Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Ed Price]

OTOH, I was always uneasy with the term “compliance” because to me, compliance 
is a coercive, one-way street. You are expected to comply, without any 
negotiation; comply or suffer the consequences. You comply, but there is no 
business incentive to excel. This is not a free market, not capitalism as it 
should be. 

 

I’m not saying that Compliance is pure evil, just that over-emphasis on 
compliance can yield stultification, restraint of trade and terminal boredom.

 

Ed Price
WB6WSN
Chula Vista, CA USA



 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: Saturday, January 16, 2016 10:54 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

In generic terms Compliance is indeed nothing more than adherence to a set of 
rules. I once debated legal council at a company who wanted exclusive use of 
the term. I pointed out how this term is used in finance, medical, 
transportation, product safety, EMC and legal circles. Given a bit more time 
I'm certain I could come up with a list nearly as long as your arm. This one 
reason why I personally prefer the term Compliance Engineer. It is unique to 
this business sector. Among my peers, I like to be more specific and mention 
product safety engineer or EMC engineer.  

 

All the best, Doug

 

 

Douglas E Powell

doug...@gmail.com 



‎https://www.linkedin.com/in/dougp01

 

 

‎ 









 


From: Brian Gregory

Sent: Saturday, January 16, 2016 11:24 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Reply To: Brian Gregory

Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

 

Ah yes, I recall a conversation with a bright one from Garrad Hassan about a 
mutual customer.  He was establishing their compliance with GH's established 
financial qualifications for an undisclosed analysis.  I picked on the 
distinction rather quickly and had to clarify to him what compliance meant to 
me, representing an NRTL.

 

Colorado Brian 



-- Original Message --
From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?
Date: Fri, 15 Jan 2016 10:11:52 -0800

As is made somewhat more clear in this article 
<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
  (linked to by the original), this has nothing to do with technical product 
compliance but is about securities compliance 
<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States> .  

 

Sloppy use of the term "compliance" with no explanation of the specific meaning.

 

Scott (am I the "other" Scott?) just made a similar point... I will post anyway.

 

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory  
wrote:

 

 If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on. 

 

That the SEC is getting involved in Compliance investigations indicates to me 
increased scrutiny of companies' compliance issues.  As a technical issue, this 
appears to me to be bureaucratic overreach at the least, since SEC and DOJ 
aren't safety organizations like OSHA.  I think out-of-compliance issues should 
be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when 
there's a user-related problem or clear malfeasance (altering of documentation, 
unsubstantiated claims, etc.), which are covered under existing laws.

 

As I see IEC regulations leaning more towards risk management/aversion, I get 
the feeling that standards organizations are also contributing to this 
overreach by trying to solve problems, via regulation/standardization that 
haven't been proven yet to be problems in the actual marketplace of people, 
customers and products.  If you've been involved in any STP's, it's hard to 
avoid the feeling that there are some making hay out of increased regulatory 
oversight, including many ways that help consultants more than end users.

 

 

Colorado Brian 

-- Original Message --
From: "gdstuyvenb...@yahoo.com"  
<058ee1229c70-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +

Ken, wasn't suggesting increased government regulation, rather useful tips for 
our own consideration.  

 

Gary Stuyvenberg

Thompson Consulting

 

  _  

From: Ken Javor 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Thursday, January 14, 2016 10:59 PM
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?

 

“Last week was a good one for the compliance profession. “

Could not disagree more.  This is big brother, or s

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Ken Javor]

We are getting off-topic here, but I can¹t let this one go without comment.
The ³financial melt-down² in the USA back in 2008/2009 was initiated by the
very US government which is now in a lily-white, holier-than-thou mode
enforcing all sorts of rules-of-conduct to make sure, as Mr. Allen says,
that this doesn't happen again. USG had been forcing banks into making
mortgage loans that were not backed by adequate security.  Meaning, they
were legally forced to make loans to people who shouldn¹t have been
qualified. They did this to avoid accusations of various sorts of
discrimination that had become illegal.  Faced with massive amount of bad
debt, bankers attempted to off-load that bad debt by selling mortgage-backed
securities, which were worthless, but people didn¹t know it. It was like a
game of ³Old Maid,² with the holder of the ³Old Maid² trying to dump it on
someone else.

The USG by forcing bankers to take on bad debt converted the banking
industry from one fundamentally based on truth and integrity (as perceived
by the public) into a group of con artists. But they became con-artists in
response tot the government stimulus of forcing them to make bad loans.

People refer to the bad actors in the banking/mortgage industry without
referencing that it wasn¹t always like that, and it was the USG that
transformed that industry from a reputable one into a disaster.

Ken Javor
Phone: (256) 650-5261



From: John Allen 
Reply-To: John Allen 
Date: Sun, 17 Jan 2016 09:13:02 -
To: 
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?

And I should have added that I, for one, am quite glad that ³compliance² is
now a far more widespread discipline than it used to be as it may mean that
we get fewer financial and other scandals that might have been avoided if
the relevant regs and rules had been followed and enforced over the last 10
years or so ­ they affected me, and many others like some of you guys.
 
John Allen
 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: 17 January 2016 08:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?
 
Morning all from a slightly snowy Southern England
 
Over the years I¹ve received a number of approaches from financial services
recruitment companies about jobs in that industry sector ­ and had to
outline the Compliance Engineer role to them because they were not aware of
there being compliance people outside their sector!
 
John Allen
W.London, UK
 
 

From: Doug Powell [mailto:doug...@gmail.com]
Sent: 17 January 2016 06:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?
 

