Doug,
I sort of went around with UL on that not to long ago. We wanted to
have a website the customer could call up, this is networking equipment. We
didn't get too far because there was no assurance that everyone would have the
ability to get a connection to the internet and hence would not be able to
access the equipment.
If access is the only concern then I would think the fact that if they
have the bought the device, and the device stores the warnings then they
obviously have the access to the warnings. I suppose they could require that
the warnings come up at least the first time the unit is turned on. Seems like
that is relatively straightforward as well. I have several programs that ask me
if I want to keep getting the same warning message and allow me to turn it off.
The FCC was a little more persnickety about markings thought. Maybe 6
years ago, I wanted to print the FCC required markings and warning phrase
inside the box the keyboard was shipped in. Once the user opened the box to
access the keyboard the printing was staring them in the face. There was a cost
and operations benefit to doing so. Keyboards don't generally have a manual and
we didn't want the cost of the paper, printing, storing, or the logistics with
getting it into the box.
The wording in the standard said that the warning must be in the user's
manual or as a separate sheet of paper included with the keyboard. Considering
the information was right in front of the consumer, and less likely to be
thrown away than a loose slip of paper, I thought this was a pretty
straightforward request. The answer I received was no, the warning must be in
the manual, or on a separate piece of paper.
Hopefully, you experience goes better. I just think that the concept
was too new, and the problem deemed to trivial for them to put any effort into
formulating an answer and its advantages/disadvantages to the manufacturer and
the consumer.
Gary
-----Original Message-----
From: Massey, Doug C. [mailto:[email protected]]
Sent: Wednesday, July 24, 2002 10:12 AM
To: IEEE - PSTC FORUM (E-mail)
Subject: e-Labeling
Hello Group;
Today's regulatory labeling requirements in a global marketplace can get
quite cumbersome, while devices such as handheld PDA-types tend to get
smaller, with fewer flat surfaces available for product labeling. One of my
company's objectives towards product labeling is that the system be
flexible, with an eye toward future requirements as the product adds
features, or moves into new world markets. A handheld product may require
laser classification/warning, safety agency mark, national safety and/or EMC
mark, FCC, Industry Canda, RTTE, and other national radiofrequency type
approval marks for up to three different low power RF devices included in
the unit simultaneously.
While considering the regulatory labeling requirements for a new handheld
computer, it occured to me that a PDA - type device is an ideal medium for
storing and displaying information; by definition, that's what it is.
The device itself could easily be an 'e-label'.
Heck, I could store and display regulatory information such as agency marks,
laser classifications, transceiver type approval numbers, etc, etc, ad
nauseum. In a Windows CE environment, it's a piece of cake and there would
be some definite advantages. Save $$ on labels. The regulatory info is as
resistant to chemicals and wear as the device itself is. I can be a bit
verbose, and make everything easy to read, instead of the usual too-crowded,
too-small format. I could even store the DoC on the device itself.
This device presents no potential hazard until it is powered up, and there
is no hazard associated with putting the battery pack in. For instance, even
with a laser barcode scanner option installed, could I display the aperture
warning on start up? The manufacturing date and laser classification reside
in memory, available to the display from a Windows icon or recessed
dedicated keypad button? Just one example of the possibilities. Just one
example of how the intent of the product specific standard may be met, while
the letter of the standard may not be.
For the purpose of clearing customs, most markings can be applied to
packaging, where there's tons of space.
I'd like to hear what your opinions are.
Doug Massey
Lead Regulatory Engineer
LXE, Inc.
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