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:[email protected]> [email protected] +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 <[email protected]> Sent: 16 October 2021 11:21 To: [email protected] 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:[email protected]> [email protected]> Sent: 16 October 2021 10:36 To: <mailto:[email protected]> [email protected] 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:[email protected]> [email protected]> Sent: 15 October 2021 19:34 To: <mailto:[email protected]> [email protected] 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. 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To post a message to the list, send your e-mail to <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
