For some folks, I offer them the FCC form 730 (?, a senior moment!) The import 
compliance one.  And point out that sure they can import that product that has 
no documentation, etc.  Just sign here.  Note this clause that details your 
impending 5 year Federal vacation that you get to pay a quarter million dollars 
for.  There is usually a long pause while they read that and digest it.  Most 
have handed the form back and said to get the documentation.   By then, the 
shipment usually get returned to sender, if there is time left, otherwise 
destroyed by Customs which we get to pay for.
Sometimes Corp Legal would get involved.  Both sides of the debate would 
present their position and the legal beagle would decide.  The decision as one 
shyster put it to the questioner that asked just why they had to endure this 
charade, was that the lawyer needed the information to determine which table he 
would be sitting at,  the questioners... or the other side!!|
Funny how they all wanted the Corp lawyer sitting at their table.



________________________________
 From: Brian Oconnell <[email protected]>
To: [email protected] 
Sent: Thursday, March 29, 2012 3:25 PM
Subject: RE: [PSES] receiving/approval processes under fire
 
Rich, Ron, John, et al,

Many thanks for the sanity check (not me, the process requirements). Reminds
me of (in another life) the boss's favorite retort: 'too many stupid people,
not enough napalm.' Where we were also taught to immediately assault
directly into an ambush. Intend to do that.

I have received many off-line replies that indicate their design engineers
had said the exact same thing to them. And just received another reply from
an agency engineer I have known > 10 years. He says this he hears this stuff
all the time from eng dept at companies not having a compliance person -
"Never had to do anything like this at any other company."

Time to go break in the new boss. This may hurt...

Brian

-----Original Message-----
From: [email protected] [mailto:[email protected]]On Behalf Of Richard
Nute
Sent: Thursday, March 29, 2012 10:24 AM
To: 'John Woodgate'; [email protected]
Subject: RE: [PSES] receiving/approval processes under fire

Mr. Woodgate suggests:

> What you do is make the design team leader *responsible*for the
> compliance of the design. He/she doesn't do the tests but has to
> understand the standards that apply enough to assess the test reports
> and sign them off.

Absolutely!  I have successfully used this process for years!
My designers have been very complementary.

However, to do this, the compliance engineer must partner
with the designer so as to offer various alternatives that
complement his design, not just a one-size-fits-all.  And,
you must take some risk with the certification house so
that your promises to the design engineer are fulfilled.  To
do this means you must also partner with the cert house at
the same time to be certain that the design is certifiable.

This means you join the design team in the very early stages
of the design and jointly agree with the design team as to
a safety design strategy -- BEFORE the design is developed
to a physical model.

This has another advantage:  the very first prototypes
comply with the requirements, and can be used for certification.
This means that the certification timetable is not in the
critical path to project completion.

Good luck!
Rich

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