From: "Dan Teninty" <[email protected]>
Reply-To: "Dan Teninty" <[email protected]>
To: "PSTC IEEE-EMC" <[email protected]>
Subject: FW: Quality Assurance and Product Approvals
Date: Tue, 27 Nov 2001 12:11:38 -0800
Rich,
After sending you my reply, I thought that I would open it up to the group
for comment. I thought I would pass on the information about the NARTE
certification for Product Safety engineers.
Best regards,
Dan
Daniel E. Teninty, P.E.
Managing Partner
DTEC Associates LLC
Streamlining The Compliance Process
Advancing New Products To Market
http://www.dtec-associates.com
(509) 443-0215
(509) 443-0181 fax
-----Original Message-----
From: Dan Teninty [mailto:[email protected]]
Sent: Tuesday, November 27, 2001 12:01 PM
To: Rich Nute
Subject: RE: Quality Assurance and Product Approvals
Rich,
I don't disagree with your point of view. It seems that there are a lot of
MBA's devoting allot of time to reducing costs. This is how business is
run.
The days are gone when, like the founders of your organization, companies
could compete on quality, reliability, features, and perceived value. Now
everything boils down to "how can we shave unit cost another $0.03?"
General
Motors has had some high profile cases where this philosophy has led to
injuries and deaths. The world is changing, not always for the better and I
will continue to tilt at windmills. I believe that consumers expect/assume
that products they purchase are "safe" and won't scramble their TV's
picture
during the Super Bowl. Quantifying this perception into a benefit that can
be placed into a spread sheet is, I agree, a difficult if not impossible
task, but a good actuary could probably come up with a defensible number.
The point is that the philosophy of corporate management sets the tone for
the rest of the company and if regulatory compliance is not a priority for
management, then it won't be a priority for the compliance department.
Reducing the amount of flame retardant plastic in a product is commendable
if it doesn't compromise the protection it provides. Engineering is about
trade-offs of conflicting requirements. Integrating compliance into a
product should trade off the risk/consequence of non-compliance leading to
an event. Events lead to lawsuits. I've always made a distinction between
standards requirements and safety. Walt Hart at Fluke was an early mentor
in
product safety and taught me to differentiate between a requirement for a
wire to be blue and a requirement that 5000 Volts not reach an end user.
Harking back to an earlier thread, there are compliance engineers like
yourself who go far beyond the requirements in the standards and understand
the basic principles involved and how this basic science leads to
standards.
Then there are the folks who have compliance thrust upon them and at the
extreme, haven't got a clue. In the commercial world of putting up
buildings and other public structures there is a requirement that a
registered professional engineer review and sign off on drawings. This is
not a perfect solution and there are bad apples, but there is a minimum
level of competence assumed that does not exist in the product safety
world.
EMC engineers have NARTE certification to add to their qualifications and
most of the NARTE certified EMC engineers I've encountered were competent
to
say the least. NARTE has just recently, at the EMC meeting in Montreal,
announced a similar certification for product safety engineers. Some will
say this is an attempt at empire building or elitism, but I contend that
raising the bar will benefit society as a whole and perhaps eventually
elevate the status of compliance engineers from, as we were affectionately
known at Fluke, "Those *&%holes downstairs" to respected professionals.
My 2 cents,
Best regards,
Dan
Daniel E. Teninty, P.E.
Managing Partner
DTEC Associates LLC
Streamlining The Compliance Process
Advancing New Products To Market
http://www.dtec-associates.com
(509) 443-0215
(509) 443-0181 fax
-----Original Message-----
From: Rich Nute [mailto:[email protected]]
Sent: Tuesday, November 27, 2001 10:35 AM
To: [email protected]
Cc: [email protected]; [email protected]
Subject: Re: Quality Assurance and Product Approvals
Hi Dan:
> Dell Computers, as well as a few other major players, take a proactive
> approach to compliance and actually have a VP position for compliance.
