I agree with Rich on the moral obligation a 
company has to avoid injury to those who
use its products.

Every year I give a lecture on Product Safety
to manufacturing engineering students at our
local university. This is what I say in answer to
Why have Product Safety ? -

As well as the corporate and legal requirements, 
designers have an obvious ethical duty to design 
safe products.

No one wants the injury or death of a user of our 
products on their conscience.

Especially if it could have been avoided by 

        - a piece of double insulation
        
        - a cover

        - a warning label

        - a little common sense  

Regards,
John Crabb, Development Excellence (Product Safety) ,     
NCR  Financial Solutions Group Ltd.,  Discovery Centre, 
3 Fulton Road, Dundee, Scotland, DD2 4SW
E-Mail :john.cr...@scotland.ncr.com
Tel: +44 (0)1382-592289  (direct ). Fax +44 (0)1382-622243. 



-----Original Message-----
From: Rich Nute [mailto:ri...@sdd.hp.com]
Sent: 31 July 2002 01:08
To: emc-p...@majordomo.ieee.org
Subject: Re: Compliance Primer

It has been some time since I have had to explain
or justify product safety activity to a high-level 
manager-type.  As others have said, it is fraught 
with difficulties.

Success depends on first determining the mindset 
of the person asking the question.  I believe I
would first ask a number of questions to find out
where the person is coming from, why he is asking,
and what his objective is in learning about 
product safety activity.  Then, I would enter into
a conversation where there is a lot of back-and-
forth so that I could continuously read the person 
as to what he wants to know.

For a business, product safety, EMC, and other
regulatory or compliance activity usually represent 
a cost without a benefit, a cost without an 
associated income.  No wonder management will 
occasionally inquire as to what happens in the
compliance department.

There is no income derived or guaranteed from 
having a set of bumper-stickers on your product.  
In some cases, those bumper-stickers may comprise 
a passport for the product, but in themselves, they 
generate no revenue.  Indeed, some organizations 
can and do get by without the bumper-stickers, but 
usually not for the long term.

Making a product safe, or complying with EMC and
other regulatory issues can prevent fines, and
can prevent a government-ordered product recall.

One management question is:  How much money do I
spend to prevent a recall?  And, does spending 
that money guarantee no recall?

As a general rule, the cost of a recall exceeds
the per-unit profit.  Its a money-loser.

And, even the best of us cannot foresee every
product safety event.  A product safety recall
is almost inevitable at least once in the lifetime
of a company.  Consultants universally advise that
each company should have a product recall plan in
place before the recall.

I address the question of "Why product safety?" 
by stating that a company has a moral (as well as
legal) obligation not to injure its customers.

Depending on mindset, management may only agree
with this principle for major injuries, not for
minor injuries (and management decides which 
injury is major and which is minor).

Do I sound pessimistic?

Scott raised another issue in that we don't have
such things as primers on compliance and 
similar subjects.  Nor do we have papers on more
complex subjects (in the field of product safety). 

Some years ago, we had the Product Safety 
Newsletter.  We used this newsletter as a means
for publishing papers on safety topics (although
none was published on this subject).  

With thanks to Jim Bacher, many of the old PSNs 
are now available for download from: 

    http://www.ewh.ieee.org/soc/emcs/pstc/psn/

While the IEEE EMC society has several 
publications, the product safety folks have 
nothing.  We need to develop both authors and a
publication medium.  We have the medium, the
mindcruiser web site.  While it is not perfect,
it is usable.

    http://ieeepstc.mindcruiser.com/

We intend this web site as an electronic version 
of the PSN.  But, we haven't yet developed a 
cadre of authors who would post papers to this 
web.  

This is an open invitation to post papers of 
general interest to the product safety, emc, 
and telecom communities to this web site.  

We're looking for the equivalent of an editor 
to oversee this function.  Volunteers please 
contact me or Jim Bacher.


Best regards,
Rich

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