John, I love your example of the Power Supply. In this case, a “standard” says one thing, but the manufacturer did it a different way. The use of Standards to show compliance to a Directive is only voluntary. In a Hazard Driven approach to safety, such a drop-dead requirement in a Standard should not be allowed unless you only look at standards as a guide to compliance, which they are. In a Risk Assessment, if doing something one way over another would not cause an increase risk, then it would be considered compliant.
But what about a Manufacturer’s Declaration of Compliance where they list standards? Do they have to abide by each of these standards to the letter to be compliant with the Directives? I don’t think so. Many DoCs state this, “conforms with all relevant provisions of the following,” blah blah blah …. to where a list of standards and technical specifications are listed. But who is say what is relevant? The Manufacturer is given that authority in the NLF; not the inspector. This is all in fun and I’m not debating you on this. The fact is, you can talk about “Hazard Driven” approach, or this or that, do lectures, write books, get your picture in CE Magazine, but what it all boils down to is making the inspectors happy. Maybe we should call this “Inspector Driven” approach to Compliance. Smile!! Isn’t that what we do or try to do? The Other Brian From: John Woodgate [mailto:j...@woodjohn.uk] Sent: Friday, November 02, 2018 2:53 PM To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE non-conformity statistics 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<http://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 ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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