In message
<!&!AAAAAAAAAAAYAAAAAAAAAJBbQmYH6FNPl0oV0KGUzsyChQAAEAAAAFWDfmYRsYJMlAsxE
qSKmE4BAAAAAA==@blueyonder.co.uk>, dated Sat, 18 Aug 2012, John Allen
<john_e_al...@blueyonder.co.uk> writes:
NRTLs inspect from 2 to 4 times a year, often on an unannounced basis,
and that does keep manufacturers ?on their toes?
I wouldn't call that 'far' more frequent, and that sort of control can
be deadly - see below.
and, for those NRTLs which have detailed product files against which to
inspect, the chances of finding non-compliant variations is (or at
least should be) much higher.
The point is that this is 'after the event' control. "According to our
records, you were using the XY23B part, but we see that you are now
using the XY23C, which is not yet approved by us, from sometime after
our last inspection four months ago. We have to withdraw certification
from your whole production since that inspection date until every unit
you have in stock or can recover is examined and modified to conform.
That will be $100 000 penalty, please." (OK, I don't know the exact
procedures in case of this sort of violation, and maybe I shall never
have to learn, but I hope you see what I mean.)
With self-certification, the appropriate action is to determine whether
the product is still compliant when the XY23C is introduced, or when the
substitution is discovered, with tests if necessary, and if it is, no
further action is necessary.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Instead of saying that the government is doing too little, too late or too
much, too early, say they've got is exactly right, thus throwing them into
total confusion.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
-
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