In generic terms Compliance is indeed nothing more than adherence to a set
of rules. I once debated legal council at a company who wanted exclusive use
of the term. I pointed out how this term is used in finance, medical,
transportation, product safety, EMC and legal circles. Given a bit more time
I'm certain I could come up with a list nearly as long as your arm. This one
reason why I personally prefer the term Compliance Engineer. It is unique to
this business sector. Among my peers, I like to be more specific and mention
product safety engineer or EMC engineer.

 

All the best, Doug

 

 

Douglas E Powell

doug...@gmail.com 

https://www.linkedin.com/in/dougp01

 

 

 

 

 

 

From: Brian Gregory
Sent: Saturday, January 16, 2016 11:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Reply To: Brian Gregory
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?
 

 

Ah yes, I recall a conversation with a bright one from Garrad Hassan about a
mutual customer.  He was establishing their compliance with GH's established
financial qualifications for an undisclosed analysis.  I picked on the
distinction rather quickly and had to clarify to him what compliance meant
to me, representing an NRTL.

 

Colorado Brian 



-- Original Message --
From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?
Date: Fri, 15 Jan 2016 10:11:52 -0800

As is made somewhat more clear in this article
<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-e
xcept-when-we-prosecute.html>  (linked to by the original), this has nothing
to do with technical product compliance but is about securities compliance
<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States> .

 

Sloppy use of the term "compliance" with no explanation of the specific
meaning.

 

Scott (am I the "other" Scott?) just made a similar point... I will post
anyway.

 

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory 
wrote:

 

 If you read the article (and others) it can be read either way.  The blog's
purpose is to give Compliance Offic

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[John Allen]

And I should have added that I, for one, am quite glad that “compliance” is now 
a far more widespread discipline than it used to be as it may mean that we get 
fewer financial and other scandals that might have been avoided if the relevant 
regs and rules had been followed and enforced over the last 10 years or so – 
they affected me, and many others like some of you guys.

 

John Allen

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 17 January 2016 08:28
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

Morning all from a slightly snowy Southern England

 

Over the years I’ve received a number of approaches from financial services 
recruitment companies about jobs in that industry sector – and had to outline 
the Compliance Engineer role to them because they were not aware of there being 
compliance people outside their sector!

 

John Allen

W.London, UK

 

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 17 January 2016 06:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

In generic terms Compliance is indeed nothing more than adherence to a set of 
rules. I once debated legal council at a company who wanted exclusive use of 
the term. I pointed out how this term is used in finance, medical, 
transportation, product safety, EMC and legal circles. Given a bit more time 
I'm certain I could come up with a list nearly as long as your arm. This one 
reason why I personally prefer the term Compliance Engineer. It is unique to 
this business sector. Among my peers, I like to be more specific and mention 
product safety engineer or EMC engineer.  

 

All the best, Doug

 

 

Douglas E Powell

doug...@gmail.com 

‎https://www.linkedin.com/in/dougp01

 

 

‎ 

 

 

 


From: Brian Gregory

Sent: Saturday, January 16, 2016 11:24 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Reply To: Brian Gregory

Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

 

Ah yes, I recall a conversation with a bright one from Garrad Hassan about a 
mutual customer.  He was establishing their compliance with GH's established 
financial qualifications for an undisclosed analysis.  I picked on the 
distinction rather quickly and had to clarify to him what compliance meant to 
me, representing an NRTL.

 

Colorado Brian 



-- Original Message --
From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?
Date: Fri, 15 Jan 2016 10:11:52 -0800

As is made somewhat more clear in this article 
<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
  (linked to by the original), this has nothing to do with technical product 
compliance but is about securities compliance 
<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States> .  

 

Sloppy use of the term "compliance" with no explanation of the specific meaning.

 

Scott (am I the "other" Scott?) just made a similar point... I will post anyway.

 

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory  
wrote:

 

 If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on. 

 

That the SEC is getting involved in Compliance investigations indicates to me 
increased scrutiny of companies' compliance issues.  As a technical issue, this 
appears to me to be bureaucratic overreach at the least, since SEC and DOJ 
aren't safety organizations like OSHA.  I think out-of-compliance issues should 
be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when 
there's a user-related problem or clear malfeasance (altering of documentation, 
unsubstantiated claims, etc.), which are covered under existing laws.

 

As I see IEC regulations leaning more towards risk management/aversion, I get 
the feeling that standards organizations are also contributing to this 
overreach by trying to solve problems, via regulation/standardization that 
haven't been proven yet to be problems in the actual marketplace of people, 
customers and products.  If you've been involved in any STP's, it's hard to 
avoid the feeling that there are some making hay out of increased regulatory 
oversight, including many ways that help consultants more than end users.

 

 

Colorado Brian 

-- Original Message --
From: "gdstuyvenb...@yahoo.com"  
<058ee1229c70-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +

Ken, wasn't sugg

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[John Allen]

Morning all from a slightly snowy Southern England

 

Over the years I’ve received a number of approaches from financial services 
recruitment companies about jobs in that industry sector – and had to outline 
the Compliance Engineer role to them because they were not aware of there being 
compliance people outside their sector!

 

John Allen

W.London, UK

 

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 17 January 2016 06:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

In generic terms Compliance is indeed nothing more than adherence to a set of 
rules. I once debated legal council at a company who wanted exclusive use of 
the term. I pointed out how this term is used in finance, medical, 
transportation, product safety, EMC and legal circles. Given a bit more time 
I'm certain I could come up with a list nearly as long as your arm. This one 
reason why I personally prefer the term Compliance Engineer. It is unique to 
this business sector. Among my peers, I like to be more specific and mention 
product safety engineer or EMC engineer.  

