RE: Electrical product recall request
Hi Ed, It’s nice to hear from you again. See my comments following your questions below. Let me know if you agree or not or have additional questions. I’m hoping others will chime in and give their opinions, too. If not, that’s ok, too. Best regards, Ron Pickard RPQ Consulting Glendale, AZ 85303 +623.512-3451 tel, +623.848-9033 fax rpick...@rpqconsulting.com www.rpqconsulting.com http://www.rpqconsulting.com/ www.linkedin.com/in/RonPickard From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Price, Edward Sent: Tuesday, January 13, 2009 9:34 AM To: owner-emc-p...@listserv.ieee.org Cc: emc-p...@ieee.org Subject: RE: Electrical product recall request From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Pickard, Ron Sent: Tuesday, January 13, 2009 6:56 AM To: Scott Xe Cc: emc-p...@ieee.org Subject: RE: Electrical product recall request Scott et al, Compliance engineering is a term to describe the engineering activities to ensure that products conform to these regulations. In that aspect, compliance engineering does mimic the legal profession. Ron Pickard Ron: In companies where there is a specifically designated Compliance Engineer, what do you see as the trend in the depth of knowledge of such an engineer? [RP] Engineers tend to focus over time into a specific area of design, manufacturing, quality, reliability, etc. engineering and then specialize into a specific discipline in those areas. Compliance engineers are not really that different in that they specialize mainly in the design/test engineering discipline in the specific areas of product safety, EMC, RF, telecom, RoHS, WEEE, etc, and adding various country requirements as another dimension to this mix, but recent harmonization has lightened that aspect a bit. And, I see the depth of knowledge being dependent on the compliance engineer’s committed/designated area(s) of responsibility (typically the more areas, the less depth), the compliance engineer’s ability(ies), and the how much the employer’s willing to fund the compliance function internally including the # of in-house compliance staff. Does this person hold technical responsibility for issues of safety, EMC, ROHS, etc, as you would expect of an engineer? Or is the scope so broad that the person acts more like a manager or coordinator of other specialists (designers and possibly outside vendors), more toward the lawyer end of the scale? [RP] This is how I see it. A typical design engineer is ultimately responsible for his design and the inclusion of compliance (EMC and safety, etc.) optimally into the design at an as early as possible stage. RoHS/WEEE involves not just the product design, but the whole product design/manufacturing/admin/etc process, including everything from procurement to landfill avoidance. The compliance engineering function affects the whole company and is [1] an engineering function to understand the technical issues, design constraints, etc and introduce design change recommendations to ensure compliance, [2] a management function so that internal and external organizations are informed of the implications of non-compliance and that compliant designs are developed, tested and manufactured to ensure continued compliance on time and within budget (cost reduction efforts and unannounced part substitutions can be nightmares), and [3] a consultancy function where the compliance engineer works with internal organizations to provide needed pertinent and up to date compliance information to ensure that those applicable internal processes/functions provide for continued compliant products. However, if I were to generalize, I would say that a compliance engineer responsible for 1 or 2 disciplines (EMC safety) would typically have a high engineering/consultancy focus. A compliance engineer responsible for more that 2 disciplines would likely have a high engineering/management/consultancy focus with a primary focus on management. Maybe I was misspoken by stating that compliance engineering sometimes mimics the legal profession. The compliance engineering function is focused on the technical conformance side of the law, however the legal profession is focused on the legal side of the law. Maybe there are multiple sides to the law. To a lawyer, that could either be good fortune or a nightmare. Regards, Ed Price ed.pr...@cubic.com blocked::mailto:ed.pr...@cubic.com WB6WSN NARTE Certified EMC Engineer Electromagnetic Compatibility Lab Cubic Defense Applications San Diego, CA USA 858-505-2780 Military Avionics EMC Is Our Specialty - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived
RE: Electrical product recall
John, My primary concern is for Europe. It seems US has lots of information/guidelines. Scott From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: 2009年1月13日 01:20 AM To: emc-p...@ieee.org Subject: Re: Electrical product recall In message 496b73b1.04686e0a.6145.c...@mx.google.com, dated Tue, 13 Jan 2009, Scott Xe scott...@gmail.com writes: It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Are you concerned with product recall in Europe? The rules are different form those in USA, of course, just to make things exciting. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Things can always get better. But that's not the only option. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: Electrical product recall
