There is a problem with "..the reader is guaranteed to get the latest revision as stored in our Document Control system."
The latest drawing has NO RELEVANCE WHATEVER to the CE Marking File. What we are required to record is the "As Built Standard" of the product tested - in terms of its Safety or EMC performance. It is for precisely this reason that UL/CSA/et al use specially written Product Descriptions to allow manufacturing follow-up inspection. Evaluation for safety (and EMC) relates to ONE PRODUCT (the type-test model) - if current production standard deviates significantly (in safety or emc terms) from that original type-test model then re-evaluation is required to limit potential corporate liability. The EU Enforcement office does not need to know what the latest product is supposed to look like - he will have the 'smoking gun' in his hand! If it has injured someone then (under EU Law) it will be classified as unsafe. The issues following this may go something like this: * Was this product properly tested? * Is the product tested the 'same as' the one that caused the injury? * Is this a random problem or are all products like this one? * Do we need to recall all products? If the product was not properly tested then there is a breach of EU and National Law - this may involve actions involving Companies - Products and People (individual prosecutions). If the defect is not random - but due to a significant difference between the TYPE TEST MODEL and the 'Smoking Gun' then it is likely (and I would hope) that a RAPEX report (RAPid Exchange of information) would be filed to Brussels so that all member states can be warned and further injury prevented. The advice I offer is "focus on the principles - reduce risk - reduce liability - preserve evidence - aim for Quality don't design down to the MINIMUM ACCEPTABLE LIMIT". Best regards Gregg -----Original Message----- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Chris Maxwell Sent: Wednesday, December 11, 2002 1:49 PM To: Gary McInturff; Nick Williams; Stephen Irving Cc: emc-p...@majordomo.ieee.org Subject: RE: Location of CE DoCs - electronic copies Gary, I'm with you on this one. I consider electronic availability to be equal to, if not superior to, having the documents on "European Soil". My feeling is that: as long as the documentation explains what the CE mark means; and points the user in the right direction for getting the files; then files can be emailed at a moment's notice; and the reader is guaranteed to get the latest revision as stored in our Document Control system. I don't think that you can make the equivalent statements about any method of keeping paper copies at any location. Of course, these are just my opinions and interpretations. I haven't had to tell them to a judge (does CENELEC have a judge?); but I believe that the reasoning is sound. Chris Maxwell | Design Engineer - Optical Division email chris.maxw...@nettest.com | dir +1 315 266 5128 | fax +1 315 797 8024 NetTest | 6 Rhoads Drive, Utica, NY 13502 | USA web www.nettest.com | tel +1 315 797 4449 | > -----Original Message----- > From: Gary McInturff [SMTP:gary.mcintu...@worldwidepackets.com] > Sent: Wednesday, December 11, 2002 10:38 AM > To: Nick Williams; Stephen Irving > Cc: emc-p...@majordomo.ieee.org > Subject: RE: Location of CE DoCs - electronic copies > > > Does electronic storage of the documents make any difference? The DoC, the test reports, BOM's, drawings and Design verification tests are all stored electronically and can be dumped from any printer in the world. Obviously, they would have electronic signatures. > Gary > > > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
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