 

All the best, Doug

 

 

Douglas E Powell

doug...@gmail.com 



‎https://www.linkedin.com/in/dougp01

 

 

‎ 









 


From: Brian Gregory

Sent: Saturday, January 16, 2016 11:24 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Reply To: Brian Gregory

Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

 

 

Ah yes, I recall a conversation with a bright one from Garrad Hassan about a 
mutual customer.  He was establishing their compliance with GH's established 
financial qualifications for an undisclosed analysis.  I picked on the 
distinction rather quickly and had to clarify to him what compliance meant to 
me, representing an NRTL.

 

Colorado Brian 



-- Original Message --
From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?
Date: Fri, 15 Jan 2016 10:11:52 -0800

As is made somewhat more clear in this article 
<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
  (linked to by the original), this has nothing to do with technical product 
compliance but is about securities compliance 
<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States> .  

 

Sloppy use of the term "compliance" with no explanation of the specific meaning.

 

Scott (am I the "other" Scott?) just made a similar point... I will post anyway.

 

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory  
wrote:

 

 If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on. 

 

That the SEC is getting involved in Compliance investigations indicates to me 
increased scrutiny of companies' compliance issues.  As a technical issue, this 
appears to me to be bureaucratic overreach at the least, since SEC and DOJ 
aren't safety organizations like OSHA.  I think out-of-compliance issues should 
be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when 
there's a user-related problem or clear malfeasance (altering of documentation, 
unsubstantiated claims, etc.), which are covered under existing laws.

 

As I see IEC regulations leaning more towards risk management/aversion, I get 
the feeling that standards organizations are also contributing to this 
overreach by trying to solve problems, via regulation/standardization that 
haven't been proven yet to be problems in the actual marketplace of people, 
customers and products.  If you've been involved in any STP's, it's hard to 
avoid the feeling that there are some making hay out of increased regulatory 
oversight, including many ways that help consultants more than end users.

 

 

Colorado Brian 

-- Original Message --
From: "gdstuyvenb...@yahoo.com"  
<058ee1229c70-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +

Ken, wasn't suggesting increased government regulation, rather useful tips for 
our own consideration.  

 

Gary Stuyvenberg

Thompson Consulting

 

  _  

From: Ken Javor 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Thursday, January 14, 2016 10:59 PM
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?

 

“Last week was a good one for the compliance profession. “

Could not disagree more.  This is big brother, or socialism, call it what you 
will.  A product either meets requirements, or it doesn't. The gov’t 
instructing the private sector on how to get there is worse

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Doug Powell]

  In generic terms Compliance is indeed nothing more than adherence to a set of rules. I once debated legal council at a company who wanted exclusive use of the term. I pointed out how this term is used in finance, medical, transportation, product safety, EMC and legal circles. Given a bit more time I'm certain I could come up with a list nearly as long as your arm. This one reason why I personally prefer the term Compliance Engineer. It is unique to this business sector. Among my peers, I like to be more specific and mention product safety engineer or EMC engineer.  All the best, DougDouglas E Powelldoug...@gmail.com ‎https://www.linkedin.com/in/dougp01 ‎From: Brian GregorySent: Saturday, January 16, 2016 11:24 PMTo: EMC-PSTC@LISTSERV.IEEE.ORGReply To: Brian GregorySubject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce? 
Ah yes, I recall a conversation with a bright one from Garrad Hassan about a mutual customer.  He was establishing their compliance with GH's established financial qualifications for an undisclosed analysis.  I picked on the distinction rather quickly and had to clarify to him what compliance meant to me, representing an NRTL.
 

Colorado Brian 

-- Original Message --From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>To: EMC-PSTC@LISTSERV.IEEE.ORGSubject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?Date: Fri, 15 Jan 2016 10:11:52 -0800
As is made somewhat more clear in this article (linked to by the original), this has nothing to do with technical product compliance but is about securities compliance. 
 
Sloppy use of the term "compliance" with no explanation of the specific meaning.
 
Scott (am I the "other" Scott?) just made a similar point... I will post anyway.


On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory <brian_greg...@netzero.net> wrote:

 
 If you read the article (and others) it can be read either way.  The blog's purpose is to give Compliance Officers tools, reference information and background as to what is going on. 
 
That the SEC is getting involved in Compliance investigations indicates to me increased scrutiny of companies' compliance issues.  As a technical issue, this appears to me to be bureaucratic overreach at the least, since SEC and DOJ aren't safety organizations like OSHA.  I think out-of-compliance issues should be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when there's a user-related problem or clear malfeasance (altering of documentation, unsubstantiated claims, etc.), which are covered under existing laws.
 
As I see IEC regulations leaning more towards risk management/aversion, I get the feeling that standards organizations are also contributing to this overreach by trying to solve problems, via regulation/standardization that haven't been proven yet to be problems in the actual marketplace of people, customers and products.  If you've been involved in any STP's, it's hard to avoid the feeling that there are some making hay out of increased regulatory oversight, including many ways that help consultants more than end users.
 
 

Colorado Brian -- Original Message --From: "gdstuyvenb...@yahoo.com"  <058ee1229c70-dmarc-requ...@ieee.org>To: EMC-PSTC@LISTSERV.IEEE.ORGSubject: Re: [PSES] Is your company doing enough to ensure adequate EMC compliance?Date: Fri, 15 Jan 2016 13:29:10 +

Ken, wasn't suggesting increased government regulation, rather useful tips for our own consideration.  

Gary Stuyvenberg
Thompson Consulting
 



From: Ken Javor <ken.ja...@emccompliance.com> To: EMC-PSTC@LISTSERV.IEEE.ORG  Sent: Thursday, January 14, 2016 10:59 PM Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC compliance? 


