From: NAME: BERNARD MCEWEN
FUNC: 10687 Eng Product Certification
TEL: 613-274-6500 <BMCEWEN@A1@K>
To: NAME: MX%"[email protected]"
<MX%"[email protected]"@MRGATE@K@WPC>
Just as "value added" is a beanie buzzword, 'self-' is a
marketing
prefix used as a punter-friendly alternative to admitting that
whatever follows is not provided. E.g. you have to pump your own
petrol in a self-service filling-station, or clear the previous
diner's mess in a self-clearing restaurant.
'Self-certified' is no more an oxymoron than 'not certified' is,
because the word 'self' on its own, doesn't imply 'certified'.
And as for 'self-declaration'; that is plain nonsense. What is
the
difference between a declaration and a self-declaration?
Regards, Bernie.
Hello All
Hello Everyone.
A range of interesting events has delayed my response to this original
thread. It is not my intention to re-open this discussion but rather to
simply close it from my original contirbutions. First, Vic, thanks for the
IEC document number (IEC 2). By drawing out the definition of certification
I was refering to, and its parties, you affirmed that 'self-certification'
is indeed an oxymoron rather than a marketing ploy as Bernie opined. But he
made a very clear point regarding 'self declaration' versus a simple
'declaration'. No difference between them and 'self declaration' simply
adds confusion.
Vic caught this as well and clarified the terminology quite well when he
referred to the Suppliers Declaration though he indicated it as a procedure
when it is really a document. However, the procedure to which a Supplier
Declaration is normally attributed when discussing things from a European
perspective is known as the Internal Production Control module (Module A
among the conformity modules also referred to by Vic.)
Both Vic and Bernie are doing this community a favor when they indicates
that the term self-declaration should not be used, and in using it, I
contributed to the decline of the overall dialogue. I apologize. (See below
for my penalty.)
Having said that, recognize that as the European approach has been unfurled,
the two ideas dealt with here have been the very two that have been
obscured by the largest number of people. The term "self-declaration" arose
as the terminology manufacturers began using when they digested the
Internal Production Control module. Many conformity assessment
organizations joined in this as well perhaps because the European's, in
their zeal to show they were not adding unnecessary burdens, wanted to show
how manufacturer friendly they were when the New Approach legislation was
created. Thus, instead of a default to the use of third parties--often a
source of confusion when market access and market success issues were
mistakenly fused---manufacturers were attracted to the 'own your own
destiny' elements within the directives; hence the term 'self' in advance
of declaration. Thus the concept of 'self' was promulgated both as means to
speed understanding and as a balm for the aching third-party blues.
Vic pointed out another aspect of that which contributed to the confusion:
the misuse of the term 'certificate' in many of the directives. This
confusion led to the term self-certification which was originally
mistakenly used by the German's to refer to a process that was in fact a
suppliers declaration approach. I agree with Vic that something was lost in
the translation since the Germans understand that certification issues
well. However, we have since been stuck with the term self-certification
which simply took the whole discussion further off course. (I still find
remarkably adept conformity professionals using this term.) To derail this
concept, conformity providers often use self-declaration since it provides
map to which most people can quickly jump when starting from 'self
certification.' It is still one step removed from the real issues as Vic
clearly pointed out.
And of course, it certainly did not help that EU legislators referred to CE
marking as the CE Mark thereby infering that certification was involved in
CE marking which was where all of this began.
Sorry to bore you all, but felt an obligation to clarify these points and
agree with Vic that the usage of self-declaration should also be
eliminated. A supplier's declaration is, in the end, the document of which
we speak, and from a EU perspective, this document is generated under all
directives though in those that call out the Internal Production Control
procedure (Module A), it is the only summary document required. (Of course
this presumes your technical documentation file exists, but that is an
adjacent but separate discussion.)
I have signed up for 50 lashings with a wet, draft Mutual Recognition
Agreement between any two large trading partners and expect to carry out
this self declared penalty by the end of the month.
Regards,
Gene
TUV Product Service
-------------
Original Text
From: "Victor L. Boersma" <[email protected]>, on 4-11-97 11:55 AM:
To: INTERNET:[email protected] <[email protected]>
Comments on Gene Panger's:
ISO/IEC Guide 2 (my copy is 1991) defines "certification" as a procedure by
which "a third party" gives written assurance that a product, process or
service
conforms to specified requirements.
Hence, certification, by international agreement is something a 3rd party
does
and there is
no such thing as "self certification".
In this business there is:
First party = the supplier
Second party = the purchaser
Third party = body or person recognized as being independent from the 1st
and
2nd parties.
What this is all about, is
Assurance of conformity = procedure resulting in a statement giving
confidence
that a
product or service fulfils specified requirements.
There are many ways of doing this, as is recognized in the EC Module
Decision,
which
gives a choice of some 8 possibilities.
One of them is
Suppliers Declaration = procedure by which a supplier gives written
assurance
that a product
or service conforms to specified requirements
There is a note attched to that statement to the effect that
- In order to avoid any confusion, the expression "self-declaration" should
not
be used.
The CE-marking, as I understand it, only means to indicate that somebody
has
done an
investigation and has produced a written declaration of conformity. It is
not
intended to
convey anything to the user, only a tool to refer authorities having
jurisdiction to whomsoever did the decalration of conformity.
Unfortunately, some of the EC Directives confuse the issue by referring to
the
Declaration
of Conformity as a "Certificate". I've got to get myself a copy of those
documents in a language other than English, to see whether we're once again
dealing with English that would
never be approved in North America (where the real English is spoken).
I also understand that there will be a meeting April 15, where a decision
will
be reached on the ENEC mark, which will be pan-European and will give users
a
degree of comfort that a
3rd party has been involved in the evaluation of the product.
All in all, what we're talking about is "giving confidence". Personally,
rightly or wrongly, I trust certain suppliers, usually the BIG names, to do
the
right things or fix it, if they made a mistake. They usually did in the
past.
Hence, a suppliers declaration from one of these BIG names, gives me as
much
confidene as a 3rd party certification. In the end, if something goes
wrong,
the big name firm will fix what went wrong, not the certification
organization.
I also have confidence in the very tiny firm that build my computers. He
has
fixed whatever went wrong, but some of his competitors are no longer in
business. Some of the 3rd party certification houses are no longer in
business.
Some of the BIG name firms are disappearing.
What constitutes "giving confidence". I don't know. I do know that in the
final analysis it becomes more of a touchy-feely thing than something you
can
hang your hat on. Ask me
next why I love and trust my wife. (Is 40 years of living together
sufficient
evidence ?)
Ciao,
Vic
