Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

2021-10-18 Thread John E Allen 
Doug and friends

 

The thought that comes (and has for a very long time!) to mind then relates to 
the detailed wording of the contract between the company and the contractor – 
and more specifically the consultant because the contractor is actually on the 
company payroll, whereas the consultant is generally not.

 

>From the company’s perspective, it might want to try to pin all legal (and 
>financial) responsibility for the completeness and correctness of resultant 
>documentation on the contract/consultant.

 

OTOH, from the contractor’s/consultant’s perspective, the above would be the 
very last thing that he/she would want to happen because of the legal 
implications of “getting it wrong” as the possible financial /maybe criminal 
liabilities could be literally be “life-changing”. 

 

Unfortunately however, the contractor/consultant may be in the very difficult 
position of having to decide whether to sign the contract and take the risk – 
or decline to take the work, and thus lose the income stream. 

 

In my case, , I went in with my eyes “fairly open” but certainly didn’t realise 
the “difficulties” that I would be facing, particularly in the last contracting 
job, because the company hadn’t really understood the extent to which it’s 
systems didn’t “make the grade”. OTOH, I did make sure that I had pretty 
substantial liability insurance cover - and I kept paying for that for at least 
a year after I left (at which point, the company compliance systems were in a 
much better state of affairs than when I had arrived) !.

 

Thus, to return somewhat to my initial comment about that para in the article, 
there are risks on both sides, and everyone involved really needs to understand 
them and the possible consequences if “things go wrong” – but unfortunately, 
that is rarely the case, especially when a company takes the gist of that para 
as being “all one has to do is….”

 

John E Allen

W. London, UK 

 

 

From: Douglas Nix <0bb8ff993b10-dmarc-requ...@listserv.ieee.org> 
Sent: 18 October 2021 16:56
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

 

I could not agree more. As a consultant, the best we can do is address the 
obvious problems, the subtle ones that may exist with in an organization are 
unlikely to be revealed during most consulting engagements, no matter how good 
a consultant you are.

 

Doug Nix
d...@mac.com <mailto:d...@mac.com> 
+1.519.729.5704

“The best way to predict your future is to create it” — Peter F. Drucker

 

 





On 16-Oct-21, at 05:35, John E Allen 
<09cc677f395b-dmarc-requ...@listserv.ieee.org 
<mailto:09cc677f395b-dmarc-requ...@listserv.ieee.org> > wrote:

 

Good morning all.

 

I printed out the article, read it quite closely and can only agree with 95%+ 
of what the author wrote – the notable exception being the paragraph on the 1st 
page beginning “CE is all about …”

 

Like many of you guys, whilst in “gainful employment” I did a LOT of “CE 
compliance” work for various companies, generally as an employee - but 
sometimes as a contractor/ consultant and, from my own experience, I can say 
that employing one of the latter to do the work is potentially a very “risky” 
approach!

 

As most of us know (or should by now!), it is the company’s, not the 
contractor’s /consultant’s,  legal responsibility to ensure that the CE 
compliance files are complete and correct and do demonstrate that the legal 
requirements have been met – and there’s the big risk in employing a 
contractors/consultant to do the legwork to create them.

 

Unless that person has been working for the company for long enough to really 
know and understand how the company systems work – especially in the areas of 
design, development and materials control & manufacturing – then he/she won’t 
know the “whole story” behind the product & project. Therefore he/she is very 
likely to miss critical issues that could affect whether the final compliance 
documentation actually reflects the way in which the product has been designed 
& built and whether it actually meets the requirements of the “CE compliance” 
regulations & standards. 

 

Most contractors/consultants that are brought into a company for a specific 
time/cost constrained compliance project won’t know “all of that”, and 
therefore the company is at risk of signing off on faulty documentation and 
leaving themselves open to possible legal action in the future…….

 

John E Allen

W. London, UK

From: Richard Nute mailto:ri...@ieee.org> > 
Sent: 15 October 2021 19:34
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

 

<<...>> 

I found this article to be very interesting.  It may be useful to you.

Stay safe, and best regards,

Rich

 

-
-

Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

2021-10-18 Thread Douglas Nix 
I could not agree more. As a consultant, the best we can do is address the 
obvious problems, the subtle ones that may exist with in an organization are 
unlikely to be revealed during most consulting engagements, no matter how good 
a consultant you are.
 
