The 80/80 rule was/is applied for auditing manufacturing as, according to
management, 'good enough for government work.' They figured the risk of
getting caught was sufficiently low enough to continue shipping.
Initial testing has no allowance for exceeding the requirements.
An experienced producer will know what variation his manufacturing can make,
and lean towards a 'margin' of passing that accounts for that tolerance.
The FCC is explicit somewhere in the rules tho shall not interfere, regardless
of compliance with the rules. (part 15 devices.) If a license holder complains
about interference, one is shut down.
The EU seems a little more relaxed. No room in the standards for exceeding the
requirements. There is "shall" all through the documents. And then the
uncertainty calculations are required.
But no explicit statements about interference to license holders.
The FCC does enforcement of complaints, but does not do surveillance, which is
left to the FCC's privatized arm of the TCB's.
Which is funny, since the one TCB audit I got called for came on a product that
I had not received the finalized reports for and had not yet gone into
production so the only unit available was the actual test unit, that they still
had in hand. The audit request was withdrawn.
I have shown the management the list of penalties from the FCC and some of the
reported actions taken by the FCC. And somewhere in the OJ, I seem to recall a
mention of actions that can be taken by the EU for violations, including banned
from the market.
On Monday, November 18, 2019, 06:31:41 PM EST, John Woodgate
<j...@woodjohn.uk> wrote:
Yes, 20% is an over-estimate for committees with more than five members.
My view (and I think it might even begin to be believed) is that it can be
accepted that standards should not allow, or even encourage, the shipment of
non-compliant product. The manufacturer alone must decide how to cope with this
requirement. One way might be to apply an X/Y rule, where X or Y or both are
larger than 80, so that the probability of a failure under an 80/80-based
surveillance is extremely low.
But statistical variations do occur, undeniably, and may change from the
instant of shipment to the instant of assessment by a surveillance authority.
So the **surveillance authority** should make allowance for these variations,
by applying the 80/80 rule, or some other algorithm that can be justified.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK On 2019-11-18 20:57, John Allen wrote:
John W
Is not the “80/20 rule” simply the “inverse” of the “80/80 rule”?J.
BTW: those 20% of the committees that actually do the work (with which, from
experience as a BSI committee secretary some years ago, I more than agree –
although in many instances it was far less than 20%!!) are but an infinitesimal
%age of the numbers of people who blithely have to accept the deliberations
thereof (some of which were overly influenced by the “status” of, and pressure
from, the Chairmen - at least that was the situation “quite a few years ago”,
but it is hopefully much better controlled nowadays!).
OTOH, in the context of EMC standards (etc.), what other “rule” might one
reasonably choose when attempting to prepare a standard for “general
consumption”?:
e.g.
- “Absolute/100% compliance”? - Obviously impossible in practice for
practical and economic reasons (except in exceptional and highly critical
situations).
- “At the discretion of the assessor?” – we probably all know where
that would lead (“How much money/work/…… do you want?”)
- “Who the hell cares”!” – one sample passed (very marginally – seen
that = 0.5 dBV on an OATS!) so that’ll be good enough! J
- - Some “other” criteria?? – and thus??
Actually, that last “question” is quite a “serious” one – so what other
criteria could be used?
John E Allen
W. London, UK
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