From: Dward [mailto:dw...@pctestlab.com] Sent: Wednesday, March 20, 2013 12:53 PM To: 'Derek Walton'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Subject: RE: [PSES] Critical component in EMC report
I would have to disagree with you. I do not know what version you are reciting, but 17025 does not contain the statement that the lab cannot give an opinion. Laboratories are accredited to ISO 17025 and 17025 allows opinions. And the applicant is in fact looking for an opinion from the lab. Even the statement that the device complies with a particular standard is an opinion. An opinion based on the accuracies of a test labs equipment, setup, and any objective evidence resulting in testing etc, but still only an opinion. And, while they may be based on objective evidence, opinions are always subjective as the originate from a person’s mind and how he/she thinks. >From 17025: Section 4.7 “Service to the customer” - NOTE 2 Customers value the maintenance of good communication, advice and guidance in technical matters, and opinions and interpretations based on results. Section 5.2.1 – “Personnel” NOTE 2 The personnel responsible for the opinions and interpretation included in test reports should, in addition to the appropriate qualifications, training, experience and satisfactory knowledge of the testing carried out, also have: Section 5.2.4 – the responsibilities for reporting opinions and interpretations. Section 5.2.5 The management shall authorize specific personnel to perform particular types of sampling, test and/or calibration, to issue test reports and calibration certificates, to give opinions and interpretations and to operate particular types of equipment. Section 5.10.3 Test reports - where appropriate and needed, opinions and interpretations (see 5.10.5); Section 5.10.5 “Opinions and interpretations” When opinions and interpretations are included, the laboratory shall document the basis upon which the opinions and interpretations have been made. NOTE 1 Opinions and interpretations should not be confused with inspections and product certifications as intended in ISO/IEC 17020 and ISO/IEC Guide 65 NOTE 2 Opinions and interpretations included in a test report may comprise, but not be limited to, the following: In fact, a good report would have to contain an opinion on the pass or fail of testing, otherwise, it is not a compliance report, it is just a document providing test results. So, as you see, reports can and do contain opinions. Thanks Dennis Ward Senior Certification Engineer PCTEST This communication and its attachments contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient (s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachment(s) are free from computer virus or other defect. Thank you. From: Derek Walton [mailto:lfresea...@aol.com] Sent: Wednesday, March 20, 2013 12:28 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Critical component in EMC report Hi Dennis, the excerpts are verbatim words from the standard. Nothing inaccurate about it. These were the words stated in the thread: SNIP Test Reports from independent test laboratories should NEVER, NEVER EVER, incorporate subjective opinions. It is your duty to identify the EUT by means of serial numbers, h/w & s/w revisions, photographs, objective descriptions, declarations of the build from the client etc., and describe the test configuration and set-up by means of diagrams, photographs, operating instructions etc. In fact, accreditation bodies expressly prohibit independent laboratories from expressing opinions. SNIP I refuted both these and gave the grounds for why both were not true. What the standard and assessing bodies allow has no bearing on the professional relationship between lab and client. It can't be interpreted as "follow the standard unless the lab or client gets upset..." Up to $1:50 now ;-) Derek. -----Original Message----- From: Dward < <mailto:dw...@pctestlab.com> dw...@pctestlab.com> To: 'Anthony Thomson' < <mailto:ton...@europe.com> ton...@europe.com>; EMC-PSTC < <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG> Sent: Wed, Mar 20, 2013 1:32 pm Subject: RE: [PSES] Critical component in EMC report Actually, that is not accurate. While it may be dangerous to the test lab and client relationships, depending on the ‘opinion’, test labs can put their opinions in their reports. Section 5.10.5 of ISO17025 states that opinions only have to be marked as such, and while the std lists certain types of opinions, it also says that allowed opinions are not limited to those stated in the list. So, while a test lab may not want to as it would most likely cause them to lose a client, they could actually say something to the effect of “While this device passed, in our opinion it is really a piece of junk and should never be sold.” Or, if they really want the clients business, they could say “This device is the best thing since sliced bread.” Like I said, it could lose a client real fast, and it may be one of those things ‘what aint got no good Inglich’, but there is nothing to stop the test lab from stating this as their opinion. Thanks Dennis Ward Senior Certification Engineer PCTEST This communication and its attachments contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient (s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachment(s) are free from computer virus or other defect. Thank you. From: Anthony Thomson [ <mailto:ton...@europe.com?> mailto:ton...@europe.com] Sent: Wednesday, March 20, 2013 3:11 AM To: <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Critical component in EMC report "So our EMC reports do “freeze” a state of the product, by listing all relevant (in our opinion) construction details." Test Reports from independent test laboratories should NEVER, NEVER EVER, incorporate subjective opinions. It is your duty to identify the EUT by means of serial numbers, h/w & s/w revisions, photographs, objective descriptions, declarations of the build from the client etc., and describe the test configuration and set-up by means of diagrams, photographs, operating instructions etc. In fact, accreditation bodies expressly prohibit independent laboratories from expressing opinions. Assistance in identifying EMC critical design elements would be a consultancy service and could only be conducted in collaboration with the design authority. That same consultancy organisation cannot produce an independent test report. T - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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