Hi Martin:
There are three issues in your message:
1) compliance to the standard;
2) reasonableness or appropriateness of the standard;
3) value added to the product through compliance.
You point out that messages posted to this list address
compliance to the standard, but not the other two issues.
I believe the nature of the issues is such that we can
effectively address compliance issues and resolve them
but not the other two.
The content of standards is addressed by a committee.
Discussion of the value of the limits and of other
content of a standard is only effective insofar as
members of this listserver are also members of the
committee. We have a few committee members as
subscribers, but not all committee members are
subscribers. So, a broad discussion of standards
contents cannot be brought to a conclusion through the
subscribers to this listserver.
I have often commented on contents of safety standards,
but such comments are not effective in changing the
standards; to change a standard I must make a very
specific input to the committee or to a member of a
committee who agrees that the issue should be addressed
by the committee.
For political reasons, committee members are reluctant
to share their views in a public forum such as this.
The view may be mistaken as an "official" interpretation
or position of the committee.
"Official" outputs of standards committees are the
minutes and the draft standards produced by the
committees. For comments on those standards to be
considered, the comments on those outputs must be
through the "official" channels for such comments, not
in a public forum such as this listserver.
So, discussion of the appropriateness of the standard or
its contents is largely ineffective in this forum. Its
not that we don't have concerns regarding the contents
and appropriateness of standards, its that this is not
an effective place for such discussions.
The same comments can be said for the value added to a
product by virtue of compliance to the standard. We
all have doubts as to some or all of the requirements
being of value. But, expression of those doubts here
will not be effective in implementing any change.
Of course, the regulatory engineer's place is to
question the appropriateness of a standard and its
contents. And we do so. Some of us sit on the
committees that draft and change the standards. But,
we can't all sit on the committees; the committees
would be huge and unwieldly.
Whether or not safety and EMC standards make this
world a better place is an interesting question. I
think the EMC standards are effective in doing this.
Emission and susceptibility limits establish
compatiblity that normal equipment operation is
assured. I'm not sure safety standards are effective
because we don't have a solid engineering basis for
the safety standards. Instead, safety standards are
based on inversion of bad experiences. This is not
a good, systematic approach for predicting injury
and providing safeguards -- which is what we SHOULD
be doing in product safety.
Best regards,
Rich
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