RE: Compliance Primer
I agree with Rich on the moral obligation a company has to avoid injury to those who use its products. Every year I give a lecture on Product Safety to manufacturing engineering students at our local university. This is what I say in answer to Why have Product Safety ? - As well as the corporate and legal requirements, designers have an obvious ethical duty to design safe products. No one wants the injury or death of a user of our products on their conscience. Especially if it could have been avoided by - a piece of double insulation - a cover - a warning label - a little common sense Regards, John Crabb, Development Excellence (Product Safety) , NCR Financial Solutions Group Ltd., Discovery Centre, 3 Fulton Road, Dundee, Scotland, DD2 4SW E-Mail :john.cr...@scotland.ncr.com Tel: +44 (0)1382-592289 (direct ). Fax +44 (0)1382-622243. -Original Message- From: Rich Nute [mailto:ri...@sdd.hp.com] Sent: 31 July 2002 01:08 To: emc-p...@majordomo.ieee.org Subject: Re: Compliance Primer It has been some time since I have had to explain or justify product safety activity to a high-level manager-type. As others have said, it is fraught with difficulties. Success depends on first determining the mindset of the person asking the question. I believe I would first ask a number of questions to find out where the person is coming from, why he is asking, and what his objective is in learning about product safety activity. Then, I would enter into a conversation where there is a lot of back-and- forth so that I could continuously read the person as to what he wants to know. For a business, product safety, EMC, and other regulatory or compliance activity usually represent a cost without a benefit, a cost without an associated income. No wonder management will occasionally inquire as to what happens in the compliance department. There is no income derived or guaranteed from having a set of bumper-stickers on your product. In some cases, those bumper-stickers may comprise a passport for the product, but in themselves, they generate no revenue. Indeed, some organizations can and do get by without the bumper-stickers, but usually not for the long term. Making a product safe, or complying with EMC and other regulatory issues can prevent fines, and can prevent a government-ordered product recall. One management question is: How much money do I spend to prevent a recall? And, does spending that money guarantee no recall? As a general rule, the cost of a recall exceeds the per-unit profit. Its a money-loser. And, even the best of us cannot foresee every product safety event. A product safety recall is almost inevitable at least once in the lifetime of a company. Consultants universally advise that each company should have a product recall plan in place before the recall. I address the question of Why product safety? by stating that a company has a moral (as well as legal) obligation not to injure its customers. Depending on mindset, management may only agree with this principle for major injuries, not for minor injuries (and management decides which injury is major and which is minor). Do I sound pessimistic? Scott raised another issue in that we don't have such things as primers on compliance and similar subjects. Nor do we have papers on more complex subjects (in the field of product safety). Some years ago, we had the Product Safety Newsletter. We used this newsletter as a means for publishing papers on safety topics (although none was published on this subject). With thanks to Jim Bacher, many of the old PSNs are now available for download from: http://www.ewh.ieee.org/soc/emcs/pstc/psn/ While the IEEE EMC society has several publications, the product safety folks have nothing. We need to develop both authors and a publication medium. We have the medium, the mindcruiser web site. While it is not perfect, it is usable. http://ieeepstc.mindcruiser.com/ We intend this web site as an electronic version of the PSN. But, we haven't yet developed a cadre of authors who would post papers to this web. This is an open invitation to post papers of general interest to the product safety, emc, and telecom communities to this web site. We're looking for the equivalent of an editor to oversee this function. Volunteers please contact me or Jim Bacher. Best regards, Rich --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail
Re: Compliance Primer
It has been some time since I have had to explain or justify product safety activity to a high-level manager-type. As others have said, it is fraught with difficulties. Success depends on first determining the mindset of the person asking the question. I believe I would first ask a number of questions to find out where the person is coming from, why he is asking, and what his objective is in learning about product safety activity. Then, I would enter into a conversation where there is a lot of back-and- forth so that I could continuously read the person as to what he wants to know. For a business, product safety, EMC, and other regulatory or compliance activity usually represent a cost without a benefit, a cost without an associated income. No wonder management will occasionally inquire as to what happens in the