Re: [PSES] Customer Requests for Risk Assessments
J -Original Message- From: Brian O'Connell [mailto:oconne...@tamuracorp.com] Sent: 18 May 2018 19:26 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments Long ago, when men were men, women were women, and dogs did not wear scarfs (sometime last year), had a customer that demanded the RAR for a component power converter, along with the complete CB test report. When this level of detail is required, have oft determined that the intent is to either to build a specification for another supplier, or to assist in the reverse engineer of the product. The complete internal RAR should NOT be a public document, per both legal and technical rationale. Brian Senior Cynical Engineering Advisor to the First Order Join the Empire and crush the rebellion From: John Woodgate [mailto:j...@woodjohn.uk] Sent: 17 May 2018 21:49 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments Don't ask for the whole RA, just ask for clear statements about points than concern you. John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2018-05-17 20:27, Nyffenegger, Dave wrote: This is a timely topic for me. Who are your "customers"? We partner with other various manufacturers, sometimes integrating other's machinery products in with ours or selling/servicing/refurbishing and providing heavy technical support for them as is. We sometimes ask for the manufacturers risk assessment (asked for one this week) so we can evaluate impact to our larger product or see the specific details that impact our servicing. We see the resistance from some Manufacturer's to provide risk assessments as well. -Dave From: "Kunde, Brian" Reply-To: "Kunde, Brian" Date: Thu, 17 May 2018 18:43:38 + To: Conversation: Customer Requests for Risk Assessments Subject: [PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn't this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our products might have. I reply that all residual risks are well documented and warned about in the provided User Manual. However, this doesn't seem to satisfy them. They still want a Risk Assessment Report. So are other companies having to generate a stripped down Risk Assessment with no real detail to satisfy these customer requests? Or is it just us? Thanks for your input, comments, and suggestions. The Other Brian - 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 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 format
Re: [PSES] Customer Requests for Risk Assessments
Long ago, when men were men, women were women, and dogs did not wear scarfs (sometime last year), had a customer that demanded the RAR for a component power converter, along with the complete CB test report. When this level of detail is required, have oft determined that the intent is to either to build a specification for another supplier, or to assist in the reverse engineer of the product. The complete internal RAR should NOT be a public document, per both legal and technical rationale. Brian Senior Cynical Engineering Advisor to the First Order Join the Empire and crush the rebellion From: John Woodgate [mailto:j...@woodjohn.uk] Sent: 17 May 2018 21:49 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments Don't ask for the whole RA, just ask for clear statements about points than concern you. John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2018-05-17 20:27, Nyffenegger, Dave wrote: This is a timely topic for me. Who are your "customers"? We partner with other various manufacturers, sometimes integrating other's machinery products in with ours or selling/servicing/refurbishing and providing heavy technical support for them as is. We sometimes ask for the manufacturers risk assessment (asked for one this week) so we can evaluate impact to our larger product or see the specific details that impact our servicing. We see the resistance from some Manufacturer's to provide risk assessments as well. -Dave From: "Kunde, Brian" Reply-To: "Kunde, Brian" Date: Thu, 17 May 2018 18:43:38 + To: Conversation: Customer Requests for Risk Assessments Subject: [PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn't this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our products might have. I reply that all residual risks are well documented and warned about in the provided User Manual. However, this doesn't seem to satisfy them. They still want a Risk Assessment Report. So are other companies having to generate a stripped down Risk Assessment with no real detail to satisfy these customer requests? Or is it just us? Thanks for your input, comments, and suggestions. The Other Brian - 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 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
Re: [PSES] Customer Requests for Risk Assessments
