Hi folks Brian raises an interesting issue - but I would be grateful if he or someone else can identify the EU legislation to which he refers.
His comments are particularly to companies like ours who supply mainly to a military market which almost "demands" to do its own servicing because it locates and uses the equipment in places where normal manufacturer's service cover is unavailable (certainly we don't have a service department in Bosnia or Kosovo!!). However, the customers' requirements' of this nature are stated in contract and typically includes full maintenance and repair training and documentation. I think our situation digresses from the issue raised, but it does have a bearing on my comments, notably that each case should be considered on its merits, Notably, the following appear to be relevant: a) The specific items of EU legislation which apply to the product. b) The type of product and the safety/EMC/telecomms standards to which it has been assessed will be relevant. c) The level of servicing which will/could be required. d) The typical target customer market, as it will affect the level of skill required to correctly maintain/repair the product'. e) The availability to the customer of the maintenance and repair instructions, the depth of detail included, and the warnings/cautions provided on what must - and must not be - done, including any tests to be applied at the end of repair/maintenance. f) The availability and assembly level of the correct routine spares, and of replacement or re-conditioned exchange units. Frankly - whilst I fully sympathise with Brian's viewpoint - I think it is very difficult to make a blanket statement that "Mr Customer, thou shalt not service/repair this equipment", particularly in respect of routine maintenance functions, e.g. changing filters, topping up fluids, cleaning, etc. Many of us do these tasks on our own cars - and would object violently to having to go back to the manufacturer (not an agent, according to Brian) to get these tasks done at the cost of a lot of time and money. However, when it get to more complex functions, then the definition of what can/cannot be done is more difficult. Nevertheless, that is what you should do in detail, and you should then clearly specify: - The maintenance documentation (by reference number etc.) in the operating instructions. - Which tasks can/cannot be done, how often, and what the required skill levels are. - All the Warnings and Cautions for the safety of both the repairer and the user, and to prevent the equipment going out of compliance with the safety/emc/etc., standards to which it was designed and manufactured. - Which spares shall be used. - What checks and tests must be performed at the end of the tasks. - What records should be kept of the maintenance and repairs performed (what, when, by whom). If you - the manufacturer - do the above, then I can see no real reason for not permitting professional customers to service their equipment. However, finally, I do accept that if you supply equipment intended for use by the general public - particularly in their own homes - you may have to clearly specify on both the equipment and in the operating instructions that no-user servicing is permitted. You might even have to make access inside the equipment very difficult by sealing the construction or by using special security fixings that cannot be opened with "normal" handtools. Regards & Happy Xmas John Allen Racal Defence Electronics Ltd ---------- From: Brian Harlowe[SMTP:[email protected]] Sent: 21 December 1999 17:04 To: [email protected] Subject: Servicing and repairs Traditionally my company has encouraged it's users to carry out a limited amount of servicing and repair on our Electronic units. Under the EU Safety legislation I know this is now a No No. I am a little bit of a lone voice crying in the wilderness as far as our management is concerned. Can any one out there quote me any instances or cases that I can use to drive home the point with our management A happy Christmas to you fellow compliance people and if we survive the Y2K business. Good luck in the new century and may this newsgroup continue to prosper Best Regards Brian Harlowe * opinions expressed here are personal and in no way reflect the position of VG Scientific --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], [email protected], or [email protected] (the list administrators). --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], [email protected], or [email protected] (the list administrators).
