Dear all,

we have been advised by our CB ( and  acredidation requires you ) to update key
documents when changes occur: I read the D of C to be such a document.

Derek Walton

John Allen wrote:

> Hi Folks
>
> I disagree strongly with Scott's assessment that the DoC has to be resigned
> for several very important and pragmatic reasons:
>
> a) To-date I have yet to see any official EU or other substantive document
> to support his viewpoint.
>
> b) People are always "coming and going" - it is a fact of business life,
> and new personnel inherit the legal responsibilities of the old.
> (That said, the "old" personnel could still be prosecuted for knowingly
> breaking the law if they had falsely signed a DoC).
>
> c) If Scott's viewpoint were widely held we would all be continuously
> updating and reissuing our DoC's. In fact we would have little time for
> anything else - like developing new products!
>
> d) The date of the signature then becomes critical - and could force a
> complete review of the product against the latest versions of the
> appropriate referenced standard(s).
>
> The problem comes if those standards have themselves been updated since the
> date of the first signature - in which case a product might have to be
> modified merely because the person signing the original DoC had left the
> company!
>
> The latter proposition is plainly ludicrous and not envisaged in the
> Directives or in the harmonised standards, which allow you to continue
> manufacturing an unaltered compliant product for some considerable number
> of years after the last date you are allowed to certify to a particular
> issue level of a standard.
>
> e) The only realistic and supportable reasons for updating the DoC are thus
> that :
> (i) The product itself changes;
> (ii) The standard(s) change, and you are going to continue manufacturing
> beyond last date at which it is permissable to to manufacture and certify
> to the particular issue level of the standard(s);
> (iii) The company and/or model names/number change.
>
> The above opinion is my own, but I can see no reason why we - or any other
> company - should take any different view.
>
> Regards
>
> John Allen
> Product & System Safety Manager
> Racal Defence Electronics Ltd
> Bracknell
> UK
>
> ----------
> From:   Scott Douglas[SMTP:[email protected]]
> Sent:   11 November 1999 13:39
> To:     [email protected]; [email protected]
> Subject:        RE: D of C - Who Signs?
>
> The DoC must be re-signed.
>
> Scott
> [email protected]
> ECRM Incorporated
> Tewksbury, MA  USA
>
> -----Original Message-----
> From: [email protected] [mailto:[email protected]]
> Sent: Thursday, November 11, 1999 10:16 AM
> To: [email protected]
> Subject: D of C - Who Signs?
> Importance: Low
>
>      Hello!
>
>      Forgive me for asking a possibly dumb question but here goes:
>
>      If the EU Declaration of Conformity is signed by a
>      responsible/technically competent person who has been nominated on
>      behalf of the company's Directors and then that person leaves the
>      company,  does his/her replacement who assumes the same level of
>      responsibility need to go back and re-issue all of the old D of C's
>      with their signature on the document.
>
>      In other words is it acceptable to issue D of C's to
>      suppliers/customers which have been signed by someone who has left
> the
>      company.
>
>      Thankyou in advance.
>
>      Tony Reynolds
>      Pitney Bowes (UK) Ltd
>      Tel +44 (0) 1279 449479
>      Fax +44 (0) 1279 449118
>      e-mail: [email protected]
>
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