“Last week was a good one for the compliance profession. “  Could not disagree more.  This is big brother, or socialism, call it what you will.  A product either meets requirements, or it doesn't. The gov’t instructing the private sector on how to get there is worse than superfluous, it’s damaging.  Ken Javor Phone: (256) 650-5261   From: "gdstuyvenb...@yahoo.com" <058ee1229c70-dmarc-requ...@ieee.org> Reply-To: "gdstuyvenb...@yahoo.com" <gdstuyvenb...@yahoo.com> Date: Fri, 15 Jan 2016 03:33:42 + To: <EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] I

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Brian Gregory]

 Ah yes, I recall a conversation with a bright one from Garrad Hassan about a 
mutual customer.  He was establishing their compliance with GH's established 
financial qualifications for an undisclosed analysis.  I picked on the 
distinction rather quickly and had to clarify to him what compliance meant to 
me, representing an NRTL. Colorado Brian 

-- Original Message --
From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?
Date: Fri, 15 Jan 2016 10:11:52 -0800


As is made somewhat more clear in this article (linked to by the original), 
this has nothing to do with technical product compliance but is about 
securities compliance.  Sloppy use of the term "compliance" with no explanation 
of the specific meaning. Scott (am I the "other" Scott?) just made a similar 
point... I will post anyway.
On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory  
wrote:
  If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on.  That the SEC is getting involved in 
Compliance investigations indicates to me increased scrutiny of companies' 
compliance issues.  As a technical issue, this appears to me to be bureaucratic 
overreach at the least, since SEC and DOJ aren't safety organizations like 
OSHA.  I think out-of-compliance issues should be (1) safety based and (2) 
customer sourced.  SEC or DOJ get involved when there's a user-related problem 
or clear malfeasance (altering of documentation, unsubstantiated claims, etc.), 
which are covered under existing laws. As I see IEC regulations leaning more 
towards risk management/aversion, I get the feeling that standards 
organizations are also contributing to this overreach by trying to solve 
problems, via regulation/standardization that haven't been proven yet to be 
problems in the actual marketplace of people, customers and products.  If 
you've been involved in any STP's, it's hard to avoid the feeling that there 
are some making hay out of increased regulatory oversight, including many ways 
that help consultants more than end users.  Colorado Brian 

-- Original Message --
From: "gdstuyvenb...@yahoo.com"  
<058ee1229c70-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +

Ken, wasn't suggesting increased government regulation, rather useful tips for 
our own consideration.  
Gary StuyvenbergThompson Consulting From: Ken Javor 

 To: EMC-PSTC@LISTSERV.IEEE.ORG 
 Sent: Thursday, January 14, 2016 10:59 PM
 Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
 
“Last week was a good one for the compliance profession. “  Could 
not disagree more.  This is big brother, or socialism, call it what you will.  
A product either meets requirements, or it doesn't. The gov’t instructing 
the private sector on how to get there is worse than superfluous, it’s 
damaging.  Ken Javor Phone: (256) 650-5261   From: "gdstuyvenb...@yahoo.com" 
<058ee1229c70-dmarc-requ...@ieee.org> Reply-To: "gdstuyvenb...@yahoo.com" 
 Date: Fri, 15 Jan 2016 03:33:42 + To: 
 Subject: [PSES] Is your company doing enough to 
ensure adequate EMC compliance?  As this is a board that deals primarily with 
regulatory/compliance issues, I thought the following article was pertinent to 
our cause and deserving of consideration.FEDS AS THOUGHT LEADERS: A 
BACK-DOOR COMPLIANCE DEFENSE TAKES SHAPE 
<http://www.fcpablog.com/blog/2015/11/11/feds-as-thought-leaders-a-back-door-compliance-defense-takes.html>
  By Richard L. Cassin <http://www.fcpablog.com/blog/author/fcpablog>  | 
Wednesday, November 11, 2015 at 7:53AM Assistant Attorney General Leslie 
Caldwell said last week the DOJ's hiring of a compliance counsel doesn't mean 
the agency is "moving toward recognizing or instituting a 'compliance 
defense.'" What then will the compliance counsel do? "She will help us evaluate 
each compliance program on a case-by-case basis -- just as the department 
always has -- but with a more expert eye," AAG Caldwell told a gethering 
<http://www.justice.gov/opa/speech/assistant-attorney-general-leslie-r-caldwell-speaks-sifma-compliance-and-legal-society>
  of compliance officers in New York. Caldwell, pictured above, then set out 
the factors the DOJ compliance counsel will assess: Does the institution ensure 
that its directors and senior managers provide strong, explicit and visible 
support for its corporate compliance policies? 
Do the people who are responsible for compliance have stature w

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[EMC-PSTC]

Hi Gary,
The article you link to is focused at CPAs and those in the financial industry. 
This IEEE list is focused on engineers, technicians, and those in the product 
development and testing industries. 

Two completely different groups of people who happen to share the name 
“compliance” in their function.

Regards,
John

John R. Kretsch, P.E., NCE
Interpro Consulting Engineering, LLC
jkret...@ip-ce.com


On Jan 16, 2016, at 19:39 , gdstuyvenb...@yahoo.com 
<058ee1229c70-dmarc-requ...@ieee.org> wrote:

Wasn't aware compliance had a different meaning depending on the industry 
involved.  Compliance is simply adherence to a specified set of rules, is it 
not?  Why should the industry matter?  

Gary


From: "Nyffenegger, Dave" 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Friday, January 15, 2016 1:27 PM
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

Amen.  Lots of difference kinds of compliance just as there are lots of 
different kinds of risk analysis.  That’s another one that gets people confused.
 