Integrators of complex systems interfacing with other manufacturers equipment, aerospace and military excluded and should provide a RAR. I am sure there are other situations as well. If we look at Brian's intro to his question "Our company makes Laboratory Equipment (test and measurement analyzers)". From: John Allen [mailto:09cc677f395b-dmarc-requ...@ieee.org] Sent: Thursday, May 17, 2018 5:11 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments Having been asked to do an RAR on very "difficult" project (a substantial update to the MoD/Quinetiq rocket projectile testing range control system at Pendine Sands in S. Wales!) some years ago, before I did that I made it very clear to the customer's Project Safety Engineer that - given the very unusual combination of high potential disk but low actual rate at which the system was/is actually operated - we would check out and then state the conditions of use, and potential resultant risk issues that might arise, but it was up to them to accept that and do the overall RA for the complete installation as we had no control on that as we could not determine the Probabilities of "something" going wrong and resulting in some form of "Accident" We would (and we did) identify the Risks and the Severities thereof, but they would then have to identify the Probabilities thereof - they/he agreed, and I suggest that any contracting company should do the same in anything like similar circumstances! John E Allen W.London, UK From: John Woodgate [mailto:j...@woodjohn.uk] Sent: 17 May 2018 21:49 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments Don't ask for the whole RA, just ask for clear statements about points than concern you. John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.woodjohn.uk&d=DwMFAg&c=9mghv0deYPYDGP-W745IEdQLV1kHpn4XJRvR6xMRXtA&r=RsvNGGiEXp8Wa3AN0R9oJL3JV5vFvlTsmxQpMmBLBIw&m=5L_kLlqlRopFjsYDNE8XBv-D2lIbthtW7V97oChEeOk&s=xLWf-08QRg9zCrfngutnDn4XXKVODDI1kDHSU6Azuz4&e=> Rayleigh, Essex UK On 2018-05-17 20:27, Nyffenegger, Dave wrote: This is a timely topic for me. Who are your "customers"? We partner with other various manufacturers, sometimes integrating other's machinery products in with ours or selling/servicing/refurbishing and providing heavy technical support for them as is. We sometimes ask for the manufacturers risk assessment (asked for one this week) so we can evaluate impact to our larger product or see the specific details that impact our servicing. We see the resistance from some Manufacturer's to provide risk assessments as well. -Dave From: Ken Javor [mailto:ken.ja...@emccompliance.com] Sent: Thursday, May 17, 2018 2:57 PM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Customer Requests for Risk Assessments Just commentary - no authoritative information. This sounds like the customer company's lawyers looking to divert blame in the event of a lawsuit by showing due diligence on their part, and maybe, just maybe, redirecting the blame vector towards your company if someone can make the case your company didn't adequately assess your product's risk. Ken Javor Phone: (256) 650-5261 From: "Kunde, Brian" <mailto:brian_ku...@lecotc.com> Reply-To: "Kunde, Brian" <mailto:brian_ku...@lecotc.com> Date: Thu, 17 May 2018 18:43:38 + To: <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Conversation: Customer Requests for Risk Assessments Subject: [PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do n
Re: [PSES] Customer Requests for Risk Assessments
Nice. From: John Woodgate [mailto:j...@woodjohn.uk] Sent: Thursday, May 17, 2018 3:59 PM To: Schmidt, Mark; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments An engineer and a lawyer argued about whose was the oldest profession. 'The creation of the Universe itself was obviously an engineering task', said the engineer. 'Before that there was only chaos'. 'Who do you think created the chaos?' said the lawyer. John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.woodjohn.uk&d=DwMD-g&c=9mghv0deYPYDGP-W745IEdQLV1kHpn4XJRvR6xMRXtA&r=RsvNGGiEXp8Wa3AN0R9oJL3JV5vFvlTsmxQpMmBLBIw&m=TUmoa4HpCuCq48eGbcwJaeOUfUrIn7JqAcVz93T1kFM&s=-OUV6qJqLKZInn8G1VVBpC6jXllEWLyjwxLgdCMk4hY&e=> Rayleigh, Essex UK On 2018-05-17 20:41, Schmidt, Mark wrote: Commentary as well, If the customer is a contractual partner or OEM I would typically share reports and such the contractual agreement between the two parties identify responsibility/liability and corporate lawyers involved. I believe the user manual is adequate for all other customers. Being the professional people we are the user manual will typically define the hazards adequately for the end user. So if one of your customers employee uses or abuses the instrument in any other manner outside the scope of its intended use (defined in the user manual) then they are responsible for their employees misuse and not your company. I know you make some pretty niche market stuff so if it were me I would hold my ground and not produce the RA. Your EN12100 and User manual is sufficient. It continues to amaze me as I grow old, how people in the corporate world have nothing better to do with their time but to create chaos. Making corporate life difficult and sometimes meaningless. There was a time where Company A produced and sold a product and Company B said wow what a great product. The end. Regards, Mark Schmidt Please be advised that this email may contain confidential information. If you are not the intended recipient, please notify us by email by replying to the sender and delete this message. The sender disclaims that the content of this email constitutes an offer to enter into, or the acceptance of, any agreement; provided that the foregoing does not invalidate the binding effect of any digital or other electronic reproduction of a manual signature that is included in any attachment. - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] Customer Requests for Risk Assessments
