Hi Darrell:


>                                                           We must keep
>   certs of flammability on file for each shipment of every plastic part to
>   satisfy UL, CSA, and TUV factory inspectors.

I don't know where you got this notion.  None of these 
organizations have this requirement.

The requirement is that when an inspector performs an
inspection, you need only show him -- AT THAT TIME -- 
that the plastic parts you are currently using on the
production line meet the applicable flammability 
requirements.

There are a number of ways to show the inspector that
the parts meet the requirements.

1.  UL molders program.

    If your molders are in the UL molders program, then 
    they provide a cert with each shipment.  This cert 
    may apply to an individual carton, to a skid full of 
    cartons, etc.  Simply show the cert on the parts you
    are using at the time of inspection.

    Some funny stories:  As soon as our parts are unloaded
    from the truck, they are immediately upacked and the
    cert is discarded.  I had to take the inspector into
    the truck to look at the packages BEFORE they were
    unloaded.  It was DARK, and hard to see.  So, the guy
    with the lift truck brought it out for us so we could
    read the cert.

    Another example:  All of the boxes bearing the certs
    had been discarded into a compactor.  An HP employee 
    crawled into the compactor to retreive a carton bearing 
    the label.  We found the cert!

    A variation is to ask the molder to mold the cert 
    into the underside of the part.  Self-explanatory.

2.  Set up a "split inspection."

    Have the inspector go to the molders plant to examine
    the parts as they are being molded.

3.  UL sub-assembly program.

    UL has a new sub-assembly program that works like the
    plastics fabrictor program.  UL qualifies the sub-
    assembler to build according to your (or any other
    client) drawing.  UL sets up a generic inspection at
    the sub-assembler.  At your site, the UL inspector
    examines the sub-assembly drawings to make sure that
    the UL requirements are covered by the drawing.  See
    Kevin Ravo at UL Santa Clara for details.

My ground rule is that the cert houses don't tell us how
to run our business.  If we don't do it for ourselves or
our customers, we certainly won't do it for the cert house!
It doesn't make business sense to file certs, since its a 
job unrelated to a customer and is only meaningful to the 
certifier.  In doing so, you're working for the certifier!  
He's supposed to be working for you since you are PAYING 
HIM!

Yeah, I know how you get into this... I had an inspector
insist that we keep all the boxes until the next inspection
so he could see that ALL of the parts had the correct 
flammability.  Can you see a warehouse full of empty 
cartons???  Can you see me (or yourself) going to management 
to tell them that they had to keep the empty cartons for
three months???

If you check your contract and FUS documents, you'll find
that you need not file certs.  The cert houses love it,
and will encourage it.  But, it doesn't make business 
sense.  And, you need only do what your FUS says, since 
that is a part of your contract.


Best regards,
Rich



-------------------------------------------------------------
 Richard Nute                      Product Safety Engineer
 Hewlett-Packard Company           Product Regulations Group 
 AiO 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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