Perhaps I was a bit acerbic in my recent response to a T-Reg submittal from Jeff Whitmire, and for that I aplogize. While I was lauded on several fronts for taking up the issue with such veracity, I was also chided for a certain amount of unproffessionalism -- to which I humbly admit. The purpose of this forum is the free exchange of ideas and interpretations, and the benefits to members are evinced by the numerous and interesting educational, theoretical, and at times down-right creative responses to issues raised. I think we can all say "thank you" for that.
However, I make no apologies for the content of my message, and I stand firmly behind my assertion that Competent Bodies, Notified Bodies AND their US affiliates bear a large amount of responsibility to ensure that information provided is not misleading or incorrect. No single interpretation of compliance with any of the New Approach Directives can be said to be indisputable, and there is no "requirement" under any of them to do anything other than fill out a Declaration of Conformity -- Perhaps with a Competent Body certificate or report (Article 10.2, 89/336/EEC), perhaps not -- and affix the CE mark. Everything else is Risk Management, and I submit that one cannot manage one's risk effectively if one doesn't have as much information as can be provided in as close detail as possible. Bias in providing this information toward the use of private test facilities or particular Competent Bodies, or any other services provided by an information source is unacceptable, and yet is rampant. THAT'S THE ISSUE THAT SPARKS MY IRE. Jeff, I aplogize for my recent lack of professionalism. I can only hope that entities respected for their contacts and affiliations with regulatory interpretive bodies in the EU will, in the future, think twice about the VALUE of the information they provide, and deliver on it to the fullest extent possible. My New Year's Resolution: "To restrain myself...a little." Happy Holidays TREGGERS. RT
