Hi Folks I disagree strongly with Scott's assessment that the DoC has to be resigned for several very important and pragmatic reasons:
a) To-date I have yet to see any official EU or other substantive document to support his viewpoint. b) People are always "coming and going" - it is a fact of business life, and new personnel inherit the legal responsibilities of the old. (That said, the "old" personnel could still be prosecuted for knowingly breaking the law if they had falsely signed a DoC). c) If Scott's viewpoint were widely held we would all be continuously updating and reissuing our DoC's. In fact we would have little time for anything else - like developing new products! d) The date of the signature then becomes critical - and could force a complete review of the product against the latest versions of the appropriate referenced standard(s). The problem comes if those standards have themselves been updated since the date of the first signature - in which case a product might have to be modified merely because the person signing the original DoC had left the company! The latter proposition is plainly ludicrous and not envisaged in the Directives or in the harmonised standards, which allow you to continue manufacturing an unaltered compliant product for some considerable number of years after the last date you are allowed to certify to a particular issue level of a standard. e) The only realistic and supportable reasons for updating the DoC are thus that : (i) The product itself changes; (ii) The standard(s) change, and you are going to continue manufacturing beyond last date at which it is permissable to to manufacture and certify to the particular issue level of the standard(s); (iii) The company and/or model names/number change. The above opinion is my own, but I can see no reason why we - or any other company - should take any different view. Regards John Allen Product & System Safety Manager Racal Defence Electronics Ltd Bracknell UK ---------- From: Scott Douglas[SMTP:s_doug...@ecrm.com] Sent: 11 November 1999 13:39 To: reyno...@pb.com; emc-p...@ieee.org Subject: RE: D of C - Who Signs? The DoC must be re-signed. Scott s_doug...@ecrm.com ECRM Incorporated Tewksbury, MA USA -----Original Message----- From: reyno...@pb.com [mailto:reyno...@pb.com] Sent: Thursday, November 11, 1999 10:16 AM To: emc-p...@ieee.org Subject: D of C - Who Signs? Importance: Low Hello! Forgive me for asking a possibly dumb question but here goes: If the EU Declaration of Conformity is signed by a responsible/technically competent person who has been nominated on behalf of the company's Directors and then that person leaves the company, does his/her replacement who assumes the same level of responsibility need to go back and re-issue all of the old D of C's with their signature on the document. In other words is it acceptable to issue D of C's to suppliers/customers which have been signed by someone who has left the company. Thankyou in advance. Tony Reynolds Pitney Bowes (UK) Ltd Tel +44 (0) 1279 449479 Fax +44 (0) 1279 449118 e-mail: reyno...@pb.com --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