Doug Nix
d...@mac.com
+1.519.729.5704

“The best way to predict your future is to create it” — Peter F. Drucker



> On 16-Oct-21, at 05:35, John E Allen 
> <09cc677f395b-dmarc-requ...@listserv.ieee.org> wrote:
> 
> Good morning all.
>  
> I printed out the article, read it quite closely and can only agree with 95%+ 
> of what the author wrote – the notable exception being the paragraph on the 
> 1st page beginning “CE is all about …”
>  
> Like many of you guys, whilst in “gainful employment” I did a LOT of “CE 
> compliance” work for various companies, generally as an employee - but 
> sometimes as a contractor/ consultant and, from my own experience, I can say 
> that employing one of the latter to do the work is potentially a very “risky” 
> approach!
>  
> As most of us know (or should by now!), it is the company’s, not the 
> contractor’s /consultant’s,  legal responsibility to ensure that the CE 
> compliance files are complete and correct and do demonstrate that the legal 
> requirements have been met – and there’s the big risk in employing a 
> contractors/consultant to do the legwork to create them.
>  
> Unless that person has been working for the company for long enough to really 
> know and understand how the company systems work – especially in the areas of 
> design, development and materials control & manufacturing – then he/she won’t 
> know the “whole story” behind the product & project. Therefore he/she is very 
> likely to miss critical issues that could affect whether the final compliance 
> documentation actually reflects the way in which the product has been 
> designed & built and whether it actually meets the requirements of the “CE 
> compliance” regulations & standards. 
>  
> Most contractors/consultants that are brought into a company for a specific 
> time/cost constrained compliance project won’t know “all of that”, and 
> therefore the company is at risk of signing off on faulty documentation and 
> leaving themselves open to possible legal action in the future…….
>  
> John E Allen
> W. London, UK
> From: Richard Nute mailto:ri...@ieee.org>> 
> Sent: 15 October 2021 19:34
> To: EMC-PSTC@LISTSERV.IEEE.ORG 
> Subject: [PSES] Safety Compliance Testing: It's A Business, So Shop Around
>  
> <<...>> 
> I found this article to be very interesting.  It may be useful to you.
> Stay safe, and best regards,
> Rich
>  
> -
> 
> 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 
> mailto:emc-p...@ieee.org>>
> All emc-pstc postings are archived and searchable on the web at: 
> http://www.ieee-pses.org/emc-pstc.html 
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at 
> http://product-compliance.oc.ieee.org/ 
>  can be used for graphics (in 
> well-used formats), large files, etc.
> Website: http://www.ieee-pses.org/ 
> Instructions: http://www.ieee-pses.org/list.html (including how to 
> unsubscribe) 
> List rules: http://www.ieee-pses.org/listrules.html 
> 
> For help, send mail to the list administrators:
> Scott Douglas mailto:sdoug...@ieee.org>>
> Mike Cantwell mailto:mcantw...@ieee.org>> 
> For policy questions, send mail to:
> Jim Bacher mailto:j.bac...@ieee.org>>
> David Heald mailto: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 
> mailto:emc-p...@ieee.org>>
> 
> All emc-pstc postings are archived and searchable on the web at: 
> http://www.ieee-pses.org/emc-pstc.html 
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at 
> http://product-compliance.oc.ieee.org/ 
>  can be used for graphics (in 
> well-used formats), large files, etc.
> 
> Website:  http://www.ieee-pses.org/ 
> Instructions:  http://www.ieee-pses.org/list.html (including how to 
> unsubscribe) 
> List rules:  http://www.ieee-pses.org/listrules.html 
> 
> For help, send mail to the list administrators:
> Scott Douglas mailto:sdoug...@ieee.org>>
> Mike Cantwell mailto:mcantw...@ieee.org>>
> 
> For policy questions, send mail to:
> Jim Bacher

Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

2021-10-18 Thread John E Allen 
Morning all

 

FWIW, I’ve sent James a (edited!) version of the questionnaire that I prepared 
many years ago to get a “feel” for how much a company, with which I was 
thinking of doing some compliance contracting, knew about “CE compliance”  and 
how prepared they were – or were not!

