take for you (or me) to decide that the product indeed meets
or complies with the standard?
> 4) "Complies with (safety standards list) and tested by (self) ... "
>
> ___ highly acceptable
> ___ acceptable
> ___ no opinion
> ___ unacceptable
> comments:________
The phrase "complies with" is a bit more assertive and positive
than "designed to." It may be that this signifies a promise on
the part of the vendor that he truly complies, to the best of his
ability.
"Tested by" is only meaningful when the test report is made
available to me. If it is not provided to me, then as far as I
am concerned, it doesn't exist.
> 5) "Complies with (safety standards list) and tested by (third party) ... "
>
> ___ highly acceptable
> ___ acceptable
> ___ no opinion
> ___ unacceptable
> comments:________
Why would an organization go to the expense of third-party
testing without some sort of third-party statement as to
compliance? I do tend to trust third party statements as
to compliance WITHOUT the need for a "tested by" statement.
But, a "complies with" statement by the vendor together with
"tested by" a third party is not particularly meaningful.
You can get almost any third party to test what you want
tested, which may not necessarily encompass all the applicable
tests. So, once again, having the test report is the real
proof.
------
To me, the only believable statement of compliance is the one
required by the EU, namely:
ISO/IEC Guide 22 (1982) Information on manufacturer's
declaration of conformity with standards or other
technical specifications.
ISO/CASCO 261 (Rev.2) January 1996 Draft - General Criteria
for Supplier's Declaration of Conformity. This document
will be issued as an ISO Standard and replace ISO/IEC Guide
22.
CEN EN 45014:1989 General criteria for supplier's declaration
of conformity.
This last one has the force of law behind it. It can be done in
any of the 5 schemes you have described (including without a test
report!). But, because it has the force of law behind it, for
the most part it is believable (except, maybe, for organizations
who don't understand its impact under the law and haven't been
caught yet!).
So, its not just the words. Its the use of a particular form
which must be truthful under penalty of law.
Anything else is the vendor's claim, which is no better than his
reputation. And, even those claims may not live up to his
reputation because, while he may be expert in the technical
aspects of his product, he may not be expert in safety or EMC.
The EU places regulatory responsibility squarely on the shoulders
of the vendor, where it should be. It doesn't rely on third-
parties, although these can be used to back the vendor's claim.
The EU expects vendors to be fully knowledgable of both the
legal and technical requirements of compliance. In the EU, the
vendor is responsible for both the performance and the
consequences of the performance of the product in the marketplace.
Compare the EU to other parts of the world which rely on third
parties or on government test houses. The vendor need not be
responsible or knowledgable except to get his product past the
test house. Then, by definition, it is an acceptable product
regardless of its performance or the consequences of its
performance in the marketplace.
Best regards,
Rich
-------------------------------------------------------------
Richard Nute Product Safety Engineer
Hewlett-Packard Company Product Regulations Group
All-In-One Division 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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