In message 496c8c92.09876e0a.1d10.7...@mx.google.com, dated Tue, 13 Jan 2009, Scott Xe scott...@gmail.com writes: My primary concern is for Europe. It seems US has lots of information/guidelines. People have already posted details of the European system. Do you need any further information? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Things can always get better. But that's not the only option. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: Electrical product recall
Nick, Many thanks for your useful information for European markets. Scott From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: 2009?~1??13?? 03:06 AM To: Scott Xe Cc: emc-p...@ieee.org Subject: Re: Electrical product recall There is information at the following sites which will be of assistance to you: http://ec.europa.eu/consumers/safety/rapex/index_en.htm http://www.berr.gov.uk/whatwedo/consumers/Safety/products/unsafe-notificatio n/index.html Somewhere in this lot there is a guidance document which provides a basis for an assessment of whether a recall is necessary. I can send you a copy if you cannot find it in the links on the above pages. At a seminar in November last year, we were told that this guidance is being revised and a new model for assessment has been agreed. Heaven only knows if/when this might make it out into the public domain. Nick. At 00:45 +0800 13/1/09, Scott Xe wrote: It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Thanks and regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to LT;mailto:emc-p...@ieee.orgemc-p...@ieee.orgGT; All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstchttp://www.ieeecommunities.org/emc -pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.htmlhttp://listserv.ieee.org/ request/user-guide.html List rules: http://www.ieee-pses.org/listrules.htmlhttp://www.ieee-pses.org/listrules .html For help, send mail to the list administrators: Scott Douglas LT;mailto:emcp...@ptcnh.netemcp...@ptcnh.netGT; Mike Cantwell LT;mailto:mcantw...@ieee.orgmcantw...@ieee.orgGT; For policy questions, send mail to: Jim Bacher LT;mailto:j.bac...@ieee.orgj.bac...@ieee.orgGT; David Heald LT;mailto:dhe...@gmail.comdhe...@gmail.comGT; - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: Electrical product recall
Hi Ron, Thanks for your useful information and helpful guidance. What is a compliance engineer? Is it responsible for ensuring the products in compliance with all legal requirements? Scott From: Pickard, Ron [mailto:ron.pick...@intermec.com] Sent: 2009年1月13日 03:54 AM To: Nick Williams; Scott Xe Cc: emc-p...@ieee.org Subject: RE: Electrical product recall Nick, The operational guidelines link for businesses (for dangerous consumer products) to which you refer is at: htt ://ec.europa.eu/consumers/safety/rapex/guidelines_business_en.htm. It's stated to be new there, but the actual linked document is dated 2004, so I guess we’ll have to wait for the revised edition. Scott, As others from the hoards of us legally unwashed have given sound advice and good references for your company to develop a recall plan, the recall plan that your company develops may likely have to pass scrutiny with your legal dept/management and some likely legal/contractual issues. Also, googling “safety recall plan” should give you several links for you to understand what a recall plan will look like and how to develop one. I hope you find this useful, but please note that I am a compliance engineer and in no way resemble a lawyer, attorney, barrister, counsel(or), legal eagle, ambulance chaser, etc, etc. Therefore, the above is not legal advice and should not be considered as such. If it was, I would be charging you at least $500/hr (with a retainer). Best regards, Ron Pickard ron.pick...@intermec.com mailto:ron.pick...@intermec.com From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: Monday, January 12, 2009 1:06 PM To: Scott Xe Cc: emc-p...@ieee.org Subject: Re: Electrical product recall There is information at the following sites which will be of assistance to you: http://ec.europa.eu/consumers/safety/rapex/index_en.htm http://www.berr.gov.uk/whatwedo/consume s/Safety/products/unsafe-notification/index.html Somewhere in this lot there is a guidance document which provides a basis for an assessment of whether a recall is necessary. I can send you a copy if you cannot find it in the links on the above pages. At a seminar in November last year, we were told that this guidance is being revised and a new model for assessment has been agreed. Heaven only knows if/when this might make it out into the public domain. Nick. At 00:45 +0800 13/1/09, Scott Xe wrote: It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Thanks and regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to LT;mailto:emc-p...@ieee.orgemc-p...@ieee.orgGT; All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-ps chttp://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user guide.htmlhttp://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.ht lhttp://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas LT;mailto:emcp...@ptcnh.netemcp...@ptcnh.netGT; Mike Cantwell LT;mailto:mcantw...@ieee.orgmcantw...@ieee.orgGT; For policy questions, send mail to: Jim Bacher LT;mailto:j.bac...@ieee.orgj.bac...@ieee.orgGT; David Heald LT;mailto:dhe...@gmail.comdhe...@gmail.comGT; - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions
RE: Electrical product recall