Having been asked to do an RAR on very "difficult" project (a substantial update to the MoD/Quinetiq rocket projectile testing range control system at Pendine Sands in S. Wales!) some years ago, before I did that I made it very clear to the customer's Project Safety Engineer that - given the very unusual combination of high potential disk but low actual rate at which the system was/is actually operated - we would check out and then state the conditions of use, and potential resultant risk issues that might arise, but it was up to them to accept that and do the overall RA for the complete installation as we had no control on that as we could not determine the Probabilities of "something" going wrong and resulting in some form of "Accident" We would (and we did) identify the Risks and the Severities thereof, but they would then have to identify the Probabilities thereof - they/he agreed, and I suggest that any contracting company should do the same in anything like similar circumstances! John E Allen W.London, UK From: John Woodgate [mailto:j...@woodjohn.uk] Sent: 17 May 2018 21:49 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments Don't ask for the whole RA, just ask for clear statements about points than concern you. John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2018-05-17 20:27, Nyffenegger, Dave wrote: This is a timely topic for me. Who are your "customers"? We partner with other various manufacturers, sometimes integrating other's machinery products in with ours or selling/servicing/refurbishing and providing heavy technical support for them as is. We sometimes ask for the manufacturers risk assessment (asked for one this week) so we can evaluate impact to our larger product or see the specific details that impact our servicing. We see the resistance from some Manufacturer's to provide risk assessments as well. -Dave From: Ken Javor [mailto:ken.ja...@emccompliance.com] Sent: Thursday, May 17, 2018 2:57 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments Just commentary - no authoritative information. This sounds like the customer company's lawyers looking to divert blame in the event of a lawsuit by showing due diligence on their part, and maybe, just maybe, redirecting the blame vector towards your company if someone can make the case your company didn't adequately assess your product's risk. Ken Javor Phone: (256) 650-5261 _ From: "Kunde, Brian" <mailto:brian_ku...@lecotc.com> Reply-To: "Kunde, Brian" <mailto:brian_ku...@lecotc.com> Date: Thu, 17 May 2018 18:43:38 +0000 To: <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Conversation: Customer Requests for Risk Assessments Subject: [PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn't this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our
Re: [PSES] Customer Requests for Risk Assessments
Don't ask for the whole RA, just ask for clear statements about points than concern you. John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2018-05-17 20:27, Nyffenegger, Dave wrote: Re: [PSES] Customer Requests for Risk Assessments This is a timely topic for me. Who are your “customers”? We partner with other various manufacturers, sometimes integrating other’s machinery products in with ours or selling/servicing/refurbishing and providing heavy technical support for them as is. We sometimes ask for the manufacturers risk assessment (asked for one this week) so we can evaluate impact to our larger product or see the specific details that impact our servicing. We see the resistance from some Manufacturer’s to provide risk assessments as well. -Dave *From:*Ken Javor [mailto:ken.ja...