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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