In message <554dbd57-d1f3-4c4a-bade-09fedbcfe...@conformance.co.uk>,
dated Mon, 19 May 2014, John Cotman <john.cot...@conformance.co.uk>
writes:
It's a shockingly bad piece of standard writing.
There may be a reason.
 Requirements in standards must be objective and measurable, such that
suitably qualified people exercising reasonable skill would form the
same view as to whether something complies or not.
In an ideal world, that would always be possible.
The "trustworthiness" bit is not appropriate for a standard,
particularly one that is supposed to provide a presumption of
conformity, and I don't understand how it has been allowed to be
published.
Consider the people who are told to write the Directive (it's not a
standard; Directives and standards are as different as sharks and lions.
They are told to regulate so that a long list of supposedly noxious
substances are not present in excess of some 'parts per billion' figure,
probably not based on toxicity but upon detection thresholds, which are
continually being lowered. Looking over their shoulders are zealots who
are not satisfied with anything, just grudgingly concede as an interim
measure when assured of continual tightening of requirements.
Against this, we have the real world. Upwards of 50 million 3 mm screws
are made each day, and the zealots will settle for nothing less than
that EACH ONE is guaranteed not to contain more than 0.1 parts per
billion of unobtainium. How do we apply 'objective and measurable' to
these screws? Destroy each one in a mass spectrometer?
The only practical solution is to require the original batches of steel
and brass to be analysed and certified. Then they are made into screws.
Can each one be accompanied by its personalized DoC? At some point along
the distribution chain, there has to be trust.
 Quite what would happen if somebody relied on it in an enforcement
action is anybody's guess.
One would hope that a submission along the above lines might inject some
sanity into the court, but it's a forlorn hope.
Just my personal opinion!
Of course.
Now, please tell us how you would solve the problem. Use no more that
100 A4 sides.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Nondum ex silvis sumus
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
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