compliance department. There is no income derived or guaranteed from having a set of bumper-stickers on your product. In some cases, those bumper-stickers may comprise a passport for the product, but in themselves, they generate no revenue. Indeed, some organizations can and do get by without the bumper-stickers, but usually not for the long term. Making a product safe, or complying with EMC and other regulatory issues can prevent fines, and can prevent a government-ordered product recall. One management question is: How much money do I spend to prevent a recall? And, does spending that money guarantee no recall? As a general rule, the cost of a recall exceeds the per-unit profit. Its a money-loser. And, even the best of us cannot foresee every product safety event. A product safety recall is almost inevitable at least once in the lifetime of a company. Consultants universally advise that each company should have a product recall plan in place before the recall. I address the question of Why product safety? by stating that a company has a moral (as well as legal) obligation not to injure its customers. Depending on mindset, management may only agree with this principle for major injuries, not for minor injuries (and management decides which injury is major and which is minor). Do I sound pessimistic? Scott raised another issue in that we don't have such things as primers on compliance and similar subjects. Nor do we have papers on more complex subjects (in the field of product safety). Some years ago, we had the Product Safety Newsletter. We used this newsletter as a means for publishing papers on safety topics (although none was published on this subject). With thanks to Jim Bacher, many of the old PSNs are now available for download from: http://www.ewh.ieee.org/soc/emcs/pstc/psn/ While the IEEE EMC society has several publications, the product safety folks have nothing. We need to develop both authors and a publication medium. We have the medium, the mindcruiser web site. While it is not perfect, it is usable. http://ieeepstc.mindcruiser.com/ We intend this web site as an electronic version of the PSN. But, we haven't yet developed a cadre of authors who would post papers to this web. This is an open invitation to post papers of general interest to the product safety, emc, and telecom communities to this web site. We're looking for the equivalent of an editor to oversee this function. Volunteers please contact me or Jim Bacher. Best regards, Rich --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: Compliance Primer
I took a similar tack, except for 5, 6, and 7, and he quietly moved on to pressure another department. Best regards, Dave Lorusso Lorusso Technologies, LLC Hah. You expect us to believe you never did a Number Seven? We know you better than that Dave, you sly dog, you. =] And you are absolutely right. We do need to lighten up now and then. See ya. Mike --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: Compliance Primer
Jim, This really brightened up my day, especially number 7. It's good to see a sense of humor in this, sometimes, very serious forum. By the way, I totally agree with you - Directors and above cannot be trusted. I once worked for one who wanted to understand the product safety process so he could come up with a rating system, i.e., rate competitors product safety programs and advertise how great ours was. I took a similar tack, except for 5, 6, and 7, and he quietly moved on to pressure another department. Best regards, Dave Lorusso Lorusso Technologies, LLC Your NEBS, Product Safety and EMC Solution www.lorusso.com http://www.lorusso.com/ 512.695.5871 -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of James Collum Sent: Tuesday, July 30, 2002 9:54 AM To: emc-p...@ieee.org Subject: Re: Compliance Primer Reason I ask is I had these questions posed to me by one of our directors. He wants to learn about compliance. I was caught flat footed. How do you explain what took you 19 years to learn? And that you really don't know as much as you think? I showed him my stack of standards but didn't think that would be a good place for him to start. I have been pondering this, and would like to suggest a different tack. In these times of recession he may be attempting to pick your brains prior to taking some draconian action, so in the same way that a good salesman always guards his rolodex, I would propose that you do the following. 1) Produce nothing in writing, I think that your showing him a huge stack of standards was an excellent place to deflect him. 2) When refering to EMC do so in front of a powered up product and make small circular hand motions when describing magnetic fields and larger hand movements for electric fields. Grasp the product firmly when refering to safety (make sure that your hair style is similar to that of a tv evangilist for optimum effect). 3) Have anecdotal evidence of the repercussions of short cuts (FCC fines for non- marked equipment at trade shows, foreign distributors being imprisoned etc etc). 