@emccompliance.com] *Sent:* Thursday, May 17, 2018 2:57 PM *To:* EMC-PSTC@LISTSERV.IEEE.ORG *Subject:* Re: [PSES] Customer Requests for Risk Assessments Just commentary – no authoritative information. This sounds like the customer company’s lawyers looking to divert blame in the event of a lawsuit by showing due diligence on their part, and maybe, just maybe, redirecting the blame vector towards your company if someone can make the case your company didn’t adequately assess your product's risk. Ken Javor Phone: (256) 650-5261 *From: *"Kunde, Brian" *Reply-To: *"Kunde, Brian" *Date: *Thu, 17 May 2018 18:43:38 + *To: * *Conversation: *Customer Requests for Risk Assessments *Subject: *[PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn’t this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our products might have. I reply that all residual risks are well documented and warned about in the provided User Manual. However, this doesn’t seem to satisfy them. They still want a Risk Assessment Report. So are other companies having to generate a stripped down Risk Assessment with no real detail to satisfy these customer requests? Or is it just us? Thanks for your input, comments, and suggestions. The Other Brian *LECO Corporation Notice:**This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. *- 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 mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html <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/ <http:/
Re: [PSES] Customer Requests for Risk Assessments
Brian, I have been asked to provide a risk assessment prior to the contract being signed. In my case it is for large systems to be installed on a customer site by an EPC (engineering procurement & construction). When I received an example report from the EPC, it too was a fairly "*dumbed down*" version of what I would normally do. It was in the form of an FMEA, which matches what we do. When I submitted my version (PDF only) to the EPC, they immediately came back with several comments related to format and the color highlights I used on the RPN numbers as related to thresholds, but nothing of actual substance. So, I took the opportunity to reformat. - All conditional color highlights are now tied to a flag I can turn on and off for printing. This made for a basically B&W report and we use the colors with our team of SMEs. - Proprietary information is masked and marked as such prior to printing in PDF. The topic headings were listed, proprietary information masked and resulting RPN numbers given. This was not done if the company has a confidentiality agreement of some kind. - Any FMEA risk items we felt had no direct impact on the customer, end users, etc.and would not change based on customer any known action or protections were removed. We kept the master list for internal purposes only. Examples may be found in PFEMA or MFMEA as opposed to DFMEA. - I developed various report formats using original data and based on requirements from IEC/ISO, UL/CSA, MIL-STD, etc. - I never put a functional excel worksheet in our company document system as too often our sales people would tell the customer, "*Oh, I have something here, let me just send it long*" On the topic of removed items, in one example we listed a risk of fire ants (genus Solenopsis) attracted to electrical fields in equipment and causing damage; not applicable in many parts of the world. And taking this out it streamlines the review process as it avoided questions like "*what does this mean?*". Out of curiosity, I decided to look up the professional profile a few of these people who are making the requirements and found they are often non-technical, paper pushers. So in the end what they wanted was a document to add to their files to show they are exercising due diligence and to check off one more box on their checklist. -Doug Douglas E Powell Laporte, Colorado USA doug...@gmail.com http://www.linkedin.com/in/dougp01 --- I don't get lost, I accidentally go on adventures. On Thu, May 17, 2018 at 12:43 PM, Kunde, Brian wrote: > Our company makes Laboratory Equipment (test and measurement analyzers). > > > > Our company performs a Risk Assessment early in the development stage of > all new products as so suggested by such documents. We generally use the EN > ISO 12100. Creating this document highlights the possible sources of risks > and allows our engineers to design products with an inherent design which > minimizes the risks as much as possible. Our Risk Assessment becomes a > document with a lot of detailed information including calculations, test > results, detailed data, and other design specifications. Such information > is considered highly confidential by our company. > > > > On occasion, and in increasing frequency, our company is asked by > potential customers to provide them with a Risk Assessment Report for our > products. Sometimes they threaten us such as they will not or cannot > consider our products unless we provide such documentation. > > > > 1. Why are customers asking for a Risk Assessment? Where did that > requirement become from? > > 2. Other than the potential loss of a sale, are we obligated to > provide our customer with a Risk Assessment? I do not see such a > requirement in the Directives or Standards we use. > > 3. Any of you been receiving similar requests? If so, do you > provide a Risk Assessment? If so, are you not worried about providing such > information? Couldn’t this information be used against you in court? Is > there a fear of providing useful information to your competitors? > > > > Part 2: > > I have requested a sample of the Risk Assessment our customers are > expecting our company to provide. The examples documents are for the most > part meaningless with little real detail about anything. But, if that is > all they want to make them happy, we are considering generating such a > document just to satisfy these requests. Any comments? > > > > When I ask our customers what information they are looking to gain from > the Risk Assessment, they tell me they want to know the level of residual > risks our products might have. I reply that all residual risks are well > documented and warned about in the provided User Manual. However, this > doesn’t seem to satisfy them. They still want a Risk Assessment Report. > > > > So are other companies hav
