John Whilst I accept the validity of some of the argument below, I have to say that whilst - particularly for the "smaller" manufacturers - the concept of actively looking for issues with existing products and then correcting them, it can often be more a matter (and particularly in the current business climate) of "keeping your head above water" by shipping as much product as possible and with "fingers a bit crossed" that you have got those right.
Compliance control during production is a major issue for small companies, particularly as they are often introducing new features, or having to replace non-available components with those they can actually get, because they have far less clout with their suppliers. That, together with often small development teams, mean that the focus is on the "now and the future" and not on what happened before - and a lot of use is made of "leverage" from older products, and that can easily result in "compliance drift" in the wrong direction. As for the issue that factory inspections only picking problems after the fact, then surely it is better to do that than not to do it at all - and these do mean that the manufacturer becomes more aware of the types of deficiencies that can and do occur, and be able to prevent/minimise them in the future. I know these views have drifted somewhat away from my initially-stated scepticism on the gains from 3rd party certification over SDoC, but there is a place for both. My comment leads back to the question of whether one is actually better, or should I say "more effective", than the other - and basically I think my answer would be "no, but when applied together, they both play a significant part in overall good product compliance". I also think that this is particularly true for importers of products made in "the Far East" where importer may actually have very little real control on the items he actually receives into the EU because he is relying on the supplier "to get it right" but without any assurance that the latter actually is doing that. That is where genuine 3rd party certification can assist him and, should counterfeit products actually get through the net, then the false application of 3rd party certification marks could make a difference - because the relevant certification organisations may well then take direct legal action against the original suppliers in their home countries (as well as the unfortunate importer!). Anyway, just more views to fuel the fires of this rather interesting thread! :-) John Allen Compliance With Experience Ltd. W.London, UK -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of John Woodgate Sent: 18 August 2012 08:57 To: [email protected] Subject: Re: [PSES] CE Marking Provoqium In message <!&!AAAAAAAAAAAYAAAAAAAAAJBbQmYH6FNPl0oV0KGUzsyChQAAEAAAAFWDfmYRsYJMlAsxE [email protected]>, dated Sat, 18 Aug 2012, John Allen <[email protected]> writes: >NRTLs inspect from 2 to 4 times a year, often on an unannounced basis, >and that does keep manufacturers ?on their toes? I wouldn't call that 'far' more frequent, and that sort of control can be deadly - see below. >and, for those NRTLs which have detailed product files against which to >inspect, the chances of finding non-compliant variations is (or at >least should be) much higher. The point is that this is 'after the event' control. "According to our records, you were using the XY23B part, but we see that you are now using the XY23C, which is not yet approved by us, from sometime after our last inspection four months ago. We have to withdraw certification from your whole production since that inspection date until every unit you have in stock or can recover is examined and modified to conform. That will be $100 000 penalty, please." (OK, I don't know the exact procedures in case of this sort of violation, and maybe I shall never have to learn, but I hope you see what I mean.) With self-certification, the appropriate action is to determine whether the product is still compliant when the XY23C is introduced, or when the substitution is discovered, with tests if necessary, and if it is, no further action is necessary. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ 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]>