With
> a little investigation into the benefits of having a first rate
compliance
> department with the ability to design for compliance, test to relevant
> standards, compile reports, participate on standards committees, and
deal
> directly with world wide agencies I would think that most companies
that
> have global markets would see both the short term and long term
benefits
to
> the bottom line. I would tend to include PC's into the ordinary
products
> pile, wouldn't you?
I do agree with (and we practice) a pro-active
approach to compliance.
In my experience, though, I am surprised that
a compliance manager would be a VP position
(in a company making "ordinary products" as
compared to a company making medical products
or similar products subject to a high degree
of regulation).
As you mention, there can be short-term and
long-term benefits to the compliance activities
you mention. However, the benefits must outweigh
the costs of the activities. Quantifying and
measuring the benefits of some compliance
activities is often very difficult.
Management philosophy of the particular company
is another significant variable in the extent
of compliance activity.
Some companies believe that safety certification
is sufficient safety. Others believe that safety
and safety certification are independent although
overlapping activities.
At one time, I knew of a company that addressed
safety not in the product, but in liability
avoidance through instruction manuals, through
insurance, and by passing liability on to its
suppliers. Cost effective, yes. Morally
effective, questionable.
> Companies that choose to take the adversarial approach to compliance
by
> cutting corners or only doing the minimum to comply, save dollars in
the
> short term, but pay later in lost customers, or worse, lawsuits. One
of
our
> clients, had a management team that took this denial/avoidance
approach
to
> NEBS. When the Telecom downturn came, they were left in a position
where
> there was lots less demand and what demand there was, was for NEBS
compliant
> products. Most of the management team that made those decisions have
either
> left the company in recent right-sizing exercises, or are working in
lesser
> positions.
Reducing the cost of compliance does not in any
way imply an adversarial approach to compliance.
Neither does cost reduction imply a reduction in
the compliance performance of the product.
For example, some years ago a R&D engineer came
to me and said, "The cost of safety is too high."
My immediate response was, "Not if you design in
safety from the start of the project."
He replied, "No. I mean that safety requires me
to use a power switch and a fuse. These cost
money. The switch serves no benefit to the user
since the unit is left on continuously." (This
was back in the days when the plug was not
considered a disconnect device.)
So, I started a project to determine alternatives
to switches and fuses and other safety components
(for the specific products we were building at
that time).
In terms of EMC compliance, I know one engineer
who keeps track of the number and cost of components
used exclusively for EMC control. His objective
was to reduce the total cost of EMC control. This
in no way is cutting corners of compliance, or
doing the minimum to comply. The result was still
full compliance -- but at least cost.
> It seems that hindsight is always able to find a goat. When I explain
the
> benefits of compliance to management teams, I try to focus on the
bottom
> line benefits of having a product that is marketable everywhere. The
costs
> for compliance, when compared to the total development cost for a new
> product tend to be in the noise. If these costs are amortized over
> reasonable quantities, then the unit cost for compliance tends to be a
> bargain.
There are two kinds of costs associated with
compliance.
The first kind is the cost of compliance in the
product development. I agree that these costs
are indeed "in the noise" compared to the overall
development costs.
The second kind of cost of compliance is the cost
of labor and components that are installed solely
for compliance. For high-volume products, these
costs are far more important than the costs of
development because they affect the price
competitiveness of the product. A flame-retardant
plastic costs more than a non-flame-retardant
plastic. How can we design a product to minimize
the use of flame-retardant plastic yet comply with
the standards as well as being a truly safe product?
For me, this second cost, the per-unit cost of
compliance, is a very significant part of my job.
Best regards,
Rich
-------------------------------------------
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.
Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/
To cancel your subscription, send mail to:
[email protected]
with the single line:
unsubscribe emc-pstc
For help, send mail to the list administrators:
Michael Garretson: [email protected]
Dave Heald [email protected]
For policy questions, send mail to:
Richard Nute: [email protected]
Jim Bacher: [email protected]
All emc-pstc postings are archived and searchable on the web at:
No longer online until our new server is brought online and the old
messages are imported into the new server.
