Good People,

I would like to, again, offer my sincere gratitude to the many off-line
responses. I will be looking at several of the organizational suggestions.

Certainly no disrespect to Mr. Randolph, but the below response is the line I
hear from the bug guys' sales executives, but only after they promise one-stop
shopping and complete project management. And I never ask test lab personnel
to do anything other than to perform the tests and provide test data. I long
for the days when the big guys were competent and did not pretermit obvious
responsibility, were able to provide expert advice, and were true business
partners.

This is a morphed example from the last two international projects. I did this:
- Wrote the CB report.
- Arranged for the factory audits.
- Tracked down the audit reports and sent it to them
- Set up the equipment at the EMC lab and helped configure the receiver when
the data made no sense.
- Red-lined the EMC report.
- Compiled the REACH and RoHS data and submitted complete report.
- Forwarded all of this stuff and much more to the approvals office for
'final' review.

Then had all of the above rejected, several times, by two other levels of
review for various clerical errors and label markings. 

As company compliance professionals, we all must hold NRTLs, NBs, NCBs, etc to
the level of competency as noted on their respective accreditations. Any
non-Fortune 1k company cannot afford to expect less. We need a 'Consumer
Reports' for all regulatory functions. Other than having really big lab
facilities with lots of really nice equipment, what is the basis of these
organizations' accreditations with the various national bodies and other
agencies ?

Brian


-----Original Message-----
From: Joe Randolph [mailto:j...@randolph-telecom.com]
Sent: Wednesday, March 09, 2011 9:55 PM
To: oconne...@tamuracorp.com; emc-p...@ieee.org
Subject: Re: International approvals

On 3/9/2011, Brian O'Connell wrote:

I only do about one project per year where the customer requires safety
and EMC for 'just about everywhere'. I am looking for an organization that
assigns a single person to run each project - for ALL facets to include
factory inspections, safety, EMC, and environmental. I have grown weary of
doing the legwork for organizations that supposedly have 'one-stop
shopping' for IA; then charge me big money for doing their work.

Both big-name organizations that I have used in past 20 months suck.
Should I seek a smaller, lesser known organization? Suggestions? 


Hi Brian:

I don't know if the "big-name organizations" you refer to were test labs, but
if so, I can understand your frustration.  Most test labs are organized to
perform requested tests and produce test reports.  What gets done with those
reports is up to the customer.

I have never seen a big test lab that offered to take full ownership of the
entire approval process for a given product.  That's simply not what they are
set up to do.  And I don't really blame them for avoiding that service, since
it is notoriously difficult to predict in advance how many hours of work will
be required to complete all the administrative tasks associated with getting
international approval for a given product.  Keep in mind that the test lab
has no direct control over the product design and has no authority to speak
for the customer's company or make decisions for the customer's company.

The only model that I have seen work well is when an in-house employee of the
customer is responsible for obtaining all the necessary approvals.  That
person has a budget that can be spent on test labs and consultants, but that
person alone is the one who "owns" the approvals for the product.  As an
employee of the customer's organization, that person also has a management
chain that they can exercise as needed to set priorities, get questions
answered by other departments within the company, and make specific
commitments on behalf of the company.  No test lab employee has those levers
available.

In theory, you could hire an outside consultant to serve in this role, and
some companies do that.  However, the process frequently gets gummed up for
the same reasons that I described above when a non-employee has to speak and
act on behalf of the customer.

So, while you may see test labs advertise that they do "worldwide approvals,"
what they really mean is that they have the equipment to perform the tests and
they have the necessary accreditations to issue reports that will be accepted
worldwide.  I don't think it means that they will actually "own" the entire
process for worldwide approvals of the product.

Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com
http://www.randolph-telecom.com

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