Re: [PSES] Customer Requests for Risk Assessments
HI Brian and the group, With respect to providing information to your competitors, which I have seen happen to many of my clients when they furnish documentation to prospective customers, I would have them sign an NDA so they would be liable if the information was divulged to a third party without your permission. This would apply to quotes and other documentation like your risk assessment. I have seen companies take a quote from one of my clients and send it to a competitor to see if the competitor can beat the quote. The competitor underbids on the project even though are not even competent to do the work! Also your document should be marked company confidential, not for distribution. This is not unusual and you need to protect yourself and your company. Doug On Thu, 17 May 2018 13:56:55 -0500, Ken Javor wrote: Just commentary – no authoritative information. This sounds like the customer company’s lawyers looking to divert blame in the event of a lawsuit by showing due diligence on their part, and maybe, just maybe, redirecting the blame vector towards your company if someone can make the case your company didn’t adequately assess your product's risk. Ken Javor Phone: (256) 650-5261 From: "Kunde, Brian" <brian_ku...@lecotc.com> Reply-To: "Kunde, Brian" <brian_ku...@lecotc.com> Date: Thu, 17 May 2018 18:43:38 + To: <EMC-PSTC@LISTSERV.IEEE.ORG> Conversation: Customer Requests for Risk Assessments Subject: [PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn’t this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our products might have. I reply that all residual risks are well documented and warned about in the provided User Manual. However, this doesn’t seem to satisfy them. They still want a Risk Assessment Report. So are other companies having to generate a stripped down Risk Assessment with no real detail to satisfy these customer requests? Or is it just us? Thanks for your input, comments, and suggestions. The Other Brian LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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) <http://www.ieee-pses.org/list.html>; List rules: http://www.ieee-pses.org/listrules.html
Re: [PSES] Customer Requests for Risk Assessments
This is a timely topic for me. Who are your "customers"? We partner with other various manufacturers, sometimes integrating other's machinery products in with ours or selling/servicing/refurbishing and providing heavy technical support for them as is. We sometimes ask for the manufacturers risk assessment (asked for one this week) so we can evaluate impact to our larger product or see the specific details that impact our servicing. We see the resistance from some Manufacturer's to provide risk assessments as well. -Dave From: Ken Javor [mailto:ken.ja...@emccompliance.com] Sent: Thursday, May 17, 2018 2:57 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments Just commentary - no authoritative information. This sounds like the customer company's lawyers looking to divert blame in the event of a lawsuit by showing due diligence on their part, and maybe, just maybe, redirecting the blame vector towards your company if someone can make the case your company didn't adequately assess your product's risk. Ken Javor Phone: (256) 650-5261 From: "Kunde, Brian" Reply-To: "Kunde, Brian" Date: Thu, 17 May 2018 18:43:38 + To: Conversation: Customer Requests for Risk Assessments Subject: [PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn't this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our products might have. I reply that all residual risks are well documented and warned about in the provided User Manual. However, this doesn't seem to satisfy them. They still want a Risk Assessment Report. So are other companies having to generate a stripped down Risk Assessment with no real detail to satisfy these customer requests? Or is it just us? Thanks for your input, comments, and suggestions. The Other Brian LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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 mailto: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) <http://www.ieee-pses.org/list.html><http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>>