Ted Brian, Thanks for good information. Scott From: Ted Eckert [mailto:ted.eck...@microsoft.com] Sent: 2009年1月13日 01:09 AM To: Scott Xe; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Electrical product recall Hello Scott, The US Consumer Product Safety Commission has guidance on recalls. The following link has the CPSC Recall Handbook, a Recall Checklist and a link to assistance from non-CPSC sources. http://www.cpsc.gov/businfo/corrective.html I also recommend that compliance engineers have at least a basic understanding of product liability law. I recently participated in a workshop from Perkins Coie that I highly recommend, although I am sure there are other very good programs available. http://www.perkinscoie.com/events/eventslist.aspx?Upcoming=true In general, you need good legal advice and you should work with legal counsel well versed in this area of practice. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. I am an engineer and not an attourney; information provided is for general reference only. From: Scott Xe [mailto:scott...@gmail.com] Sent: Monday, January 12, 2009 8:46 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Electrical product recall It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Thanks and regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
RE: Electrical product recall
John, I have received the useful information and guidelines from Rapex for Europe CPSC for USA for my start and appreciate all the responses from the group. Scott From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: 2009?~1??13?? 09:00 PM To: emc-p...@ieee.org Subject: Re: Electrical product recall In message 496c8c92.09876e0a.1d10.7...@mx.google.com, dated Tue, 13 Jan 2009, Scott Xe scott...@gmail.com writes: My primary concern is for Europe. It seems US has lots of information/guidelines. People have already posted details of the European system. Do you need any further information? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Things can always get better. But that's not the only option. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: Electrical product recall
In message 496c9a27.04686e0a.0f20.b...@mx.google.com, dated Tue, 13 Jan 2009, Scott Xe scott...@gmail.com writes: What is a compliance engineer? Is it responsible for ensuring the products in compliance with all legal requirements? Most probably, although a compliance engineer and a mass engineer would resonate beautifully. (;-) -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Things can always get better. But that's not the only option. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: Electrical product recall request
Scott et al, To answer your question, typical of the case that most, if not all, of the subscribers of this forum can attest, electronic products are subject to government and industry regulations concerning product safety, electromagnetic noise radiation/immunity and wireless/wired telecommunication. Compliance engineering is a term to describe the engineering activities to ensure that products conform to these regulations. Mostly compliance engineering focuses its attention on published regulatory and industry standards, ensuring that products are in compliance with those regulations. Regulatory standards are those adopted by national governments and are almost exclusively mandatory. Industry standards (Bluetooth, GSM, UMTS, Wibree, RS-xxx, EIA/TIA, etc.) are those standards where compliance may be needed but are not legally mandatory. And in some instances, such as the EU and the US, there is a need to review and interpret government legislation such as the EU’s Directives and the US’s Code of Federal Regulations. In that aspect, compliance engineering does mimic the legal profession. In the limited amount of time that I have today, I wanted to quickly answer your question in a nutshell and hope that the above has adequately answered your question. And, if anyone cares to interject, add or correct the above in any way, please do. Best regards, Ron Pickard ron.pick...@intermec.com mailto:ron.pick...@intermec.com From: Scott Xe [mailto:scott...@gmail.com] Sent: Tuesday, January 13, 2009 7:42 AM To: Pickard, Ron; 'Nick Williams' Cc: emc-p...@ieee.org Subject: RE: Electrical product recall Hi Ron, Thanks for your useful information and helpful guidance. What is a compliance engineer? Is it responsible for ensuring the products in compliance with all legal requirements? Scott From: Pickard, Ron [mailto:ron.pick...@intermec.com] Sent: 2009年1月13日 03:54 AM To: Nick Williams; Scott Xe Cc: emc-p...@ieee.org Subject: RE: Electrical product recall Nick, The operational guidelines link for businesses (for dangerous consumer products) to which you refer is at: htt ://ec.europa.eu/consumers/safety/rapex/guidelines_business_en.htm. It's stated to be new there, but the actual linked document is dated 2004, so I guess we’ll have to wait for the revised edition. Scott, As others from the hoards of us legally unwashed have given sound advice and good references for your company to develop a recall plan, the recall plan that your company develops may likely have to pass scrutiny with your legal dept/management and some likely legal/contractual issues. Also, googling “safety recall plan” should give you several links for you to understand what a recall plan will look like and how to develop one. I hope you find this useful, but please note that I am a compliance engineer and in no way resemble a lawyer, attorney, barrister, counsel(or), legal eagle, ambulance chaser, etc, etc. Therefore, the above is not legal advice and should not be considered as such. If it was, I would be charging you at least $500/hr (with a retainer). Best regards, Ron Pickard ron.pick...