4) Expand your D of C's for Europe to include every possible directive and standard that may apply (including the ones about straight bananas) get this particular director to sign the D of C's, as he is trying to fathom them, ask him if he has a passport and if he is thinking of a European vacation at any time soon, when he says no reply excellent! very quickly and excitedly. 5) Wear T shirts that reflect 19 plus years of experience (have them made to order and stone washed to age them if needed). T shirts such as Shockley, Bardeen and Bratain, first transistor may be a bit much but. Zilog Z80 or Cromemco S100 bus systems would be apt. 6) At the quarterly manufacturing audit, get the safety agency rep in a really foul mood and then whisk him in to see this director. 7) Seek out the most attractive and unobtainable female in your company and flirt and make passes at her in an outrageous and quirky style. (this last one has no bearing on compliance but if everyone in the regulatory field did this someone would be bound to get lucky and then it would make for an interesting story at an IEEE EMC society meeting). Usual caveats, my words not my employers, tongue in cheek, etc etc Jim
Re: Compliance Primer
I've used the approach that one doesn't design compliance IN, one designs non-compliance OUT. People who have the view that EMI reduction is a matter of filters, shields and spring fingers, find out, if they don't know already, that this is the expensive way to do things. They become more receptive to seeking compliance at the component, circuit, and board level. I've seen it happen. Cortland --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: Compliance Primer
The last thing you want to do as a compliance engineer under such circumstances is to appear as something of a Compliance Cop. This will drive an impenetrable wedge between you and literally anyone in management. Most probably what James says is correct - the director is looking for either: 1) primarily - ways to cut costs, or 2) secondarily - loopholes. It *might be* good showing someone in this capacity a mountain of standards. But, he more than likely wants to cut to the chase as to *why* you have that mountain of standards. And most likely he'll key into one liners about it being the law. And he'll most likely think something such as, 'okay so it's the law, we all don't obey the speed limit do we?' If he's looking into cost/benefits ratios which he probably is, don't dwell too much on the why we do it, i.e. citing laws verbatum. Dwell on what happens if you don't do it, i.e. penalties, recalls, fines, a European alert system which notifies all of Europe within 3 days about bad product even in countries you don't sell. But most of all - money. It's a common language. And be cool about it. Besides, you're doing HIM a favor by avoiding all that cost and headache. Regards, Doug McKean --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: Compliance Primer
Reason I ask is I had these questions posed to me by one of our directors. He wants to learn about compliance. I was caught flat footed. How do you explain what took you 19 years to learn? And that you really don't know as much as you think? I showed him my stack of standards but didn't think that would be a good place for him to start. I have been pondering this, and would like to suggest a different tack. In these times of recession he may be attempting to pick your brains prior to taking some draconian action, so in the same way that a good salesman always guards his rolodex, I would propose that you do the following. 1) Produce nothing in writing, I think that your showing him a huge stack of standards was an excellent place to deflect him. 2) When refering to EMC do so in front of a powered up product and make small circular hand motions when describing magnetic fields and larger hand movements for electric fields. Grasp the product firmly when refering to safety (make sure that your hair style is similar to that of a tv evangilist for optimum effect). 3) Have anecdotal evidence of the repercussions of short cuts (FCC fines for non- marked equipment at trade shows, foreign distributors being imprisoned etc etc). 4) Expand your D of C's for Europe to include every possible directive and standard that may apply (including the ones about straight bananas) get this particular director to sign the D of C's, as he is trying to fathom them, ask him if he has a passport and if he is thinking of a European vacation at any time soon, when he says no reply excellent! very quickly and excitedly. 5) Wear T shirts that reflect 19 plus years of experience (have them made to order and stone washed to age them if needed). T shirts such as Shockley, Bardeen and Bratain, first transistor may be a bit much but. Zilog Z80 or Cromemco S100 bus systems would be apt. 6) At the quarterly manufacturing audit, get the safety agency rep in a really foul mood and then whisk him in to see this director. 7) Seek out the most attractive and unobtainable female in your company and flirt and make passes at her in an outrageous and quirky style. (this last one has no bearing on compliance but if everyone in the regulatory field did this someone would be bound to get lucky and then it would make for an interesting story at an IEEE EMC society meeting). Usual caveats, my words not my employers, tongue in cheek, etc etc Jim
Re: Compliance Primer