Re: [PSES] Customer Requests for Risk Assessments
An engineer and a lawyer argued about whose was the oldest profession. 'The creation of the Universe itself was obviously an engineering task', said the engineer. 'Before that there was only chaos'. 'Who do you think created the chaos?' said the lawyer. John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2018-05-17 20:41, Schmidt, Mark wrote: Re: [PSES] Customer Requests for Risk Assessments Commentary as well, If the customer is a contractual partner or OEM I would typically share reports and such the contractual agreement between the two parties identify responsibility/liability and corporate lawyers involved. I believe the user manual is adequate for all other customers. Being the professional people we are the user manual will typically define the hazards adequately for the end user. So if one of your customers employee uses or abuses the instrument in any other manner outside the scope of its intended use (defined in the user manual) then they are responsible for their employees misuse and not your company. I know you make some pretty niche market stuff so if it were me I would hold my ground and not produce the RA. Your EN12100 and User manual is sufficient. It continues to amaze me as I grow old, how people in the corporate world have nothing better to do with their time but to create chaos. Making corporate life difficult and sometimes meaningless. There was a time where Company A produced and sold a product and Company B said wow what a great product. The end. Regards, Mark Schmidt - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] Customer Requests for Risk Assessments
Commentary as well, If the customer is a contractual partner or OEM I would typically share reports and such the contractual agreement between the two parties identify responsibility/liability and corporate lawyers involved. I believe the user manual is adequate for all other customers. Being the professional people we are the user manual will typically define the hazards adequately for the end user. So if one of your customers employee uses or abuses the instrument in any other manner outside the scope of its intended use (defined in the user manual) then they are responsible for their employees misuse and not your company. I know you make some pretty niche market stuff so if it were me I would hold my ground and not produce the RA. Your EN12100 and User manual is sufficient. It continues to amaze me as I grow old, how people in the corporate world have nothing better to do with their time but to create chaos. Making corporate life difficult and sometimes meaningless. There was a time where Company A produced and sold a product and Company B said wow what a great product. The end. Regards, Mark Schmidt From: Ken Javor [mailto:ken.ja...@emccompliance.com] Sent: Thursday, May 17, 2018 2:57 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Customer Requests for Risk Assessments Just commentary - no authoritative information. This sounds like the customer company's lawyers looking to divert blame in the event of a lawsuit by showing due diligence on their part, and maybe, just maybe, redirecting the blame vector towards your company if someone can make the case your company didn't adequately assess your product's risk. Ken Javor Phone: (256) 650-5261 From: "Kunde, Brian" Reply-To: "Kunde, Brian" Date: Thu, 17 May 2018 18:43:38 + To: Conversation: Customer Requests for Risk Assessments Subject: [PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn't this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our products might have. I reply that all residual risks are well documented and warned about in the provided User Manual. However, this doesn't seem to satisfy them. They still want a Risk Assessment Report. So are other companies having to generate a stripped down Risk Assessment with no real detail to satisfy these customer requests? Or is it just us? Thanks for your input, comments, and suggestions. The Other Brian LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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 All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html<
Re: [PSES] Customer Requests for Risk Assessments
