Your first paragraph states the problem, and 'technical violation - no
action' is the way it's resolved.
In a DoC, I wouldn't mention 'relevant' at all, particularly now the
legal profession has got its hooks into the European compliance system.
It really does look like a 'loophole creator', not only to a rabid
regulator. The place to assert relevance/irrelevance is in the
assessment document, whether for EMC or safety.
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2018-11-02 20:38, Kunde, Brian wrote:
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 Associateswww.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
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