@intermec.com mailto:ron.pick...@intermec.com From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: Monday, January 12, 2009 1:06 PM To: Scott Xe Cc: emc-p...@ieee.org Subject: Re: Electrical product recall There is information at the following sites which will be of assistance to you: http://ec.europa.eu/consumers/safety/rapex/index_en.htm http://www.berr.gov.uk/whatwedo/consume s/Safety/products/unsafe-notification/index.html Somewhere in this lot there is a guidance document which provides a basis for an assessment of whether a recall is necessary. I can send you a copy if you cannot find it in the links on the above pages. At a seminar in November last year, we were told that this guidance is being revised and a new model for assessment has been agreed. Heaven only knows if/when this might make it out into the public domain. Nick. At 00:45 +0800 13/1/09, Scott Xe wrote: It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Thanks and regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to LT;mailto:emc-p...@ieee.orgemc-p...@ieee.orgGT; All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-ps chttp://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/http://www.ieee-pses.org
RE: Electrical product recall request
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Pickard, Ron Sent: Tuesday, January 13, 2009 6:56 AM To: Scott Xe Cc: emc-p...@ieee.org Subject: RE: Electrical product recall request Scott et al, Compliance engineering is a term to describe the engineering activities to ensure that products conform to these regulations. In that aspect, compliance engineering does mimic the legal profession. Ron Pickard Ron: In companies where there is a specifically designated Compliance Engineer, what do you see as the trend in the depth of knowledge of such an engineer? Does this person hold technical responsibility for issues of safety, EMC, ROHS, etc, as you would expect of an engineer? Or is the scope so broad that the person acts more like a manager or coordinator of other specialists (designers and possibly outside vendors), more toward the lawyer end of the scale? Regards, Ed Price ed.pr...@cubic.com blocked::mailto:ed.pr...@cubic.com WB6WSN NARTE Certified EMC Engineer Electromagnetic Compatibility Lab Cubic Defense Applications San Diego, CA USA 858-505-2780 Military Avionics EMC Is Our Specialty - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
Re: Electrical product recall request
In message 9d04b979323dcd428297dda95108893e0120c...@bb-corp-ex2.corp.cubic.cub, dated Tue, 13 Jan 2009, Price, Edward ed.pr...@cubic.com writes: In companies where there is a specifically designated Compliance Engineer, what do you see as the trend in the depth of knowledge of such an engineer? Does this person hold technical responsibility for issues of safety, EMC, ROHS, etc, as you would expect of an engineer? Such an arrangement is very likely to lead to conflict over safety and EMC issues between the Compliance Engineer and the product design engineers. Safety and EMC should be *designed in*, and I think most here would agree, so the responsibility for compliance should rest with the designers. The Compliance Engineer manages the compliance testing and the training and updating of the design engineers as standards change (and maybe improve!). Or is the scope so broad that the person acts more like a manager or coordinator of other specialists (designers and possibly outside vendors), more toward the lawyer end of the scale? With regard to RoHS and WEEE, yes, the Compliance Engineer has to ensure that designers, purchasers, quality managers and suppliers are aware of the requirements and to ensure that systems are in place to prevent violations. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Things can always get better. But that's not the only option. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: Electrical product recall
Hello Scott, The US Consumer Product Safety Commission has guidance on recalls. The following link has the CPSC Recall Handbook, a Recall Checklist and a link to assistance from non-CPSC sources. http://www.cpsc.gov/businfo/corrective.html I also recommend that compliance engineers have at least a basic understanding of product liability law. I recently participated in a workshop from Perkins Coie that I highly recommend, although I am sure there are other very good programs available. http://www.perkinscoie.com/events/eventslist.aspx?Upcoming=true In general, you need good legal advice and you should work with legal counsel well versed in this area of practice. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. I am an engineer and not an attourney; information provided is for general reference only. From: Scott Xe [mailto:scott...@gmail.com] Sent: Monday, January 12, 2009 8:46 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Electrical product recall It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Thanks and regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
RE: Electrical product recall
