To continue flogging a dead frog.... The PHB/MBA style management that has plagued North American compliance labs is where it is because we, the compliance engineering community, have chosen the path of least resistance (which is required for reliable bonding...). Mr. Nute is correct in the statement that agencies are being driven by bottom line concerns. But will also take the side of some of these labs (those that know me are probably having seizures), as have personally seen much weirdness in the test and certification of power conversion stuff. There is one particular lab, even if requested by customer, that my employer will never use: incorrect/incomplete reports, no conditions of acceptability, incorrectly scoped standards, no evidence of factory surveillance, etc. Under the SCC/OSHA systems, the lab takes considerable risk (regardless of the language in your General Services agreement with the agencies) under the civil tort process for all North American legal jurisdictions.
One questioned if "Is it that NRTLs don't trust each other's data? " Yes. In some cases, have had a customer say the marks of X and Y will not fly with Z because they also want yada yada. If customer will pay, we re-submit to Z, where they have access to all of my most wonderful TRFs, pics of test configs, etc; so Z will take my Tech File and use the reports from X and Y as basis for use of their mark and add the model to their FUS audits. Agency Z's management is happy they made more $$$$ with minimal engineering hours, and agency Z's assessment engineer can go home, drink an ale, and feel reasonably assured that the product is ok. Another wondered if this is ok in legal terms. Yes. If the lab adheres to 29CFR1910, OSHA cannot do anything about a lab's refusal to accept another lab's certification, or a lab's internal policy structure. One commented that their labs typically accept other labs' reports. Have found to be true where there are personal relationships and mutual respect among the various compliance and assessment engineers. A customer once commented that his assessment engineer accepted my employer's box because he knew the people that wrote the report. Finally, it was said by another august member that "It is extremely unlikely that this will change any time in the foreseeable future." As the situation is not intractable in technical sense, we should all endeavor to gently persuade some amount of change in lab attitudes. And as Mr. Nute noted, just take your business elsewhere. Brian -----Original Message----- From: Richard Nute [mailto:ri...@ieee.org] Sent: Thursday, September 04, 2014 10:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue Hi John: On 9/4/2014 8:52 AM, jral...@productsafetyinc.com wrote: > Is it that NRTLs don't trust each other's data? Or is the pink elephant in > the room revenue and market share?? The issue is revenue (profits). If the NRTL performs ALL of the tests, the revenue is higher and the profits higher. They use the argument that the NRTL must KNOW that the equipment is safe through their own measurements. They cannot be held responsible for tests that are done by another NRTL. On the other hand, some NRTLs do accept tests and data from other NRTLs. And, some NRTLs have MRAs (to reduce time and costs for a client). Best regards, Rich - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
