Brian Not arguing at all with your comments - generally I think I generally agree with them in the specific issue of strict compliance with the standards.
But why do I think that that the standards are not the whole answer? Why? Because the burden on small (and even on bigger) companies of complying with the complex requirements of many standards can be (generally IS) very heavy - just think how much time/money it takes to comply with the ones you know well - and then think how much more is required for a company that does not? And, in that respect, the NRTL approach is very prescriptive - deviations from the standards is hard, if not impossible, for them to permit. OTOH, the EU approach is more encompassing because the prime requirement is to comply with the essential protection requirements of the relevant Directive(s). As such you do NOT need to comply with all the detailed requirements of a standard, but if you claim compliance with a Harmonized Standard but you don’t comply with some of its specific requirements then you DO have to identify where you have deviated and how you still hold that you comply with the essential requirements of the Directive in question. That's not to excuse companies that ignore the above statement of the requirements, but to explain why it is perfectly possible for the situations you describe could arise in the EU and yet still be compliant with the legal (and hopefully ethical) requirements in this area of the world. OTOH, in the US the situation is more "black and white" and with less room for "flexibility" - which also means a rather blinkered approach IMHO! John Allen West London, UK -----Original Message----- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: 21 February 2015 20:21 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Non sequitur? The survey indicated injury rates, not recalled products (actually preferable to injuries). A small example from my edge of the desert. With exception of the U.K. and Germany, all of the PV stuff that has been reviewed by self that was built in the EU required some significant fixes - did not conform to EN62109-1 much less UL1741/1703. Methinks the industry attitude of many southern EU states needs some adjustment. The only thing that OSHA and SCC should fix is the mess that is the (lack of) mutual recognition among accredited labs. If one NRTL thinks another NRTL's work cannot be accepted, then make a regulatory framework where they are required to be doing the same thing or the offending NRTL's VP of engineering goes to jail. Brian From: John Allen [mailto:john_e_al...@blueyonder.co.uk] Sent: Saturday, February 21, 2015 1:46 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? Good morning (London time!) W.r.t. the OSHA survey – things have changed a bit in the EU since 2008 – for both good and bad! I think there is more general awareness of the hazards of electrical and other goods – and certainly there are more product recalls than there ever were in earlier days, and the supply chain is more aware of its responsibilities to ensure that only “safe” items are supplied. You only have to look at the number of high-profile product recalls that now routinely occur! OTOH, the ranges of goods on offer, and the variety of sources from which they come, have expanded enormously – and that, unfortunately, has lead to more “holes in the systems” for trying to ensure that only “safe” items are put on the market. However, I think that there are several common factors which are tending to reinforce the overall trend towards safer products across the World, and thus in both N.America and Europe, such as: 1) More and more products are being developed for worldwide, as opposed to national, markets, and that means that the designers and manufacturers have to take all the market requirements into account – and, with the welcome rise in the importance of truly international safety standards, that means that those suppliers do more closely try to meet them (or then either fail to get their products into the big markets, or else get widely taken to account for supplying unsafe products) The NTRL approach in N. America and the EU CE marking requirements over here have both substantially contributed to that both directly in their own marketplaces and more globally as the less economically-developed countries (even the big ones like China!) pragmatically adopt the similar standards and regulatory controls on the basis that “if it works in the big countries then it should work for us as well” (and as well as encouraging and helping their own manufacturers to meet those same standards in order to have much wider export markets – or at least not to lose them!). 2) Intelligence gathering and dissemination of information on unsafe products is now much more worldwide – and so knowledge of those products quickly gets to both the regulators and the general public, and the latter are in a much better position to put pressure on the former to get the suppliers to get the problems fixed! Gone are the days when a supplier in one country could be reasonably sure that faults in products on one side of the World would not become public knowledge elsewhere – or that a local supplier could claim that a product was OK and a particular safety problem had never been known about in his marketplace, even though it was well known to the suppliers and regulators in another. National product-alert/recall regimes are much more established in both of the big markets – the legally-enforced systems such CPSC/OHSA in the US and RAPEX in the EU have more clout than they did before. Even if many of the individual regulators are short of funds to enforce the rules, the combined effects of all of them help collectively So where do I think that leaves us? Well, collectively a lot better than we were in 2008, and with a general way forward to better, safer products. Is the NTRL system in the US still necessary? Yes, because that is how the State regulators and the public expect/require it to be at present – but in another 10-20 years, maybe it will become a fond memory from the past! ☺ John Allen W.London, UK From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] Sent: 21 February 2015 03:21 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? OSHA Conducted a Request for Information (RFI) back in 2008 that compared the effectiveness and overall costs of SDoC vs 3rd Party Conformity assessment, the full summary report can be found here http://www.regulations.gov/#!documentDetail;D=OSHA-2008-0032-0099 . While there was no clean data (products that were purely SDoC vs products that were purely 3rd party) available to draw firm conclusions, some of the findings were interesting: • Recorded injuries from electrical equipment were double (per 100,000 workers) in the EU vs the US • A European study found that 58% of extension cords that were available for sale in the EU were sufficiently unsafe to justify a sales ban/product recall • In the 2008 RFI, OSHA estimated that implementing an SDoC system in the U.S. could cost the Agency approximately $360 million annually. In contrast, the current budget associated with operating the NRTL Program is approximately $1 million per year. Based on this estimate, operating an effective SDoC program would require OSHA to incur substantial additional costs. OSHA's current budget for all of its operations is about $558 million. Thus, based on OSHA's estimate, adopting an SDoC system would increase OSHA's entire current budget by more than 150%. Kevin Robinson On Fri, Feb 20, 2015 at 5:36 PM, McDiarmid, Ralph <ralph.mcdiar...@schneider-electric.com> wrote: I'm drifting ever so slightly off topic now but . . . legislation certainly keeps NRTLs in business. I've long admired the EU model, where manufactures declare compliance and are responsible for it. Do we really need 3rd party certification in USA, Canada, Australia, etc? I think the new approach directives and CE mark in Europe is working. _______________________________________________________________________________ Ralph McDiarmid | Schneider Electric | Solar Business | CANADA | Regulatory Compliance Engineering - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> 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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> 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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
