Date sent:              Sat, 18 Aug 2012 08:56:30 +0100
Send reply to:          John Woodgate <[email protected]>
> 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.

100% to 400% more often.  How often would give you 
confidence?

As a former NRTL (noninspecting) employee, I was 
subjected to noise from some manufacturer's about 
how intrusive quarterly inspections were.

I suspect there's no system that will satisfy all 
players.

> 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.

At another former employer, I heard a story of a 
moderately large piece of rack mountable equipment 
designed by an European subsidiary intended for the 
European market that could not be brought into 
compliance with radiated emissions limits using 
standardized test methods without significant 
revisit to the drawing board.  Their solution?  
Place the unit on its back.  Et voila! A self 
certification was emitted.

I would not call this company small.

I could speculate as to what other "special 
considerations" might have been found self 
certifiable.

I'd like to hear other stories of the self 
certification regime.


Peter Tarver

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