Rich, et al; there is a fourth option and that is the one the originator was
referencing. When not following one of the three programs that Rich noted;
the inspectors require Certificates of Conformity from the molder for each
lot. The document must list the molder's name, the material used and the
flame rating and be signed and dated. The manufacturer must keep these
available for the inspectors that appear each quarter.
----------
From: Rich Nute [SMTP:[email protected]]
Sent: Wednesday, November 18, 1998 7:19 PM
To: [email protected]
Cc: [email protected]
Subject: Re: Plastics Cert Documentation
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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