 

He’s going to take a good look at it in a few weeks’ time, and then, maybe, 
I’ll share any resultant version with forum members (since I won’t be using it 
myself, having been retired for so long – OTOH, if anyone wants to “call me 
back in” then I might still be interested in doing that ).

 

John E Allen

W. London, UK

 

 

 

From: James Pawson (U3C)  
Sent: 18 October 2021 09:30
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

 

Hello John,

 

These are excellent points. I was going to say that I’ve not come across this 
attitude with many of my customers but then the question popped into my head of 
“how do I know that for sure?”

 

What questions would you typically ask of your clients to understand their 
attitude to their business and their risk tolerance?

 

I’ll often ask customers about what their previous experience with compliance 
is, how they have handled it for other products, and to see an example 
Technical File equivalent for a previous product. This helps me understand what 
their internal processes are.

 

Some instructive chats are often had with the equivalent of the Service Manager 
to get an understanding of any field related compliance problems that sometimes 
don’t make it back to the design team.

 

I’ve tended to find (with occasional exceptions) that appetite for compliance 
risk is inversely proportional to size of company, which makes sense when you 
consider the mindset of someone starting a business vs an established company 
with more to lose.

 

(Sidebar: There was a recent  
<https://www.gov.uk/government/publications/safety-regulations-compliance-study>
 study that compared the effect of penalty rates, accessibility of info on the 
penalty scheme, and income of business with compliance rates in a simulated 
setting. Given the simulated setting I’m not sure what useful information you 
can draw from this. For example, I don’t play board games like I play business. 
My wife and friends would all have better EMC consultancies than me if this 
were the case!)

 

Looking forward to hearing your thoughts

All the best

James

 

 

 

 

James Pawson

The EMC Problem Solver

 

Unit 3 Compliance Ltd

EMC : Environmental : Safety : CE + UKCA : Consultancy

 

 <http://www.unit3compliance.co.uk/> www.unit3compliance.co.uk  |   
<mailto:ja...@unit3compliance.co.uk> ja...@unit3compliance.co.uk 

+44(0)1274 911747  |  +44(0)7811 139957

2 Wellington Business Park, New Lane, Bradford, BD4 8AL

Registered in England and Wales # 10574298

 

 

From: John E Allen <09cc677f395b-dmarc-requ...@listserv.ieee.org> 
Sent: 16 October 2021 11:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

 

& PS: Something I should have mentioned about how some companies treat their 
contractors /consultants doing this sort of work.

 

Like mushrooms they are often “kept in the dark and fed on “you know what”!”, 
i.e. the companies don’t (often just plain “can’t”) provide the contractor 
/consultant with all the info that should be in the compliance files -> GIGO 
situation!

John E Allen

W. London, UK

 

From: John E Allen < <mailto:09cc677f395b-dmarc-requ...@listserv.ieee.org> 
09cc677f395b-dmarc-requ...@listserv.ieee.org> 
Sent: 16 October 2021 10:36
To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

 

Good morning all.

 

I printed out the article, read it quite closely and can only agree with 95%+ 
of what the author wrote – the notable exception being the paragraph on the 1st 
page beginning “CE is all about …”

 

Like many of you guys, whilst in “gainful employment” I did a LOT of “CE 
compliance” work for various companies, generally as an employee - but 
sometimes as a contractor/ consultant and, from my own experience, I can say 
that employing one of the latter to do the work is potentially a very “risky” 
approach!

 

As most of us know (or should by now!), it is the company’s, not the 
contractor’s /consultant’s,  legal responsibility to ensure that the CE 
compliance files are complete and correct and do demonstrate that the legal 
requirements have been met – and there’s the big risk in employing a 
contractors/consultant to do the legwork to create them.

 

Unless that person has been working for the company for long enough to really 
know and understand how the company systems work – especially in the areas of 
design, development and materials control & manufacturing – then he/she won’t

Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

2021-10-18 Thread James Pawson (U3C) 
Hello John,

 

These are excellent points. I was going to say that I've not come across
this attitude with many of my customers but then the question popped into my
head of "how do I know that for sure?"

 

What questions would you typically ask of your clients to understand their
attitude to their business and their risk tolerance?