Scott, I always preferred to keep it simple. Compliance is developing a product that complies with specific requirements stated in applicable national or international standards developed by recognized experts. We comply with those standards because that is what our customer base expects of us, even though customers rarely mention that expectation. We also comply with the appropriate standards so our products will be acceptable to any third party who may test or evaluate our products. Ordinarily the scope of the standard will be all that is necessary to identify the correct standards. Most products will have requirements stated in more than one standard. For example: there will be a product standard, a transformer standard, a switch standard, a standard for polymeric materials, a standard for fuses, a standard for thermal cut-outs, a standard for radio interference suppression capacitors, standards for appliance couplers, standards for plugs, standard for the power supply cable, and others. Then there are the emc standards, the x-ray and laser standards, etc, etc. Regards Lou Aiken, LaMer LLC 27109 Palmetto Drive Orange Beach, AL 36561 USA Tel 251 981 6786 Fax 251 981 3054 Mobile 251 979 4648 - Original Message - From: Scott Douglas To: emc-p...@ieee.org Sent: Monday, July 29, 2002 9:15 AM Subject: Compliance Primer Hi, Does anyone know of any primers on regulatory compliance? Like what compliance is, why we do it, how does one figure out what standards apply to a product, and whatever? Reason I ask is I had these questions posed to me by one of our directors. He wants to learn about compliance. I was caught flat footed. How do you explain what took you 19 years to learn? And that you really don't know as much as you think? I showed him my stack of standards but didn't think that would be a good place for him to start. Looking forward to your comments. Regards, Scott Douglas Senior Compliance Engineer Narad Networks 515 Groton Road Westford, MA 01886 office: 978 589-1869 cell: 978-239-0693 dougl...@naradnetworks.com www.naradnetworks.com
Re: Compliance Primer
I would add a litle to Rick's insight from my experience. You may find that Manufacturing appreciates the quality enhancements usually obtained in the regulatory process (and other test methods such as stress testing) and would understand the consequences of non-compliance. Product designers may not recognize a need for regulatory enhancements. Complaints of software bugs are more tangible (since they tend to be suffered by more customers) to RD than hardware regulatory issues. When an executive sees a competitor's non-compliant product competing successfully then the executive is tempted by greed to copy that successful business model. This attitude was proven by how quickly financial accounting fraud spread to so many companies here in America. Eric Lifsey Compliance Engineer --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: Compliance Primer
I used to do seminars internal to companies where I worked on this very subject. Great for people with insomnia. I can pass along the information for a small fee of, say, $20,000 per page ... big grin Regards, Doug McKean - Original Message - From: Scott Douglas To: emc-p...@ieee.org Sent: Monday, July 29, 2002 6:15 AM Subject: Compliance Primer Hi, Does anyone know of any primers on regulatory compliance? Like what compliance is, why we do it, how does one figure out what standards apply to a product, and whatever? Reason I ask is I had these questions posed to me by one of our directors. He wants to learn about compliance. I was caught flat footed. How do you explain what took you 19 years to learn? And that you really don't know as much as you think? I showed him my stack of standards but didn't think that would be a good place for him to start. Looking forward to your comments. Regards, Scott Douglas Senior Compliance Engineer Narad Networks 515 Groton Road Westford, MA 01886 office: 978 589-1869 cell: 978-239-0693 dougl...@naradnetworks.com www.naradnetworks.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: Compliance Primer
Hi Rick, Thank you for the input. I have found the same experience on the penalties issue. You are correct in the fact that it will be mentioned and not be a focal point of the article. Any other comments and suggestions are greatly appreciated. Incidentally, I would also really enjoy hearing from the group about what kind of resource SCS could incorporate into their website which would be most beneficial to you. Best regards, Garry Hojan CEO/ President Strategic Compliance Services (SCS) a Division of NRL, L.L.C. 11402 E Mariposa Rd. Stockton, CA 95215 Tel:209-465-0619 Fax:209-812-1931 Mobile: 209-662-4322 Email: gho...@regulatory-compliance.com Web:www.regulatory-compliance.com -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of rbus...@es.com Sent: Monday, July 29, 2002 8:41 AM To: emc-p...