Tony's comments are well made. Although the principle of CE Marking is clear,
some companies take advantage of the low probability of being caught. The real
safety (and EMC) hazards are not caused so much by companies relying on outside
certification as by others (especially importers into the EU) taking no measures
at all but still applying a CE mark. A report in "Which?" consumer magazine (Oct
98 - subscribers only - see:
http://sub.which.net/publicinterest/reports/oct1998pu12t15/02state.html)
found many unsafe household items bearing the CE mark.
In the UK, PC assemblers have been fined for failing to comply with the EMC
regulations, but as far as I know (and speaking as someone who signs DoCs!)
no-one has been jailed for CE Mark related offences.
Roger
"Nikolassy, Anton" <[email protected]> on 28/11/99 02:57:16
Please respond to "Nikolassy, Anton" <[email protected]>
To: "'Ing. Gert Gremmen'" <[email protected]>, Rich Nute <[email protected]>
cc: Emc-Pstc <[email protected]> (bcc: Roger Viles/PLY/Global)
Subject: RE: UL in Washington Post
I also agree with Rich that independent accredited test organizations only
verify conformance to standards. A few of those standards are performance
based, but most are not. Even in Europe.
If I remember correctly, the object of the CE marking system was take down
trade barriers. Unfortunately, it has been determined that a significant
percentage of all CE marked product sold in the EU does not comply with the
relevant Directives. Although I believe that most manufacturers honestly
think their product complies, it takes an independent verification to
maintain objectivity.
So far, most of the opposition manufacturers have encountered has come from
customs inspectors and their customers or competition. Very little policing
has been of a technical surveillance nature. The resources are just not
available. Of course, this varies from country to country.
I wonder if anyone actually knows someone who went to jail for failure to
comply with a safety directive. I'd be interested in the quantity of
inmates being housed in the jails of Europe for this issue.
As a final note, our tort system does provide for responsibility to
negligence and recourse for those harmed.
Tony
Anton (Tony) J. Nikolassy
Factory Mutual Research.
1151 Boston-Providence Tpk.
Norwood, MA. 02062 U.S.A.
Phone: 781-255-4819
FAX: 781-762-9375
e-mail: [email protected]
-----Original Message-----
From: Ing. Gert Gremmen [mailto:[email protected]]
Sent: Friday, November 26, 1999 9:34 AM
To: Rich Nute
Cc: Emc-Pstc
Subject: RE: UL in Washington Post
Very well stated Rich,
(see below)
It puts the finger on the real problem with what i call
"testimonial certification" . It's the process were
manufacturers
stop thinking about safety as soon as the UL (or other
respected
test house) has allowed to use their safety mark.
The test house however is hired to perform the certification
process
test according to applicable standards which as result of
international standardization process must cover a very wide
range
of products in one manuscript.
Therefore i want to draw your attention again to the
European system
of Safety Directives, specifying safety in terms of generic
safety
requirements (so-called essential requirements) and make the
manufacturer sign for it's liability using the DoC.
The safety of the product has to be proved to the
manufacturer
in such a way that he can feel confidant about it's
declaration.
Therefore he will need to actively seek an suitable standard
or
any other test suite that covers his liability, and this
change of what manufacturers ask a test house stimulate test
houses
to research beyond the strict letter of the standard.
The process shown in the ce marking system has the best of
two worlds:
- direct liability of the manufacturer by signing DoC
- usage of international standards not to prove but give
assumption of
safety only (this requires the manufacturer to go beyond
standards if he can
suspect additional dangers such as food stucking into
toasters)
- self certification to reduce the costs of the approval
process.
That this process is more stringent then UL VDE or KEMA
SEMCO etc testing is
shown by f.a. filter manufacturers grouping together in
searching to exclude
their components from electrical safety ce marking, and
preferring the
route to hire many international test houses (including
annual payments)
above the free process of self certification but with
inceased liability.
Regards,
Gert Gremmen Ing.
== Ce-test, Qualified testing ==
Consultants in EMC, Electrical safety and Telecommunication
Compliance tests for European standards and ce-marking
Member of NEC/IEC voting committee for EMC.
Our Web presence: http://www.cetest.nl
List of current harmonized standards
http://www.cetest.nl/emc-harm.htm
-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of
Rich Nute
Sent: woensdag 24 november 1999 20:43
To: [email protected]
Cc: [email protected]
Subject: Re: UL in Washington Post
Hello from San Diego:
Many thanks to Sean for posting the URL for the
Washington Post article on UL.
While I am notorious as a "UL-basher," I think
the focus of this article is misplaced.
This article presumes that UL puts the safety
into products. Unfortunately, many manufacturers
also believe that UL puts the safety into their
products.
Manufacturers, not UL, are responsible for the
safety of their products.
UL is a certifier. UL certifies that the product
complies with the requirements published in a
standard.
Best regards, and for my USA colleagues, west wishes
for the Thanksgiving Holiday,
Rich
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