Peter, NOTE: THIS EMAIL DOES NOT REPRESENT THE POLICY OR OPINION OF MY EMPLOYER.
Thanks for your thoughtful response. Based on the many responses that I have received both on and off-line, it is evident that much of the compliance engineering community is now faced with NCBs and NRTLs that are driven by the "bottom line." Because I respect, and have learned much from, working-level NCB and NRTL engineers, that are mostly driven by product safety and sound engineering principles, it can be assumed the problem is within the boardroom of these organizations. If "The Process" now promulgates policies designed to (only) increase revenue, which do not necessarily ensure operator or end-user safety, then the process is (yet) another tax on business and another trade restraint. Perhaps it is time to press our company officers to put political pressure on the bureaucracy that certifies these organizations. Product Compliance is too important to be driven by revenue-production schemes. luck to all of us, Brian -----Original Message----- From: Peter L. Tarver [ mailto:[email protected]] Sent: Tuesday, April 13, 2004 1:09 PM To: [email protected] Subject: RE: NRTL vs. NRTL, NCB vs. NCB Brian - You've heard much of what I might have otherwise said from others. I will add: All NRTLs are not created equal. I've reviewed reports from several of them and found minor inadequacies and inaccuracies here in there in them, which are of little consequence. On the other hand, some NRTLs are consistent in misapplying requirements or not applying them where there's no evidence of engineering rationale to support that decision. There are, in fact no rules that require an NCB to accept a CB Scheme Certificate and Test Report that doesn't also allow an NCB to review the report and decide if additional testing or a more thorough retesting is necessary. You can read more on this by downloading the IECEE 01 and IECEE 02 documents that define operation and interoperation of NCBs under the CB Scheme. In fact, retesting and factory surveillance are criteria explicitly identified in IECEE 02 as an issue when an NCB considers acceptance of a CB Scheme Certificate and Test Report when applying for a national certification. Here's one to grab you: I've recently been involved with an CBTL where three iterative updates were required to a CB Scheme report to which one previous amendment was made. The CBTL had tested the product twice in the previous 18 months, one of which occurred in the previous 9 months (the original evaluation and the previous amendment). Yet, the self-same CBTL stated they "needed" to retest on the next report amendment, on the basis that their "accreditation" required it. No amount of rational discussion could sway them and no engineering rationale was forthcoming from them. In their favor, at least, that the next revision of the CB Scheme report would otherwise have been the fourth report amendment. The practice of limiting the number of report amendments is documented in IECEE02. However, neither IECEE 01 nor IECEE 02 stipulate retesting is necessary at this stage. To make matters more interesting, the update would only have corrected an omission of detail in the safety critical components list, that was need to support a GS License. When I related this story to management, their first conclusion was that the NCB didn't trust their own test data or they were putting the squeeze on us to wring a few more bucks out of us. It's hard to disagree. Regards, Peter L. Tarver, PE [email protected]