 

I'll often ask customers about what their previous experience with
compliance is, how they have handled it for other products, and to see an
example Technical File equivalent for a previous product. This helps me
understand what their internal processes are.

 

Some instructive chats are often had with the equivalent of the Service
Manager to get an understanding of any field related compliance problems
that sometimes don't make it back to the design team.

 

I've tended to find (with occasional exceptions) that appetite for
compliance risk is inversely proportional to size of company, which makes
sense when you consider the mindset of someone starting a business vs an
established company with more to lose.

 

(Sidebar: There was a recent study
<https://www.gov.uk/government/publications/safety-regulations-compliance-st
udy>  that compared the effect of penalty rates, accessibility of info on
the penalty scheme, and income of business with compliance rates in a
simulated setting. Given the simulated setting I'm not sure what useful
information you can draw from this. For example, I don't play board games
like I play business. My wife and friends would all have better EMC
consultancies than me if this were the case!)

 

Looking forward to hearing your thoughts

All the best

James

 

 

 

 

James Pawson

The EMC Problem Solver

 

Unit 3 Compliance Ltd

EMC : Environmental : Safety : CE + UKCA : Consultancy

 

 <http://www.unit3compliance.co.uk/> www.unit3compliance.co.uk  |
<mailto:ja...@unit3compliance.co.uk> ja...@unit3compliance.co.uk 

+44(0)1274 911747  |  +44(0)7811 139957

2 Wellington Business Park, New Lane, Bradford, BD4 8AL

Registered in England and Wales # 10574298

 

 

From: John E Allen <09cc677f395b-dmarc-requ...@listserv.ieee.org> 
Sent: 16 October 2021 11:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety Compliance Testing: It's A Business, So Shop
Around

 

& PS: Something I should have mentioned about how some companies treat their
contractors /consultants doing this sort of work.

 

Like mushrooms they are often "kept in the dark and fed on "you know
what"!", i.e. the companies don't (often just plain "can't") provide the
contractor /consultant with all the info that should be in the compliance
files -> GIGO situation!

John E Allen

W. London, UK

 

From: John E Allen <
<mailto:09cc677f395b-dmarc-requ...@listserv.ieee.org>
09cc677f395b-dmarc-requ...@listserv.ieee.org> 
Sent: 16 October 2021 10:36
To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety Compliance Testing: It's A Business, So Shop
Around

 

Good morning all.

 

I printed out the article, read it quite closely and can only agree with
95%+ of what the author wrote - the notable exception being the paragraph on
the 1st page beginning "CE is all about ."

 

Like many of you guys, whilst in "gainful employment" I did a LOT of "CE
compliance" work for various companies, generally as an employee - but
sometimes as a contractor/ consultant and, from my own experience, I can say
that employing one of the latter to do the work is potentially a very
"risky" approach!

 

As most of us know (or should by now!), it is the company's, not the
contractor's /consultant's,  legal responsibility to ensure that the CE
compliance files are complete and correct and do demonstrate that the legal
requirements have been met - and there's the big risk in employing a
contractors/consultant to do the legwork to create them.

 

Unless that person has been working for the company for long enough to
really know and understand how the company systems work - especially in the
areas of design, development and materials control & manufacturing - then
he/she won't know the "whole story" behind the product & project. Therefore
he/she is very likely to miss critical issues that could affect whether the
final compliance documentation actually reflects the way in which the
product has been designed & built and whether it actually meets the
requirements of the "CE compliance" regulations & standards. 

 

Most contractors/consultants that are brought into a company for a specific
time/cost constrained compliance project won't know "all of that", and
therefore the company is at risk of signing off on faulty documentation and
leaving themselves open to possible legal action in the future...

 

John E Allen

W. London, UK

From: Richard Nute < <mailto:ri...@ieee.org&

Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

2021-10-16 Thread John E Allen 
& PS: Something I should have mentioned about how some companies treat their
contractors /consultants doing this sort of work.

 

Like mushrooms they are often "kept in the dark and fed on "you know
what"!", i.e. the companies don't (often just plain "can't") provide the
contractor /consultant with all the info that should be in the compliance
files -> GIGO situation!



