Seems to be good design requires at least single fault tolerance - which is 
outside of "normal" functioning.


Sandy
CDRH/OSEL/DESE phone number : 301-796-2582

________________________________
From: Cortland Richmond [mailto:[email protected]]
Sent: Friday, December 07, 2012 9:06 AM
To: [email protected]
Subject: Re: [PSES] The Cost of Safety

I was on contract to write a test plan for a new AED when one of the project 
managers complained about the cost of doing all the tests. "No one else does, 
it's a competitive disadvantage. Why make it so difficult?"

Rather than fall back on "Because you can't legally sell them without," I 
replied "I don't want to kill people we're trying to save."

He went away.

In fact, a lot of EMI tests are not immediately critical to the life of a 
person being treated, but the ambulance still has to be able to hear the 
dispatcher. Some of them do relate to function; its radio shouldn't shut down 
treatment*, or an AED's processor decision be mislead by overhead locomotive 
power at 16 2/3 Hz.**  Nor do you want to interfere with aircraft collision 
avoidance or its communications. So I kept it simple.

*Reported to have resulted in death in either a Glen Dash column, or an EMC 
Club Banana Skins; I forget which.

** 
www.ncbi.nlm.nih.gov/pubmed/15294405<http://www.ncbi.nlm.nih.gov/pubmed/15294405>

Might we have a psychologist speak at an EMC Symposium on "How to talk your 
boss into doing the right thing"?



Cortland Richmond

On 12/7/2012 0232, John Woodgate wrote:
Safety and EMC 3rd party testing costs are properly a marketing expense, 
because they are incurred in order to be allowed on to the market. They are not 
a charge on R&D, because the products work perfectly OK without the testing.

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