@ieee.org Subject:RE: Compliance Primer For what its worth, it has been my experience over the years that management is turned off by hearing about threats and penalties. That is not to say that they don't care, and these should definitely be part of your presentation, but they are looking business building issues. I try to show how regulatory efforts improve product quality, how additional markets may be opened and how testing costs can best be managed. Showing them why regulatory issues are important should be the bulk of your presentation. Addressing the penalties and consequences should be mentioned but in my opinion should not be focal point. The issue that is always thrown back at me are the numerous accounts where company A shipped product without proper regulatory approval and nothing happened. We all know this has been problematic. Obviously the issue is whether or not their company is willing to take the risk. After all product regulations is in effect a risk management effort. We minimize the risk of hazards, minimize the risk of interference and minimize the risk that our companies could get into legal trouble. Just my $.02 Rick Evans Sutherland rbus...@es.com -Original Message- From: Garry Hojan [mailto:gho...@regulatory-compliance.com] Sent: Monday, July 29, 2002 9:10 AM To: Scott Douglas; emc-p...@ieee.org Subject: RE: Compliance Primer Hi Scott, I am in the process of writing just such an article, directed towards those within an organization who have, what I would call, a periphery view of regulatory compliance (directors, purchasing, sales and marketing) and how it effects them and the company. I am writing it with your situation in mind, but I would be interested in the group's viewpoint on the value of such an article. Do you find yourself explaining what rc is? Do you have to justify the fact that it has to be done? How many times do you find yourself in a pressure situation where the product is sold without the appropriate approvals and your under the gun to get the approvals? I would also be extremely appreciative if the group has some scenario's that they would like covered in the article. I will also be covering penalties and liability issues, which should hopefully open some eyes of those who feel that it is an acceptable business risk to run with a less than satisfactory compliance program. In the article I will explain the process of how to determine which standards apply for which country/product mix, and how difficult it can be for some countries due to time zones, translations, unclear or differing instructions from within the country, political issues, political and business policy, unwritten caveats, etc., etc. I look forward to hearing from the group. Best regards, Garry Hojan CEO/ President Strategic Compliance Services (SCS) a Division of NRL, L.L.C. 11402 E Mariposa Rd. Stockton, CA 95215 Tel: 209-465-0619 Fax: 209-812-1931 Mobile: 209-662-4322 Email: gho...@regulatory-compliance.com Web: www.regulatory-compliance.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org
RE: Compliance Primer
For what its worth, it has been my experience over the years that management is turned off by hearing about threats and penalties. That is not to say that they don't care, and these should definitely be part of your presentation, but they are looking business building issues. I try to show how regulatory efforts improve product quality, how additional markets may be opened and how testing costs can best be managed. Showing them why regulatory issues are important should be the bulk of your presentation. Addressing the penalties and consequences should be mentioned but in my opinion should not be focal point. The issue that is always thrown back at me are the numerous accounts where company A shipped product without proper regulatory approval and nothing happened. We all know this has been problematic. Obviously the issue is whether or not their company is willing to take the risk. After all product regulations is in effect a risk management effort. We minimize the risk of hazards, minimize the risk of interference and minimize the risk that our companies could get into legal trouble. Just my $.02 Rick Evans Sutherland rbus...@es.com -Original Message- From: Garry Hojan [mailto:gho...@regulatory-compliance.com] Sent: Monday, July 29, 2002 9:10 AM To: Scott Douglas; emc-p...@ieee.org Subject: RE: Compliance Primer Hi Scott, I am in the process of writing just such an article, directed towards those within an organization who have, what I would call, a periphery view of regulatory compliance (directors, purchasing, sales and marketing) and how it effects them and the company. I am writing it with your situation in mind, but I would be interested in the group's viewpoint on the value of such an article. Do you find yourself explaining what rc is? Do you have to justify the fact that it has to be done? How many times do you find yourself in a pressure situation where the product is sold without the appropriate approvals and your under the gun to get the approvals? I would also be extremely appreciative if the group has some scenario's that they would like covered in the article. I will also be covering penalties and liability issues, which should hopefully open some eyes of those who feel that it is an acceptable business risk to run with a less than satisfactory compliance program. In the article I will explain the process of how to determine which standards apply for which country/product mix, and how difficult it can be for some countries due to time zones, translations, unclear or differing instructions from within the country, political issues, political and business policy, unwritten caveats, etc., etc. I look forward to hearing from the group. Best regards, Garry Hojan CEO/ President Strategic Compliance Services (SCS) a Division of NRL, L.L.C. 11402 E Mariposa Rd. Stockton, CA 95215 Tel: 209-465-0619 Fax: 209-812-1931 Mobile: 209-662-4322 Email: gho...@regulatory-compliance.com Web: www.regulatory-compliance.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: Compliance Primer
