#pyreply 2.65

As others have said - requirements for service parts are all over the map.

The other issue is the General Services agreement that the factory and
applicant have with the agencies whose mark is being applied. Most
conformity assessment bodies will not allow substitution of plastic material
where the component is on a C/C table in the CDF or in a report. If the
material is being used a fire enclosure, you risk re-call at worst, or
submittal for an alternate construction project at best, if a factory
auditor issues a variation notice.

Brian

-----Original Message-----
From: [email protected] [mailto:[email protected]]On Behalf Of McInturff,
Gary
Sent: Thursday, June 13, 2013 1:24 PM
To: '[email protected]'
Subject: Pointer please.

Where in the safety directives are the instructions for spare parts or
service parts. We manufacture a device for an end customer but don't do the
safety approvals - we are just designated as a factory. I haven't seen any
activity in getting this device approved under the new edition of the
standard and am concerned that it has fallen through the cracks by the
customer.
I don't believe it's a current production system but they are maintaining
the systems already in the field, meaning that this are service parts I
believe, but I don't know exactly what allows them to continue importing
them into Europe. 
 
The real issue is that some of the plastic that had been used in the past
isn't going to be available but it is described as a critical component in
the safety files by manufacturers name. model type. We can replace the
material with the same flame rating but the raw material is from a different
supplier. Even if spare parts are allowed for a system with an out of date
harmonized safety standard I don't think one can just change the components
without some activity, but exactly what and how, add some notes to the
technical file?
 
I've tried discussing the issue with the customer but can't get through the
purchasers to the compliance people, to insure that this isn't just slipping
through the cracks.
 
 
Esterline Interface TechnologiesFeaturing 
ADVANCED INPUT, GAMESMAN, LRE MEDICAL, and MEMTRON  products
600 W. Wilbur Avenue
Coeur d'Alene, ID  83815-9496
Toll Free: 800-444-5923 X1XXX
Tel:  (208) 635-8
Fax: (208) 635-8

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