Rich,

Thanks for your advice.  It is unnecessary to re-test with previous version of 
standard since they did not find any non-conformance except the additional 
construction requirement.  Thus they do not want to confirm we are right -> 
they are wrong.  In next production, the product will comply with the latest 
version of standards.

Regards,

Scott

On 2 Aug, 2014, at 3:20 am, Richard Nute <ri...@ieee.org> wrote:

> 
> 
> Hi Scott:
> 
> 
> The product (which was certified to the version of the
> standard that was in effect at the time) was tested by
> a third-party laboratory (to a new requirement in the
> current edition of the standard) and found non-compliant.
> Somebody (either the laboratory or the authority) used
> the descriptive term "unsafe" because it did not comply
> with a safety standard.
> 
> (To a naive person, non-compliance with a safety standard
> makes an "unsafe" product.)
> 
> Since the third-party lab was engaged by the authority,
> you have no recourse to the lab (except on a friendly
> basis).  Re-test to the "old" version of the standard
> can only be authorized by the authority (who has no
> interest in your sales and trusts that the third-party
> lab is testing correctly, including choice of standard).
> 
> You can ask the authority to re-test to the "old" standard,
> but I guess that they would rather you "fix" the non-
> compliance and then they will authorize a re-test.  The
> authority is naive as to whether or not the product is
> safe, and will go by the word of the third-party lab.
> 
> As much as it hurts, I suggest that your only remedy is
> to make the product compliant to the latest version of
> the standard.
> 
> 
> Good luck,
> Rich
> 
> 
> 
> On 7/31/2014 10:21 AM, Scott Xe wrote:
>> Recently we received a sales ban from an authority.  The authority took a 
>> sample from the market and appointed a 3rd party laboratory for verification 
>> of LVD conformity.  They found a non conformance on construction according 
>> to the latest version of safety standard and concluded the product is 
>> unsafe.  The requirement is new in the latest version and did not appear in 
>> the previous version.
>> 
>> When our product was verified by the 3rd party test house, it complied with 
>> previous version of safety standard but was the latest version of the safety 
>> standard at time of testing.  The new version was issued 2 months later and 
>> has an additional construction requirement.  The DoW of previous version of 
>> safety standard is in 2016.  We are at loss how come they consider our 
>> product unsafe with the latest version of the standard during this 
>> transitional period.  Any previous experience to deal with such authority 
>> can be shared?  It sounds ridiculous charge on our product.
>> 
>> Thanks and regards,
>> 
>> Scott
>> 
>> 
> 
> 

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