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.