-Dave
 
From: Scott Aldous [mailto:0220f70c299a-dmarc-requ...@ieee.org] 
Sent: Friday, January 15, 2016 1:12 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?
 
As is made somewhat more clear in this article 
<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
 (linked to by the original), this has nothing to do with technical product 
compliance but is about securities compliance 
<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States>. 
 
Sloppy use of the term "compliance" with no explanation of the specific meaning.
 
Scott (am I the "other" Scott?) just made a similar point... I will post anyway.
 
On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory mailto:brian_greg...@netzero.net>> wrote:
 
 If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on. 
 
That the SEC is getting involved in Compliance investigations indicates to me 
increased scrutiny of companies' compliance issues.  As a technical issue, this 
appears to me to be bureaucratic overreach at the least, since SEC and DOJ 
aren't safety organizations like OSHA.  I think out-of-compliance issues should 
be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when 
there's a user-related problem or clear malfeasance (altering of documentation, 
unsubstantiated claims, etc.), which are covered under existing laws.
 
As I see IEC regulations leaning more towards risk management/aversion, I get 
the feeling that standards organizations are also contributing to this 
overreach by trying to solve problems, via regulation/standardization that 
haven't been proven yet to be problems in the actual marketplace of people, 
customers and products.  If you've been involved in any STP's, it's hard to 
avoid the feeling that there are some making hay out of increased regulatory 
oversight, including many ways that help consultants more than end users.
 
 
Colorado Brian 

-- Original Message --
From: "gdstuyvenb...@yahoo.com <mailto:gdstuyvenb...@yahoo.com>"  
<058ee1229c70-dmarc-requ...@ieee.org 
<mailto:058ee1229c70-dmarc-requ...@ieee.org>>
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +
Ken, wasn't suggesting increased government regulation, rather useful tips for 
our own consideration.  
 
Gary Stuyvenberg
Thompson Consulting
 
From: Ken Javor mailto:ken.ja...@emccompliance.com>>
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Sent: Thursday, January 14, 2016 10:59 PM
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
 
“Last week was a good one for the compliance profession. “

Could not disagree more.  This is big brother, or socialism, call it what you 
will.  A product either meets requirements, or it doesn't. The gov’t 
instructing the private sector on how to get there is worse than superfluous, 
it’s damaging.

Ken Javor
Phone: (256) 650-5261 

From: "gdstuyvenb...@yahoo.com <mailto:gdstuyvenb...@yahoo.com>" 
<058ee1229c70-dmarc-requ...@ieee.org 
<mailto:058ee1229c70-dmarc-requ...@ieee.org>>
Reply-To: "gdstuyvenb...@yahoo.com <mailto:gdstuyvenb...@yahoo.com>" 
mailto:gdstuyvenb...@yahoo.com>>
Date: Fri, 15 Jan 2016 03:33:42 +
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: [PSES] Is your company doing enough to ensure adequate EMC compliance?

As this is a board that deals prim

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[gdstuyvenb...@yahoo.com]

Wasn't aware compliance had a different meaning depending on the industry 
involved.  Compliance is simply adherence to a specified set of rules, is it 
not?  Why should the industry matter?  
Gary

  From: "Nyffenegger, Dave" 
 To: EMC-PSTC@LISTSERV.IEEE.ORG 
 Sent: Friday, January 15, 2016 1:27 PM
 Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
complia nce?
   
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{font-family:Wingdings;}#yiv4988723167 ol {margin-bottom:0in;}#yiv4988723167 ul 
{margin-bottom:0in;}#yiv4988723167 Amen.  Lots of difference kinds of 
compliance just as there are lots of different kinds of risk analysis.  That’s 
another one that gets people confused.    -Dave    From: Scott Aldous 
[mailto:0220f70c299a-dmarc-requ...@ieee.org]
Sent: Friday, January 15, 2016 1:12 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?    As is made somewhat more clear in this article (linked to by the 
original), this has nothing to do with technical product compliance but is 
about securities compliance.     Sloppy use of the term "compliance" with no 
explanation of the specific meaning.    Scott (am I the "other" Scott?) just 
made a similar point... I will post anyway.    On Fri, Jan 15, 2016 at 9:52 AM, 
Brian Gregory  wrote:    If you read the article 
(and others) it can be read either way.  The blog's purpose is to give 
Compliance Officers tools, reference information and background as to what is 
going on.    That the SEC is getting involved in Compliance investigations 
indicates to me increased scrutiny of companies' compliance issues.  As a 
technical issue, this appears to me to be bureaucratic overreach at the least, 
since SEC and DOJ aren't safety organizations like OSHA.  I think 
out-of-compliance issues should be (1) safety based and (2) customer sourced.  
SEC or DOJ get involved when there's a user-related problem or clear 
malfeasance (altering of documentation, unsubstantiated claims, etc.), which 
are covered under existing laws.   As I see IEC regulations leaning more 
towards risk management/aversion, I get the feeling that standards 
organizations are also contributing to this overreach by trying to solve 
problems, via regulation/standardization that haven't been proven yet to be 
problems in the actual marketplace of people, customers and products.  If 
you've been involved in any STP's, it's hard to avoid the feeling that there 
are some making hay out of increased regulatory oversight, including many ways 
that help consul

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Ken Javor]

Whew ­ sigh of relief!

Ken Javor
Phone: (256) 650-5261



From: "Nyffenegger, Dave" 
Reply-To: "Nyffenegger, Dave" 
Date: Fri, 15 Jan 2016 18:27:29 +
To: 
Conversation: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?

Amen.  Lots of difference kinds of compliance just as there are lots of
different kinds of risk analysis.  That¹s another one that gets people
confused.
 
