Hi Richard:


>                                         The manufacturer must keep these
>   available for the inspectors that appear each quarter.

To my knowledge, no third-party certifier has required
such records.

Most would like you to do so, and if you volunteered, 
they would be very happy and would not discourage you
from doing so.  But, such record-keeping is not a 
requirement.

You need only show, at the time of the inspection, that
you are using the correct parts.  You need not prove that
at times prior to the inspection you were using the 
correct parts.

This is parallel to hi-pot testing.  You need only show,
at the time of inspection, that you are hi-potting the
products.  You need not provide hi-pot test records from
the time of the last inspection.

The purpose of the unannounced, drop-in inspection is to
determine that, at that moment, you are building the 
product in accordance with the requirements.  The 
assumption is that if you are in accordance with the
requirements at the moment of the inspection, then you 
are also in accordance with the requirements at the other
times.  Supposedly, a successful inspection confirms your
process, and therefore all units built in accordance with
your process are also in accordance with the safety
requirements.

If you have any doubt of what I say, check your UL FUS
procedure and equivalents from the other certification
houses.  These documents spell out your obligations.
Any record-keeping beyond these is voluntary on your
part, and very likely may be the result of "jawboning"
on the part of your inspector.  (You remember "jawboning"
from the Nixon era: talk as if the requirement is a law
even though it is not.)  

Ask your inspector where such record-keeping is spelled 
out in the certification house rules.  I'll bet a beer to 
each of you who asks this question and gets, in response 
(and provides me with a copy), a written certification 
house policy requirement (applicable to all clients) to 
keep such plastic cert records!


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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