Now, I am going to have to ask representatives of the agencies that are on
this mailing list to address these two issues.
Assuming the parts have not been inspected elsewhere, my experience has been
that when the inspector picks up a molded part, he must find the molder's
approved mark; or, if none, I must provide a C of C that covers that lot. I
agree that he will not ask to see C of Cs from earlier lots. Failing having
the mark or a C of C, there is no other way to "prove" compliance, and the
inspector will issue a variation notice.
As to the hipot, there have been occasions where I had to prove to the
inspector that I had the pass/fail records. Are they required? Good
question.
----------
From: Rich Nute [SMTP:[email protected]]
Sent: Thursday, November 19, 1998 12:19 PM
To: [email protected]
Cc: [email protected]
Subject: Re: Plastics Cert Documentation
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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