-Dave
 
From: Scott Aldous [mailto:0220f70c299a-dmarc-requ...@ieee.org]
Sent: Friday, January 15, 2016 1:12 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
complia nce?
 

As is made somewhat more clear in this article
<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-e
xcept-when-we-prosecute.html>  (linked to by the original), this has nothing
to do with technical product compliance but is about securities compliance
<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States> .

 

Sloppy use of the term "compliance" with no explanation of the specific
meaning.

 

Scott (am I the "other" Scott?) just made a similar point... I will post
anyway.

 

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory 
wrote:

 

 If you read the article (and others) it can be read either way.  The blog's
purpose is to give Compliance Officers tools, reference information and
background as to what is going on.

 

That the SEC is getting involved in Compliance investigations indicates to
me increased scrutiny of companies' compliance issues.  As a technical
issue, this appears to me to be bureaucratic overreach at the least, since
SEC and DOJ aren't safety organizations like OSHA.  I think
out-of-compliance issues should be (1) safety based and (2) customer
sourced.  SEC or DOJ get involved when there's a user-related problem or
clear malfeasance (altering of documentation, unsubstantiated claims, etc.),
which are covered under existing laws.

 

As I see IEC regulations leaning more towards risk management/aversion, I
get the feeling that standards organizations are also contributing to this
overreach by trying to solve problems, via regulation/standardization that
haven't been proven yet to be problems in the actual marketplace of people,
customers and products.  If you've been involved in any STP's, it's hard to
avoid the feeling that there are some making hay out of increased regulatory
oversight, including many ways that help consultants more than end users.

 

 

Colorado Brian 

-- Original Message --
From: "gdstuyvenb...@yahoo.com"
<058ee1229c70-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +

Ken, wasn't suggesting increased government regulation, rather useful tips
for our own consideration.
 

Gary Stuyvenberg

Thompson Consulting

 


From: Ken Javor 
To: EMC-PSTC@LISTSERV.IEEE.ORG
Sent: Thursday, January 14, 2016 10:59 PM
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
compliance?

 

³Last week was a good one for the compliance profession. ³

Could not disagree more.  This is big brother, or socialism, call it what
you will.  A product either meets requirements, or it doesn't. The gov¹t
instructing the private sector on how to get there is worse than
superfluous, it¹s damaging.

Ken Javor
Phone: (256) 650-5261 


From: "gdstuyvenb...@yahoo.com" <058ee1229c70-dmarc-requ...@ieee.org>
Reply-To: "gdstuyvenb...@yahoo.com" 
Date: Fri, 15 Jan 2016 03:33:42 +
To: 
Subject: [PSES] Is your company doing enough to ensure adequate EMC
compliance?

As this is a board that deals primarily with regulatory/compliance issues, I
thought the following article was pertinent to our cause and deserving of
consideration.  

FEDS AS THOUGHT LEADERS: A BACK-DOOR COMPLIANCE DEFENSE TAKES SHAPE
<http://www.fcpablog.com/blog/2015/11/11/feds-as-thought-leaders-a-back-door
-compliance-defense-takes.html>
By Richard L. Cassin <http://www.fcpablog.com/blog/author/fcpablog>  |
Wednesday, November 11, 2015 at 7:53AM
Assistant Attorney General Leslie Caldwell said last week the DOJ's hiring
of a compliance counsel doesn't mean the agency is "moving toward
recognizing or instituting a 'compliance defense.'"
What then will the compliance counsel do?
"She will help us evaluate each compliance program on a case-by-case basis
-- just as the department always has -- but with a more expert eye," AAG
Caldwell told a gethering
<http://www.justice.gov/opa/speech/assistant-attorney-general-leslie-r-caldw
ell-speaks-sifma-compliance-and-legal-society>  of compliance officers in
New York.
Caldwell, 

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Nyffenegger, Dave]

Amen.  Lots of difference kinds of compliance just as there are lots of 
different kinds of risk analysis.  That’s another one that gets people confused.

-Dave

From: Scott Aldous [mailto:0220f70c299a-dmarc-requ...@ieee.org]
Sent: Friday, January 15, 2016 1:12 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

As is made somewhat more clear in this 
article<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
 (linked to by the original), this has nothing to do with technical product 
compliance but is about securities 
compliance<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States>.

Sloppy use of the term "compliance" with no explanation of the specific meaning.

Scott (am I the "other" Scott?) just made a similar point... I will post anyway.

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory 
mailto:brian_greg...@netzero.net>> wrote:

 If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on.

That the SEC is getting involved in Compliance investigations indicates to me 
increased scrutiny of companies' compliance issues.  As a technical issue, this 
appears to me to be bureaucratic overreach at the least, since SEC and DOJ 
aren't safety organizations like OSHA.  I think out-of-compliance issues should 
be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when 
there's a user-related problem or clear malfeasance (altering of documentation, 
unsubstantiated claims, etc.), which are covered under existing laws.

As I see IEC regulations leaning more towards risk management/aversion, I get 
the feeling that standards organizations are also contributing to this 
overreach by trying to solve problems, via regulation/standardization that 
haven't been proven yet to be problems in the actual marketplace of people, 
customers and products.  If you've been involved in any STP's, it's hard to 
avoid the feeling that there are some making hay out of increased regulatory 
oversight, including many ways that help consultants more than end users.


Colorado Brian

-- Original Message --
From: "gdstuyvenb...@yahoo.com<mailto:gdstuyvenb...@yahoo.com>"  
<058ee1229c70-dmarc-requ...@ieee.org<mailto:058ee1229c70-dmarc-requ...@ieee.org>>
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +
Ken, wasn't suggesting increased government regulation, rather useful tips for 
our own consideration.

