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 --------- 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). --------- 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). 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