Colleagues,
Well, altho my initial question ran far afield I thank
everyone who chimed in to respond.
The discussion has been quite interesting even tho the
initial question is still left somewhat hanging.
The business/cultural/legal discussion that has blossomed
shows us that the interaction between a worldwide set of manufacturers &
certifiers has not yet settled down into smooth working system.
In some ways it is better than the system in place more than
35 years ago when I started working with test house certifications. In
other ways it has become messier because of trying to institute an approval
system that is acceptable worldwide.
The US based OSHA system comes from a different cultural
place than many of the other schemes instituted around the world. The whole
US system is more driven by legal and market forces, which I fully support
in spite of the difficulties in brings. The mfgr gets to choose their level
of exposure in providing their goods into the marketplace. Remember,
workplace safety is not the only exposure; AHJs inspecting construction and
retailers selling products have a significant role in this process.
An interesting discussion about the certification of
components ensued. From my perspective the NA Recognition of component
safety provides a unique building block capability for mfgrs in that the
same components do not need to be re-evaluated over and over when used
across products. (The 800lb gorilla rules here; component mfgrs have little
choice but to use their service since their customers will need that cert
for many product certs thru the same lab.) This simplifies the initial
certification evaluation of a product and ensures that there is ongoing
surveillance of the product downstream. The CE marking scheme could have
invoked such a method but has chosen not to do so; it's probably too late to
start one now.
I understand the need of countries that institute a full
certification scheme to develop a national base of qualified staff to run
the scheme & so they invoke in-country testing to bring their staff up to
speed. The international community ought to be supportive enough to help
them work thru that phase & get to the phase where they will fully accept CB
Reports. This has been done in the past and is going on now in some cases.
(I know that some mfgrs are sending their CB Report and EMC reports to India
along with the product for evaluation; I sure that Indian engineers will
read them carefully during their evaluation - if they get them.)
Since I commonly work with small companies here in the US
with limited staff and budget I recommend that they use a NRTL for their
safety evaluation and also get a CB Report - which contains all of the data
- plus provides a nice certificate which they can provide to anyone who asks
for proof of conformance (without revealing the details of the product
design or evaluation). That covers a lot of bases from what I see.
Again, thanx to each one who joined in. Hopefully many
silent followers have gained some additional insight into the issues
discussed.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201 fone/fax
[email protected]
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