Gary Stuyvenberg
Thompson Consulting


From: Ken Javor 
mailto:ken.ja...@emccompliance.com>>
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Sent: Thursday, January 14, 2016 10:59 PM
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?

“Last week was a good one for the compliance profession. “

Could not disagree more.  This is big brother, or socialism, call it what you 
will.  A product either meets requirements, or it doesn't. The gov’t 
instructing the private sector on how to get there is worse than superfluous, 
it’s damaging.

Ken Javor
Phone: (256) 650-5261


From: "gdstuyvenb...@yahoo.com<mailto:gdstuyvenb...@yahoo.com>" 
<058ee1229c70-dmarc-requ...@ieee.org<mailto:058ee1229c70-dmarc-requ...@ieee.org>>
Reply-To: "gdstuyvenb...@yahoo.com<mailto:gdstuyvenb...@yahoo.com>" 
mailto:gdstuyvenb...@yahoo.com>>
Date: Fri, 15 Jan 2016 03:33:42 +
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: [PSES] Is your company doing enough to ensure adequate EMC compliance?

As this is a board that deals primarily with regulatory/compliance issues, I 
thought the following article was pertinent to our cause and deserving of 
consideration.

FEDS AS THOUGHT LEADERS: A BACK-DOOR COMPLIANCE DEFENSE TAKES SHAPE 
<http://www.fcpablog.com/blog/2015/11/11/feds-as-thought-leaders-a-back-door-compliance-defense-takes.html><http://www.fcpablog.com/blog/2015/11/11/feds-as-thought-leaders-a-back-door-compliance-defense-takes.html>
By Richard L. Cassin 
<http://www.fcpablog.com/blog/author/fcpablog><http://www.fcpablog.com/blog/author/fcpablog>
  | Wednesday, November 11, 2015 at 7:53AM
Assistant Attorney General Leslie Caldwell said last week the DOJ's hiring of a 
compliance counsel doesn't mean the agency is "moving toward recognizing or 
instituting a 'compliance defense.'"
What then will the compliance counsel do?
"She will help

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Rodney Davis]

Yes, we are not the only discipline concerned with Compliance.

select  delete.


Rodney Davis



From: Scott Aldous <0220f70c299a-dmarc-requ...@ieee.org>
Sent: Friday, January 15, 2016 1:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC complia 
nce?

As is made somewhat more clear in this 
article<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
 (linked to by the original), this has nothing to do with technical product 
compliance but is about securities 
compliance<https://en.wikipedia.org/wiki/Securities_regulation_in_the_United_States>.
[http://www.fcpablog.com/storage/Screen%20Shot%202015-11-09%20at%207.58.07%20AM.png?__SQUARESPACE_CACHEVERSION=1447074024595]<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>

SEC: We protect compliance officers, except when we 
...<http://www.fcpablog.com/blog/2015/11/9/sec-we-protect-compliance-officers-except-when-we-prosecute.html>
www.fcpablog.com
Andrew Ceresney, head of the SEC's enforcement division, delivered the keynote 
last week to the National Society of Compliance Professionals at the group's 
annual ...



Sloppy use of the term "compliance" with no explanation of the specific meaning.

Scott (am I the "other" Scott?) just made a similar point... I will post anyway.

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory 
mailto:brian_greg...@netzero.net>> wrote:

 If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on.

That the SEC is getting involved in Compliance investigations indicates to me 
increased scrutiny of companies' compliance issues.  As a technical issue, this 
appears to me to be bureaucratic overreach at the least, since SEC and DOJ 
aren't safety organizations like OSHA.  I think out-of-compliance issues should 
be (1) safety based and (2) customer sourced.  SEC or DOJ get involved when 
there's a user-related problem or clear malfeasance (altering of documentation, 
unsubstantiated claims, etc.), which are covered under existing laws.

As I see IEC regulations leaning more towards risk management/aversion, I get 
the feeling that standards organizations are also contributing to this 
overreach by trying to solve problems, via regulation/standardization that 
haven't been proven yet to be problems in the actual marketplace of people, 
customers and products.  If you've been involved in any STP's, it's hard to 
avoid the feeling that there are some making hay out of increased regulatory 
oversight, including many ways that help consultants more than end users.


Colorado Brian

-- Original Message --
From: "gdstuyvenb...@yahoo.com<mailto:gdstuyvenb...@yahoo.com>"  
<058ee1229c70-dmarc-requ...@ieee.org<mailto:058ee1229c70-dmarc-requ...@ieee.org>>
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +

Ken, wasn't suggesting increased government regulation, rather useful tips for 
our own consideration.

Gary Stuyvenberg
Thompson Consulting


From: Ken Javor 
mailto:ken.ja...@emccompliance.com>>
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Sent: Thursday, January 14, 2016 10:59 PM
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?

“Last week was a good one for the compliance profession. “

Could not disagree more.  This is big brother, or socialism, call it what you 
will.  A product either meets requirements, or it doesn't. The gov’t 
instructing the private sector on how to get there is worse than superfluous, 
it’s damaging.

Ken Javor
Phone: (256) 650-5261



From: "gdstuyvenb...@yahoo.com<mailto:gdstuyvenb...@yahoo.com>" 
<058ee1229c70-dmarc-requ...@ieee.org<mailto:058ee1229c70-dmarc-requ...@ieee.org>>
Reply-To: "gdstuyvenb...@yahoo.com<mailto:gdstuyvenb...@yahoo.com>" 
mailto:gdstuyvenb...@yahoo.com>>
Date: Fri, 15 Jan 2016 03:33:42 +
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: [PSES] Is your company doing enough to ensure adequate EMC compliance?

