A typical technical non-compliance is incorrect marking of power supply
data. Different standards have different requirements, and it's easy to
mistakenly state, for example, the supply current when the standard
requires the input power to be stated. Yes, the majority of reported
violations are minor and require no action, except that the manufacturer
has to fix the issue for future production.
Another case, although I don't know if it would always be rated
'technical' is when the offending product is shown to have an
unpredictable and random fault, which might well be caused by a
component failure during early use, so that the product was probably
compliant when new. I know of a case like that, where a ceramic
capacitor fractured, which caused weak HF oscillation that was detected
by an adjacent radio.
The issue of personal interpretations is embedded in the AHJ system and
needs a total change of approach, which is not probable.
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2018-11-02 18:31, Kunde, Brian wrote:
Ok, I’ll pile on.
I have never been involved in a market surveillance inspection so I
really have no right to comment, but I am trying to understand what
constitutes itself as a Technical Non-Compliance.
Many of my products get inspected post-sale at our customer sites by
third-party labs or union inspectors doing a “Field Evaluation”. Most
inspections go very smoothly, but some labs/inspectors write up every
little thing they don’t understand or cannot test in the field as a
“Non-Compliance”. Sometimes they have their OWN interpretations of
the rules and documentation requirements. Then our customer is placed
in the middle as we try to make the lab/inspector understand why the
product really is compliant. I’m sure many of you have had similar
experiences.
When I see market surveillance reports with tens of thousands of
non-compliances listed but only a few dozen cases where any kind of
real “action” is taken, the first thing I wonder is how legitimate or
serious are the bulk of the non-compliances in the first place. It
makes me think that maybe the mass majority of these cases are so
minor that they simply become learning experience for someone and only
the rare and more serious non-compliances result in fines or legal
action.
Am I the only one who thinks this way?
Don’t get me wrong; I love these types of reports with big numbers. If
I want, I can use them to scare my superiors into doing what I say. I
might even get more budget money to hire more people or get more lab
space. But I really would like to know how many of these
non-compliances are really bad bad product verses barely failed
product verses a poor execution of the difficult to interpret rules
and regulations.
Please don’t beat me up too bad. When I’m bored my mind drifts down
dark paths of no return.
The Other Brian
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