http://www.cpsc.gov/BUSINFO/8002.html http://www.fda.gov/ora/compliance_ref/rpm/pdf/ch7.pdf http://www.tga.gov.au/docs/pdf/urptg.pdf Also review your signed corporate agreements with safety agencies, NBs, NRTLs, etc. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Scott Xe Sent: Monday, January 12, 2009 8:46 AM To: emc-p...@ieee.org Subject: Electrical product recall It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Thanks and regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: Electrical product recall
In message 496b73b1.04686e0a.6145.c...@mx.google.com, dated Tue, 13 Jan 2009, Scott Xe scott...@gmail.com writes: It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Are you concerned with product recall in Europe? The rules are different form those in USA, of course, just to make things exciting. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Things can always get better. But that's not the only option. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: Electrical product recall
There is information at the following sites which will be of assistance to you: http://ec.europa.eu/consumers/safety/rapex/index_en.htm http://www.berr.gov.uk/whatwedo/consumers/Safety/products/unsafe-notification/index.html Somewhere in this lot there is a guidance document which provides a basis for an assessment of whether a recall is necessary. I can send you a copy if you cannot find it in the links on the above pages. At a seminar in November last year, we were told that this guidance is being revised and a new model for assessment has been agreed. Heaven only knows if/when this might make it out into the public domain. Nick. At 00:45 +0800 13/1/09, Scott Xe wrote: It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Thanks and regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to LT;mailto:emc-p...@ieee.orgemc-p...@ieee.orgGT; All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstchttp://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.htmlhttp://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.htmlhttp://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas LT;mailto:emcp...@ptcnh.netemcp...@ptcnh.netGT; Mike Cantwell LT;mailto:mcantw...@ieee.orgmcantw...@ieee.orgGT; For policy questions, send mail to: Jim Bacher LT;mailto:j.bac...@ieee.orgj.bac...@ieee.orgGT; David Heald LT;mailto:dhe...@gmail.comdhe...@gmail.comGT; - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: Electrical product recall
Nick, The operational guidelines link for businesses (for dangerous consumer products) to which you refer is at: htt ://ec.europa.eu/consumers/safety/rapex/guidelines_business_en.htm. It's stated to be new there, but the actual linked document is dated 2004, so I guess we’ll have to wait for the revised edition. Scott, As others from the hoards of us legally unwashed have given sound advice and good references for your company to develop a recall plan, the recall plan that your company develops may likely have to pass scrutiny with your legal dept/management and some likely legal/contractual issues. Also, googling “safety recall plan” should give you several links for you to understand what a recall plan will look like and how to develop one. I hope you find this useful, but please note that I am a compliance engineer and in no way resemble a lawyer, attorney, barrister, counsel(or), legal eagle, ambulance chaser, etc, etc. Therefore, the above is not legal advice and should not be considered as such. If it was, I would be charging you at least $500/hr (with a retainer). Best regards, Ron Pickard ron.pick...@intermec.com mailto:ron.pick...@intermec.com From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: Monday, January 12, 2009 1:06 PM To: Scott Xe Cc: emc-p...@ieee.org Subject: Re: Electrical product recall There is information at the following sites which will be of assistance to you: http://ec.europa.eu/consumers/safety/rapex/index_en.htm http://www.berr.gov.uk/whatwedo/consume s/Safety/products/unsafe-notification/index.html Somewhere in this lot there is a guidance document which provides a basis for an assessment of whether a recall is necessary. I can send you a copy if you cannot find it in the links on the above pages. At a seminar in November last year, we were told that this guidance is being revised and a new model for assessment has been agreed. Heaven only knows if/when this might make it out into the public domain. Nick. At 00:45 +0800 13/1/09, Scott Xe wrote: It is a quite common terms in the industry and mostly related to safety hazard. We would like to establish a process for the product recall. Is there any important rules or guidance to follow for a meaningful and absolutely necessary recall? Thanks and regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to LT;mailto:emc-p...@ieee.orgemc-p...@ieee.orgGT; All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-ps chttp://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user guide.htmlhttp://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.ht lhttp://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas LT;mailto:emcp...@ptcnh.netemcp...@ptcnh.netGT; Mike Cantwell LT;mailto:mcantw...@ieee.orgmcantw...@ieee.orgGT; For policy questions, send mail to: Jim Bacher LT;mailto:j.bac...@ieee.orgj.bac...@ieee.orgGT; David Heald LT;mailto:dhe...@gmail.comdhe...@gmail.comGT; - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
