Have I got an old copy of CFR 47?
I happen to run across this paragraph the other day?. I can't be more than a
year old, as the CD ROM its contained on was purchased around that time.
§2.955 Retention of records.
(a) For each equipment subject to verification, the responsible
party, as shown in §2.909 shall maintain the records listed as follows:
(1) A record of the original design drawings and
specifications and all changes that have been made that may affect
compliance with the requirements of §2.953.
(2) A record of the procedures used for production
inspection and testing (if tests were performed) to insure the conformance
required by §2.953. (Statistical production line emission testing is not
required.)
(3) A record of the measurements made on an appropriate
test site that demonstrates compliance with the applicable regulations in
this chapter. The record shall:
(i) Indicate the actual date all testing was
performed;
(ii) State the name of the test laboratory,
company, or individual performing the verification testing. The Commission
may request additional information regarding the test site, the test
equipment or the qualifications of the company or individual performing the
verification tests;
(iii) Contain a description of how the device was
actually tested, identifying the measurement procedure and test equipment
that was used;
(iv) Contain a description of the equipment under
test (EUT) and support equipment connected to, or installed within, the EUT;
(v) Identify the EUT and support equipment by trade
name and model number and, if appropriate, by FCC Identifier and serial
number;
(vi) Indicate the types and lengths of connecting
cables used and how they were arranged or moved during testing;
(vii) Contain at least two drawings or photographs
showing the test set-up for the highest line conducted emission and showing
the test set-up for the highest radiated emission. These drawings or
photographs must show enough detail to confirm other information contained
in the test report. Any photographs used must be focused originals without
glare or dark spots and must clearly show the test configuration used;
(viii) List all modifications, if any, made to the
EUT by the testing company or individual to achieve compliance with the
regulations in this chapter;
(ix) Include all of the data required to show
compliance with the appropriate regulations in this chapter; and
(x) Contain, on the test report, the signature of
the individual responsible for testing the product along with the name and
signature of an official of the responsible party, as designated in §2.909.
(4) For equipment subject to the provisions in Part 15 of
this chapter, the records shall indicate if the equipment was verified
pursuant to the transition provisions contained in §15.37 of this chapter.
(b) The records listed in paragraph (a) of this section shall be
retained for two years after the manufacture of said equipment item has been
permanently discontinued or until the conclusion of an investigation or a
proceeding if the manufacturer or importer is officially notified that an
investigation or any other administrative proceeding involving his equipment
has been instituted.
-----Original Message-----
From: Ehler, Kyle [SMTP:kyle.eh...@lsil.com]
Sent: Thursday, July 22, 1999 11:32 AM
To: Scott Douglas; 'EMC-PSTC'
Subject: RE: Record Retention
Hi Scott,
A while back I inquired with TUV, UL and FCC about this very
subject.
UL and TUV is pretty loose about manufacturer's recordkeeping of
production
run information, but product safety test data and related filing
information
is expected to be retained for at least seven years after last
production
date according to Kevin Hyland (x42652), the RROP for ITE records at
the
Northbrook office of UL (847 272 8800). For factory records, the
point is
fairly moot as long as a FUS program is in place with quarterly
inspections
conducted which include dielectric and ground bond procedures on
%100 of
production and test equipment start of day checks.
The FCC wants records maintained the same period or longer, but
since the
two are closely related to agency compliance, archiving both EMC and
Safety
data in one place is just good business practice. Our lab is in
process of
getting all but originals into electronic form and packing it onto
CD-Roms.
A dollar a CD-R is a lot less than a zip disk...
Incidentally, UL still maintains records from their first inception.
They
reportedly have product records over 100 years old.
I was investigating this on a proactive basis in efforts to prod our
factory
into keeping more detailed records. The data could be useful in
tracking
break-ins of changes to the manufacturing process in event of a
call-back.
This would make the task of tracing thousands of products in the
field as
simple as associating the serial number list with the customer
shipping
list.
The effort was like pushing a rope uphill -I failed anyway.
Kyle Ehler kyle.eh...@lsil.com <mailto:kyle.eh...@lsil.com>
Ass. Design Engineer
LSI Logic Storage Systems Division
3718 N. Rock Road
U.S.A. Wichita, Kansas 67226
Ph. 316 636 8657
Fax 316 636 8889
Fax 316 636 8315
Kyle Ehler kyle.eh...@lsil.com <mailto:kyle.eh...@lsil.com>
Design Engineer
LSI Logic Storage Systems Division
3718 N. Rock Road
U.S.A. Wichita, Kansas 67226
Ph. 316 636 8657
Fax 316 636 8889
Fax 316 636 8315
-----Original Message-----
From: Scott Douglas [SMTP:s_doug...@ecrm.com]
Sent: Thursday, July 22, 1999 8:35 AM
To: 'EMC-PSTC'
Subject: Record Retention
I have a question about record retention.
We make ITE which incorporates lasers and certify to LVD,
EMC
directives.
We do not create a TCF specifically. We do have outside lab
test
reports
for safety and for EMC. We also have the usual parts lists
and CAD
drawings
for fabrication and assembly along with test procedures. We
do
record all
production tests required for each product shipped.
What documents do we need to keep and how long do we need to
keep
them?
We keep the form where we record production tests required
for
compliance
(hipot, ground continuity, laser safety, etc.) for ten
years. What
engineering drawings, parts lists, test procedures, etc. do
we need
to keep
and for how long? Can anyone point me to a specific
reference that
requires
this?
Thank you in advance for your comments.
Scott
s_doug...@ecrm.com
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