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
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