Gregg, The problem that you mention below does not have anything to do with the argument of paper vs electronic storage; where you keep your DoC or even whether you use the latest copy of documentation. The problem that you bring up, which is valid, lies in how the documentation is created and revised.
Test reports have to be revised so that historical information is not lost. Our latest compliance test plans include a list of major subassemblies, by revision, of the test sample used for testing. If there is retesting, that list isn't destroyed during the revision. A new list is added to account for the changes. So, in the best case, the user is guaranteed to get the latest, current revision from our document control which INCLUDES all testing ever done on the product and a snapshot of the product taken at each point in testing. Now consider the paper case. Can you guarantee that any one paper copy will have all of that information? Are you suggesting that a separate, new paper copy be created and stored for each and every revision of a product; or each and every re-test? I can guarantee that it just isn't the case. Many NRTL reports, in paper, consist of an original report plus amendments and revisions. The amendments and revisions consist of either changed sheets, inserted sheets, additional appendices... Our office has taken over custodial responsibility for these reports created by other companies that were merged with us. I can tell you, first hand, that these paper reports are a MESS. They come to me in a &%*$ box with no page numbering scheme or any other way of knowing if you have the whole report or just a part. Some of the companies that were merged with us had electronic reports. They gave me a disk or server address with all of the test data on it. Job done. The electronic reports consist of a directory with all files stored and named by date, and/or report number. By the way. Our electronic files are backed up regularly and stored offsite in a fireproof container. Can anyone say the same about their paper copies? Consider the thought experiment that follows: Put an electronic copy of test data on a company's document control server with regular backup. The electronic backup is kept offsite just in case the factory has a fire, earthquake, plague of paper eating locusts, whatever. Then consider a paper copy in someone's office in Europe. Which one would you trust? Which one do you think will be around in ten years? All your points are well taken; but they are solvable in electronic format. My experience is that electronic wins out in: integrity of copy, availability, storage safety, ease of update, coherence of storage and just about any other category that I can think of. The only time paper wins out over electronic is during a power outage. Chris Maxwell | Design Engineer - Optical Division email chris.maxw...@nettest.com | dir +1 315 266 5128 | fax +1 315 797 8024 NetTest | 6 Rhoads Drive, Utica, NY 13502 | USA web www.nettest.com | tel +1 315 797 4449 | > -----Original Message----- > From: Gregg Kervill [SMTP:gr...@test4safety.com] > Sent: Thursday, December 12, 2002 9:58 AM > To: Chris Maxwell; 'Gary McInturff'; 'Nick Williams'; 'Stephen Irving' > Cc: emc-p...@majordomo.ieee.org > Subject: RE: Location of CE DoCs - electronic copies > > There is a problem with "..the reader is guaranteed to get the latest > revision as stored in our Document Control system." > > The latest drawing has NO RELEVANCE WHATEVER to the CE Marking File. What we > are required to record is the "As Built Standard" of the product tested - in > terms of its Safety or EMC performance. > > It is for precisely this reason that UL/CSA/et al use specially written > Product Descriptions to allow manufacturing follow-up inspection. > > > Evaluation for safety (and EMC) relates to ONE PRODUCT (the type-test model) > - if current production standard deviates significantly (in safety or emc > terms) from that original type-test model then re-evaluation is required to > limit potential corporate liability. > > > The EU Enforcement office does not need to know what the latest product is > supposed to look like - he will have the 'smoking gun' in his hand! > > If it has injured someone then (under EU Law) it will be classified as > unsafe. The issues following this may go something like this: > > * Was this product properly tested? > * Is the product tested the 'same as' the one that caused the injury? > * Is this a random problem or are all products like this one? > * Do we need to recall all products? > > > If the product was not properly tested then there is a breach of EU and > National Law - this may involve actions involving Companies - Products and > People (individual prosecutions). > > If the defect is not random - but due to a significant difference between the > TYPE TEST MODEL and the 'Smoking Gun' then it is likely (and I would hope) > that a RAPEX report (RAPid Exchange of information) would be filed to > Brussels so that all member states can be warned and further injury prevented. > > > > The advice I offer is "focus on the principles - reduce risk - reduce > liability - preserve evidence - aim for Quality don't design down to the > MINIMUM ACCEPTABLE LIMIT". > > > > > Best regards > > Gregg > > > > > > -----Original Message----- > > From: Gary McInturff [SMTP:gary.mcintu...@worldwidepackets.com] > > Sent: Wednesday, December 11, 2002 10:38 AM > > To: Nick Williams; Stephen Irving > > Cc: emc-p...@majordomo.ieee.org > > Subject: RE: Location of CE DoCs - electronic copies > > > > > > Does electronic storage of the documents make any difference? The > > DoC, the test reports, BOM's, drawings and Design verification tests are > > all stored electronically and can be dumped from any printer in the world. > > Obviously, they would have electronic signatures. > > Gary > > > > > > > > ------------------------------------------- > 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: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Ron Pickard: emc-p...@hypercom.com > Dave Heald: davehe...@attbi.com > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > Jim Bacher: j.bac...@ieee.org > > All emc-pstc postings are archived and searchable on the web at: > http://ieeepstc.mindcruiser.com/ > Click on "browse" and then "emc-pstc mailing list" ------------------------------------------- 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: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
