Rich,

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?

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.

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.

Its not hard to dig up a few good case studies in Product Liability to drive
home the point.

Best regards,

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: [email protected]
[mailto:[email protected]]On Behalf Of Rich Nute
Sent: Monday, November 26, 2001 12:36 PM
To: [email protected]
Cc: [email protected]
Subject: Re: Quality Assurance and Product Approvals


Hi Alan:

>   Two questions, does the group see a time when we have a VP Compliance on
>   level terms with VP Finance, VP Marketing etc, or is this already
>   happening in the US.

No.  And not likely to happen in companies with ordinary
products.

As a general rule, "compliance" is seen as a necessary
evil.  It is a cost without an associated revenue (or
customer-recognized need or benefit).  Few companies
want to give VP status (and an empire) to a non-revenue-
generating function.

Many companies measure the product incremental cost for
"compliance."  The objective is to find methods and means
for minimizing these product costs.

Furthermore, few companies recognize the work of "compliance"
folks as prevention of future unanticipated costs such as
failure of sales due to non-compliance, product liability,
or even product recalls.  The reason the work is not
recognized is the difficulty of measuring the future cost of
non-compliance, especially if the company has never had such
an incident.

>   Second Question. Does the group think a formal qualification in
>   Compliance Management & CE Marking would be a good idea.

While we may think this is a good idea, most professional
managers in the field of compliance consider the job as one
interim step in their career.  If "compliance" is a non-
revenue-generating activity, then the step to personal
growth is to measure the cost of compliance for the duration
of one's leadership, and add this to one's CV.  Then, move
on.

Candidates for compliance management might find courses
useful. However, the value of such qualifications is not
for the long term.

Another problem is that upper management doesn't want to be
told that they are restricted by compliance rules insofar as
setting objectives for the products and the company.  They
certainly don't want to feel that the only management folks
qualified for managing a compliance function are those that
are trained and qualified in compliance management.

Formal qualification in compliance management may be seen by
upper management as a power play where the compliance
manager uses his knowledge to gain some degree of control
over other managers.

If "formal qualification" in compliance management is
principally that of methodology for measuring and reducing
cost of compliance, then I would think this would be a
very good idea.


Best regards,
Rich




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