Hi Scott, I would first show your director the reference in the 2002 NEC Article 90.7 (Page 70-31) Examination of Equipment for Safety. It doesn't get specific information as what you are asking for, but it does give the reason we have to do what we do. From that point on, I'm sure other list members have more specific ideas. Ron Baugh VeriFone, Inc. -Original Message- From: Scott Douglas [SMTP:dougl...@naradnetworks.com] Sent: Monday, July 29, 2002 6:15 AM To: emc-p...@ieee.org Subject:Compliance Primer Hi, Does anyone know of any primers on regulatory compliance? Like what compliance is, why we do it, how does one figure out what standards apply to a product, and whatever? Reason I ask is I had these questions posed to me by one of our directors. He wants to learn about compliance. I was caught flat footed. How do you explain what took you 19 years to learn? And that you really don't know as much as you think? I showed him my stack of standards but didn't think that would be a good place for him to start. Looking forward to your comments. Regards, Scott Douglas Senior Compliance Engineer Narad Networks 515 Groton Road Westford, MA 01886 office: 978 589-1869 cell: 978-239-0693 dougl...@naradnetworks.com www.naradnetworks.com http://www.naradnetworks.com/ --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: Compliance Primer
Hi Scott, I am in the process of writing just such an article, directed towards those within an organization who have, what I would call, a periphery view of regulatory compliance (directors, purchasing, sales and marketing) and how it effects them and the company. I am writing it with your situation in mind, but I would be interested in the group's viewpoint on the value of such an article. Do you find yourself explaining what rc is? Do you have to justify the fact that it has to be done? How many times do you find yourself in a pressure situation where the product is sold without the appropriate approvals and your under the gun to get the approvals? I would also be extremely appreciative if the group has some scenario's that they would like covered in the article. I will also be covering penalties and liability issues, which should hopefully open some eyes of those who feel that it is an acceptable business risk to run with a less than satisfactory compliance program. In the article I will explain the process of how to determine which standards apply for which country/product mix, and how difficult it can be for some countries due to time zones, translations, unclear or differing instructions from within the country, political issues, political and business policy, unwritten caveats, etc., etc. I look forward to hearing from the group. Best regards, Garry Hojan CEO/ President Strategic Compliance Services (SCS) a Division of NRL, L.L.C. 11402 E Mariposa Rd. Stockton, CA 95215 Tel: 209-465-0619 Fax: 209-812-1931 Mobile: 209-662-4322 Email: gho...@regulatory-compliance.com Web: www.regulatory-compliance.com -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Scott Douglas Sent: Monday, July 29, 2002 6:15 AM To: emc-p...@ieee.org Subject: Compliance Primer Hi, Does anyone know of any primers on regulatory compliance? Like what compliance is, why we do it, how does one figure out what standards apply to a product, and whatever? Reason I ask is I had these questions posed to me by one of our directors. He wants to learn about compliance. I was caught flat footed. How do you explain what took you 19 years to learn? And that you really don't know as much as you think? I showed him my stack of standards but didn't think that would be a good place for him to start. Looking forward to your comments. Regards, Scott Douglas Senior Compliance Engineer Narad Networks 515 Groton Road Westford, MA 01886 office: 978 589-1869 cell: 978-239-0693 dougl...@naradnetworks.com www.naradnetworks.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Compliance Primer
Hi, Does anyone know of any primers on regulatory compliance? Like what compliance is, why we do it, how does one figure out what standards apply to a product, and whatever? Reason I ask is I had these questions posed to me by one of our directors. He wants to learn about compliance. I was caught flat footed. How do you explain what took you 19 years to learn? And that you really don't know as much as you think? I showed him my stack of standards but didn't think that would be a good place for him to start. Looking forward to your comments. Regards, Scott Douglas Senior Compliance Engineer Narad Networks 515 Groton Road Westford, MA 01886 office: 978 589-1869 cell: 978-239-0693 dougl...@naradnetworks.com www.naradnetworks.com