I agree. You may be able to make your published RAR somewhat more meaningful than others, without disclosing sensitive information. This would be a marketing advantage. John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2018-05-17 19:56, Ken Javor wrote: Re: [PSES] Customer Requests for Risk Assessments Just commentary – no authoritative information. This sounds like the customer company’s lawyers looking to divert blame in the event of a lawsuit by showing due diligence on their part, and maybe, just maybe, redirecting the blame vector towards your company if someone can make the case your company didn’t adequately assess your product's risk. Ken Javor Phone: (256) 650-5261 *From: *"Kunde, Brian" *Reply-To: *"Kunde, Brian" *Date: *Thu, 17 May 2018 18:43:38 + *To: * *Conversation: *Customer Requests for Risk Assessments *Subject: *[PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn’t this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our products might have. I reply that all residual risks are well documented and warned about in the provided User Manual. However, this doesn’t seem to satisfy them. They still want a Risk Assessment Report. So are other companies having to generate a stripped down Risk Assessment with no real detail to satisfy these customer requests? Or is it just us? Thanks for your input, comments, and suggestions. The Other Brian *LECO Corporation Notice:**This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. *- 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 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) <http://www.ieee-pses.org/list.html> <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher David Heald - 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 mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and
Re: [PSES] Customer Requests for Risk Assessments
Just commentary no authoritative information. This sounds like the customer company¹s lawyers looking to divert blame in the event of a lawsuit by showing due diligence on their part, and maybe, just maybe, redirecting the blame vector towards your company if someone can make the case your company didn¹t adequately assess your product's risk. Ken Javor Phone: (256) 650-5261 From: "Kunde, Brian" Reply-To: "Kunde, Brian" Date: Thu, 17 May 2018 18:43:38 + To: Conversation: Customer Requests for Risk Assessments Subject: [PSES] Customer Requests for Risk Assessments Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn¹t this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our products might have. I reply that all residual risks are well documented and warned about in the provided User Manual. However, this doesn¹t seem to satisfy them. They still want a Risk Assessment Report. So are other companies having to generate a stripped down Risk Assessment with no real detail to satisfy these customer requests? Or is it just us? Thanks for your input, comments, and suggestions. The Other Brian LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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 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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher David Heald - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
[PSES] Customer Requests for Risk Assessments
Our company makes Laboratory Equipment (test and measurement analyzers). Our company performs a Risk Assessment early in the development stage of all new products as so suggested by such documents. We generally use the EN ISO 12100. Creating this document highlights the possible sources of risks and allows our engineers to design products with an inherent design which minimizes the risks as much as possible. Our Risk Assessment becomes a document with a lot of detailed information including calculations, test results, detailed data, and other design specifications. Such information is considered highly confidential by our company. On occasion, and in increasing frequency, our company is asked by potential customers to provide them with a Risk Assessment Report for our products. Sometimes they threaten us such as they will not or cannot consider our products unless we provide such documentation. 1. Why are customers asking for a Risk Assessment? Where did that requirement become from? 2. Other than the potential loss of a sale, are we obligated to provide our customer with a Risk Assessment? I do not see such a requirement in the Directives or Standards we use. 3. Any of you been receiving similar requests? If so, do you provide a Risk Assessment? If so, are you not worried about providing such information? Couldn't this information be used against you in court? Is there a fear of providing useful information to your competitors? Part 2: I have requested a sample of the Risk Assessment our customers are expecting our company to provide. The examples documents are for the most part meaningless with little real detail about anything. But, if that is all they want to make them happy, we are considering generating such a document just to satisfy these requests. Any comments? When I ask our customers what information they are looking to gain from the Risk Assessment, they tell me they want to know the level of residual risks our products might have. I reply that all residual risks are well documented and warned about in the provided User Manual. However, this doesn't seem to satisfy them. They still want a Risk Assessment Report. So are other companies having to generate a stripped down Risk Assessment with no real detail to satisfy these customer requests? Or is it just us? Thanks for your input, comments, and suggestions. The Other Brian LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