John E Allen

W. London, UK

 

From: John E Allen <09cc677f395b-dmarc-requ...@listserv.ieee.org> 
Sent: 16 October 2021 10:36
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety Compliance Testing: It's A Business, So Shop
Around

 

Good morning all.

 

I printed out the article, read it quite closely and can only agree with
95%+ of what the author wrote - the notable exception being the paragraph on
the 1st page beginning "CE is all about ."

 

Like many of you guys, whilst in "gainful employment" I did a LOT of "CE
compliance" work for various companies, generally as an employee - but
sometimes as a contractor/ consultant and, from my own experience, I can say
that employing one of the latter to do the work is potentially a very
"risky" approach!

 

As most of us know (or should by now!), it is the company's, not the
contractor's /consultant's,  legal responsibility to ensure that the CE
compliance files are complete and correct and do demonstrate that the legal
requirements have been met - and there's the big risk in employing a
contractors/consultant to do the legwork to create them.

 

Unless that person has been working for the company for long enough to
really know and understand how the company systems work - especially in the
areas of design, development and materials control & manufacturing - then
he/she won't know the "whole story" behind the product & project. Therefore
he/she is very likely to miss critical issues that could affect whether the
final compliance documentation actually reflects the way in which the
product has been designed & built and whether it actually meets the
requirements of the "CE compliance" regulations & standards. 

 

Most contractors/consultants that are brought into a company for a specific
time/cost constrained compliance project won't know "all of that", and
therefore the company is at risk of signing off on faulty documentation and
leaving themselves open to possible legal action in the future...

 

John E Allen

W. London, UK

From: Richard Nute mailto:ri...@ieee.org> > 
Sent: 15 October 2021 19:34
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

 

<<...>> 

I found this article to be very interesting.  It may be useful to you.

Stay safe, and best regards,

Rich

 

-


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
mailto:emc-p...@ieee.org> >

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at
http://product-compliance.oc.ieee.org/ can be used for graphics (in
well-used formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to
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David Heald mailto:dhe...@gmail.com> > 

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discussion list. To post a message to the list, send your e-mail to
mailto:emc-p...@ieee.org> >

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at
http://product-compliance.oc.ieee.org/ can be used for graphics (in
well-used formats), large files, etc.

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David Heald mailto:dhe...@gmail.com> > 


-
---

Re: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

2021-10-16 Thread John E Allen 
Good morning all.

 

I printed out the article, read it quite closely and can only agree with
95%+ of what the author wrote - the notable exception being the paragraph on
the 1st page beginning "CE is all about ."

 

Like many of you guys, whilst in "gainful employment" I did a LOT of "CE
compliance" work for various companies, generally as an employee - but
sometimes as a contractor/ consultant and, from my own experience, I can say
that employing one of the latter to do the work is potentially a very
"risky" approach!

 

As most of us know (or should by now!), it is the company's, not the
contractor's /consultant's,  legal responsibility to ensure that the CE
compliance files are complete and correct and do demonstrate that the legal
requirements have been met - and there's the big risk in employing a
contractors/consultant to do the legwork to create them.

 

Unless that person has been working for the company for long enough to
really know and understand how the company systems work - especially in the
areas of design, development and materials control & manufacturing - then
he/she won't know the "whole story" behind the product & project. Therefore
he/she is very likely to miss critical issues that could affect whether the
final compliance documentation actually reflects the way in which the
product has been designed & built and whether it actually meets the
requirements of the "CE compliance" regulations & standards. 

 

Most contractors/consultants that are brought into a company for a specific
time/cost constrained compliance project won't know "all of that", and
therefore the company is at risk of signing off on faulty documentation and
leaving themselves open to possible legal action in the future...

 

John E Allen

W. London, UK

From: Richard Nute  
Sent: 15 October 2021 19:34
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Safety Compliance Testing: It's A Business, So Shop Around

 

<<...>> 

I found this article to be very interesting.  It may be useful to you.

Stay safe, and best regards,

Rich

 

-


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
mailto:emc-p...@ieee.org> >

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at
http://product-compliance.oc.ieee.org/ can be used for graphics (in
well-used formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to
unsubscribe)  
List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators:
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Mike Cantwell mailto:mcantw...@ieee.org> > 

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Jim Bacher mailto:j.bac...@ieee.org> >
David Heald mailto: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 


All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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