Rich & Friends
I, too in a past life at HP at Bristol, took the same approach of making sure that our processes and productions were well in excess of what past experience had shown that UL/CSA inspectors had looked for – and, albeit with a couple of minor “glitches”, that resulted in a pretty “smooth ride” thereafter (even much earlier on, when things were quite good, a BSI inspector, on behalf of CSA IIRC, commented that if the inspectors “look down” a couple of layers and find little or nothing then they won’t look much lower – on the basis that they found that if there were companies where the first or second layer highlighted serious discrepancies then those do have “problems”, whereas with a company like us (then) they could probably find issues if they looked deep enough and hard enough, but that would not be “fair” and not be an “even playground”). So, the moral is (if you can persuade the management to support you!) to sort your potential issues to a deeper level than you can expect from the inspectors (OR the “law” if a real problem appears to have surfaced) and then you can rest reasonably “easy” – and you hope that your suppliers have done the same! In other words, be rigorous with yourselves and check out your suppliers in a similar manner, and if they are not then sort or ditch them! John E Allen W. London, UK From: Richard Nute [mailto:ri...@ieee.org] Sent: 22 September 2017 20:13 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Safety critical component part #'s and Agency approvals Back when I was working… For each of our part numbers, we had a drawing (spec). For purchased parts, the drawing was a cut and paste of the part manufacturer’s spec. This drawing equated our part number to the manufacturer’s part number. If the part was required to be certified, such was indicated on the drawing. This drawing was used for purchasing the part. Then, the company did away with incoming inspection. The certification houses had a fit, and threatened to appeal to the president of the company. I told the certification houses that I couldn’t justify setting up an inspection process and hiring people to look for the certification mark (for which we never had a failure). (The certification houses had no sympathy for our expenses.) Instead, I invited the certification house inspectors to the production line where they could look at the parts as they were being installed in the product. This worked. (Some parts are bulk-marked, so the certification mark is on the package. In one inspection, the package had been discarded to the compactor. Our manufacturing host climbed into the compactor and retrieved the package!) We installed process measurement. My process measurement was the number of inspection deficiencies, any one of which threatened to shut down the production line. So, I instituted a periodic line inspection in anticipation of a certification house inspection. I was much more thorough and detailed than the certification house inspectors. I drove the deficiencies to zero. This infuriated the inspectors, so the certification houses sent managers to see why their inspectors could find no deficiencies. Sigh. Rich From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Friday, September 22, 2017 5:44 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Safety critical component part #'s and Agency approvals We address this possible issue in two ways. 1. We list the certification markings that are on Safety Critical Components on our purchase print as “incoming inspection requirements”. When parts are received, our IQA department visually verifies that the certification markings on the parts match the print. If they are different, the parts are rejected until this issues has been resolved (possible the manufacturer changed the certification body, etc.). 2. The purchase print also has a statement that says that the supplier must notify us in advance of any changes to the part including regulatory certifications and status. The purchase print is a type of contract between the supplier and the purchasing company. 3. Our Compliance Department performs Production Audits (usually on an annual bases) on all families of products. During these audits, all safety critical components are verified that they are what they are supposed to be and verifies the certification markings. The certification markings is also a type of contract or declaration from the manufacturer. Datasheets and pages from the manufacturer’s catalog that shows certification marks, symbols, or a list of standards are really meaningless and as others have already pointed out this information can change without warning. The Other Brian From: Regan Arndt [mailto:reganar...@gmail.com] Sent: Thursday, September 21, 2017 4:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Safety critical component part #'s and Agency approvals Greetings everyone, My experience in regulatory compliance dates back to 1994 where it was a foregone conclusion that most component manufacturers did not identify their agency certification as a unique identifier in their part number. I have seen some good progress over the years, but I also believe that the industry still continues to eliminate redundant certification (due to standards harmonization) or sometimes complete agency certification (for the sake of cost reduction) on components without changing their respective part number. Or even worse, continue to advertise that the component is approved but in reality, it is not. Has anyone experienced anything recently that they wish to share? P.S. I am updating my old safety presentation and need some good examples before I present again to our local IEEE chapter meeting. Thanks for sharing whatever you can. (privately or within this forum) Cheers! Regan - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
