Hi Greg,

I guess it seems to me that if the device is non-functional, then none of
the regulatory information applies.

As to the other point about the warning being visible constantly, I agree -
careful consideration must be given before using the display to present a
warning. I'm more thinking along the lines of radio type approval ID's, etc,
the displaying of which have no conceivable detrimental impact on safety.

Thanks for your input.

Doug

-----Original Message-----
From: [email protected] [mailto:[email protected]]
Sent: Thursday, July 25, 2002 11:04 PM
To: [email protected]; [email protected]
Subject: Re: e-Labeling


Doug,

I think it's an interesting idea.  Unfortunately, you have as many different

regulators to convince as you have labels.

As a former "certifier", I have a few questions that  I think would need to 
be resolved.  For example, if there were some question about the device that

an authority needed the label information for, and the device were not 
functioning,  the information would not be retreivable.   I don't see how
you 
could argue that the device itself was properly marked in that case.  
Depending on the particular standard and marking requirement, the packaging 
materials may suffice for this.

Also, I believe that for warnings that are intended to appear on the device 
itself, the intent of the standard would be that such warnings would have to

be displayed continuously, not just when a screen is pulled up or at
startup. 
 While there is no guarantee a user will actually read a warning, all users 
must at least be exposed to the warning.  A second user picking up an
already 
switched-on device will not be exposed to the warning prior to use, unless 
the warning is always present on the screen - I suspect you do not intend to

do that.

There are other questions lurking in the back of my mind, but it's late and 
I'm too tired to get them out of the cobwebs.   Those two should be enough 
for you to chew on for now.   

Good luck.



Greg Galluccio
www.productapprovals.com

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