Doug - In addition to the other responses, here's more food for thought.
Theoretically, there's nothing to prevent you from labeling and performing all normal 100% of production testing on the product at your facility, rather than the factory. However, the practicalities of traceability of some parts and components can be extraordinarily onerous, especially for molded or processed polymeric parts, wire harnesses, wire and connectors (all types). For wire, in particular, the labeling on the spool is what is relied upon by auditors for suitability, since no NRTL (that I'm aware of) has certification marks for wire off the spool and surface markings are normally not relied upon for proof of certification. You may be able to work out a paper trail with the NRTL for some parts, with the factory forwarding a sheaf of paper with each lot, but this won't work for everything. In addition, managing noncompliant products could be an enormous headache. Who'd do the rework? What if the rework is extensive? What if the one lot the factory neglects to attach the sheaf of papers is the one the auditor happens to see in you facility? In my view, it's worth the money to put all of this off on the factory(ies). In your hypothetical case, with ten potential factories, it would likely be best to limit the number of factories to a few at any given time and get them under a contract with the NRTL. Even if all of the factories must be included, for whatever reasons, it's probably for the better to get them all under contract, because each factory will have a learning curve to build a product and you can't be certain what you'll receive during regular production will compare in all respects to a first article, where it should expected that more care will be applied than for regular production. Regards, Peter L. Tarver, PE [email protected] > From: Doug McKean > Sent: Sunday, September 04, 2005 7:39 PM > To: [email protected] > > > Recently, I had a discussion with an NTRL > regarding product factory > inspections. > I was under the impression that where the label > was applied, that was where > the factory inspection would occur. And, if the > contract noted a different > company where the manfacturing was done and being > that was typically > (not always) where the lable was applied, that > was inspections would happen. > > Not so, according to these people. This was in > response to a hypothetical > situation I gave them to consider. > > For instance, say your company has sells a > product in your companys name. > But, you have assembly done at any number of > contractors. And the NRTL > label is applied at your company. Even if the > contractors aren't on the > contract with the NRTL for whatever reason, the > factory inspector will > inspect as much as possible the product at your > site, then inspect the > contractor site even though it is not on the > contract. Basically at their > discretion. > > The result of this is ... if say your company has > ten contractors on a list > of approved vendors with which do business (just > as an example for the > sake of argument) for possible assembly contracts > and at any time you > do business with just one of those contractors, > this all really means you > must inform the NRTL of all ten 'posible' > manufactoring locations and > all ten, including your own company, are to be > inspected on a quarterly > basis and thus increase your factory inspection > cost by a factor of 10. > > For some reason, this all sounds a little > unreasonable to me. > > What say you? > > Regards, Doug McKean > This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/listserv/request/user-guide.html 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: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
