Agreed John but not every company has or can afford a dedicated Product Safety/ EMC team to work with the designers from cradle to grave..
Before accepting my current position I was on the other side of the fence as I worked for a large name European Safety Agency for many years. I can't tell how many calls I fielded from manufacturers, with no in house safely engineer, who wanted to know what was required to meet the EU CE Marking requirements and had to ship product in a couple of weeks to meet contract commitments. In many cases the caller was stunned at the perceived complexity of what they had to do to show compliance to place a CE Mark on their product. IN most cases I never heard from them again after that initial call and it left me wondering what the did to verify their product was compliant to bear a CE Mark and ship in such a short time frame...........Since they did not have a Safety person involved in the design of the product it is hard for me to believe their product were compliant and ready for CE marking with out some type of modifications being required. Certainly the ideal implementation of the CE Mark is the right way to go but what percentage of products which bear the CE mark truly are compliant?? I thought I read an article in the past where a audit of toys shipping with the CE Mark to a particular country showed over 70% had some form of noncompliance and should not have been marked with the CE Mark. Unfortunately with out proper market surveillance as a deterrent I suspect that there are fair amount of products currently being shipped to the EU which have some type of nonconformance and would not be CE Marked. I agree the CB Scheme is a preferred way to require compliance I just question how effective it has been...I look forward to feedback and opinions from our EU colleagues................ From: [email protected] [mailto:[email protected]] On Behalf Of John Woodgate Sent: Tuesday, January 02, 2007 5:22 AM To: [email protected] Subject: Re: OSHA reg? In message <201048ea81ba0745aca78e4cc8839001769...@desmdswms201.des.grplnk.net>, dated Tue, 2 Jan 2007, "Haynes, Tim (SELEX) (UK Capability Green)" <[email protected]> writes >If so, this would seem to me to be a fundamental difference between EU >and USA that I was unaware of. The US situation is similar to that which was in place in Scandinavia, and to some extent in other countries, including UK ('BEAB Approval') before the grip of the administrations on product safety was loosened in the EU. The new EMC Directive also de-emphasizes the role of third-party involvement. What caused this turn-around in policy? I didn't see any explanation, but it MIGHT be a macro-scale example of a situation that I experienced. At one time, the consumer audio products that were designed by my team were submitted near the end of the development cycle to a safety team, who occasionally imposed costly late changes. This was very obviously the wrong way to work. MY people should be trained to design the products ab initio to meet the safety requirements and the responsibility for the safety of the product should rest with me as team leader. As you might expect, it was not easy to convince management of this, but I was 'allowed to try it'. It eliminated ALL need for (OK, we were lucky, but my team avidly learned about BS 415 and applied it properly) late-stage safety modifications in that year, so the arrangement was allowed to continue. Until, in the way things happen, an even less enlightened management took charge. But by then I'd moved on. In the same way, it may have appeared to the EU powers that 'safety must be designed in' and you don't ensure that with third-party testing and 'approval'. The 'approval' part makes managements think, very reasonably, that the responsibility for product safety rests with the approving agency. That means the agency has to monitor the production, and doing that every six months is hardly sufficient to eliminate the possibility of errors - witness the frequency of product recalls. Making the manufacturer responsible puts the responsibility in the right place, makes it clear that staff need to be trained and to understand the safety requirements and, most preferably but too seldom, that means 'design in', not 'impose later'. Safety teams should carry out the testing, which requires special skills not needed by product development engineers. But the product development team should be responsible to management for the safety of the products they develop. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Politically unexceptionable seasonal greetings to all. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc ______________________________________________________________________ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email ______________________________________________________________________
