>   On the aspect of the "where to put Product Safety/Compliance in the 
>   organization" discussion bears mentioning on the forum. In general I 
>   advocate that the Product Safety/Compliance department be separate from 
>   Engineering, Sales, and Operations. The Safety/Compliance group should 
>   avoid conflicts of interest (real or apparent) that may arise in the 
>   above mentioned groups. Even the occasional appearance of a conflicting 
>   interest can undermine the credibility of the Safety/Compliance team.


Over the years, I've been a member of various organizations,
but always doing the same function (job).  Regardless of 
organization, I did the same job.

I've found that my effectiveness in doing the job is much
better when I have been physically close to the R&D teams.

Likewise, I've found that my effectiveness in doing the job 
is much better when I have been a part of the same 
organization as R&D.

I've always taken the approach that safety is designed into 
the product from the very start of the project.  Safety is 
an engineering discipline that, unfortunately, is not a 
part of engineering school curricula.  So, it must be 
learned on the job, and I am the teacher.  The R&D engineer 
is responsible for designing the safety of the product; I 
am the consultant who explains the safety function, offers 
examples of acceptable designs, provides criteria for 
acceptable designs, evaluates and tests proposed designs, 
and ultimately agrees that the specific design meets the 
safety function requirement.

Its a team effort.  Credibility and expertise of the 
safety engineer is a key element to being accepted as a 
part of the team.

Externally imposed organizational requirements that the 
Product Safety group be organizationally positioned to
avoid "conflict of interest" seem to presuppose a 
management style and philosophy that I have not 
experienced.  (I'm sure I've lived a sheltered life in 
terms of management style and philosophy!)  :-) 

In an ideal world, the R&D engineer would be trained in
product safety.  There would be no need for the product
safety engineer I've described above.  Safety testing 
would be included in the product functional testing, not 
as a separate entity.  Third-party certifications would 
be obtained by a procurement group (charged with buying
the right to use the mark).


Best regards,
Rich





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