As this is a board that deals primarily with regulatory/compliance issues, I 
thought the following article was pertinent to our cause and deserving of 
consideration.

FEDS AS THOUGHT LEADERS: A BACK-DOOR COMPLIANCE DEFENSE TAKES SHAPE 
<http://www.fcpablog.com/blog/2015/11/11/feds-as-thought-leaders-a-back-door-compliance-defense-ta

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Scott Aldous]

As is made somewhat more clear in this article

(linked
to by the original), this has nothing to do with technical product
compliance but is about securities compliance
.

Sloppy use of the term "compliance" with no explanation of the specific
meaning.

Scott (am I the "other" Scott?) just made a similar point... I will post
anyway.

On Fri, Jan 15, 2016 at 9:52 AM, Brian Gregory 
wrote:

>
>  If you read the article (and others) it can be read either way.  The
> blog's purpose is to give Compliance Officers tools, reference information
> and background as to what is going on.
>
> That the SEC is getting involved in Compliance investigations indicates to
> me increased scrutiny of companies' compliance issues.  As a technical
> issue, this appears to me to be bureaucratic overreach at the least, since
> SEC and DOJ aren't safety organizations like OSHA.  I think
> out-of-compliance issues should be (1) safety based and (2) customer
> sourced.  SEC or DOJ get involved when there's a user-related problem or
> clear malfeasance (altering of documentation, unsubstantiated claims,
> etc.), which are covered under existing laws.
>
> As I see IEC regulations leaning more towards risk management/aversion, I
> get the feeling that standards organizations are also contributing to this
> overreach by trying to solve problems, via regulation/standardization that
> haven't been proven yet to be problems in the actual marketplace of people,
> customers and products.  If you've been involved in any STP's, it's hard to
> avoid the feeling that there are some making hay out of increased
> regulatory oversight, including many ways that help consultants more than
> end users.
>
>
> Colorado Brian
>
> -- Original Message --
> From: "gdstuyvenb...@yahoo.com"  <
> 058ee1229c70-dmarc-requ...@ieee.org>
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
> compliance?
> Date: Fri, 15 Jan 2016 13:29:10 +
>
> Ken, wasn't suggesting increased government regulation, rather useful tips
> for our own consideration.
>
> Gary Stuyvenberg
> Thompson Consulting
>
> --
> *From:* Ken Javor 
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Sent:* Thursday, January 14, 2016 10:59 PM
> *Subject:* Re: [PSES] Is your company doing enough to ensure adequate EMC
> compliance?
>
> “Last week was a good one for the compliance profession. “
>
> Could not disagree more.  This is big brother, or socialism, call it what
> you will.  A product either meets requirements, or it doesn't. The gov’t
> instructing the private sector on how to get there is worse than
> superfluous, it’s damaging.
>
> Ken Javor
> Phone: (256) 650-5261
>
>
> --
> *From: *"gdstuyvenb...@yahoo.com" <058ee1229c70-dmarc-requ...@ieee.org
> >
> *Reply-To: *"gdstuyvenb...@yahoo.com" 
> *Date: *Fri, 15 Jan 2016 03:33:42 +
> *To: *
> *Subject: *[PSES] Is your company doing enough to ensure adequate EMC
> compliance?
>
> As this is a board that deals primarily with regulatory/compliance issues,
> I thought the following article was pertinent to our cause and deserving of
> consideration.
>
>
> *FEDS AS THOUGHT LEADERS: A BACK-DOOR COMPLIANCE DEFENSE TAKES SHAPE
> 
> 
> *By Richard L. Cassin 
>   | Wednesday, November 11,
> 2015 at 7:53AM
> Assistant Attorney General Leslie Caldwell said last week the DOJ's hiring
> of a compliance counsel doesn't mean the agency is "moving toward
> recognizing or instituting a 'compliance defense.'"
> What then will the compliance counsel do?
> "She will help us evaluate each compliance program on a case-by-case basis
> -- just as the department always has -- but with a more expert eye," AAG
> Caldwell *told a gethering
> 
> 
>  *of compliance officers in New York.
> Caldwell, pictured above, then set out the factors the DOJ compliance
> counsel will assess:
>
>- Does the institution ensure that its directors and senior managers
>provide strong, explicit and visible support for its corporate compliance
>policies?
>- Do the people who are responsible for compliance have stature within
>the company? Do compliance teams get adequate funding and access to
>necessary resources? Of co

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Scott Douglas]

Are we missing the point here? Or reading more into the message? SEC is
about finance. FCPA is Foreign Corrupt Practices Act and had to do with
trade and kickbacks and such. How does this translate into Product
Compliance?

Scott
On Jan 15, 2016 9:54 AM, "Brian Gregory"  wrote:

>
>  If you read the article (and others) it can be read either way.  The
> blog's purpose is to give Compliance Officers tools, reference information
> and background as to what is going on.
>
> That the SEC is getting involved in Compliance investigations indicates to
> me increased scrutiny of companies' compliance issues.  As a technical
> issue, this appears to me to be bureaucratic overreach at the least, since
> SEC and DOJ aren't safety organizations like OSHA.  I think
> out-of-compliance issues should be (1) safety based and (2) customer
> sourced.  SEC or DOJ get involved when there's a user-related problem or
> clear malfeasance (altering of documentation, unsubstantiated claims,
> etc.), which are covered under existing laws.
>
> As I see IEC regulations leaning more towards risk management/aversion, I
> get the feeling that standards organizations are also contributing to this
> overreach by trying to solve problems, via regulation/standardization that
> haven't been proven yet to be problems in the actual marketplace of people,
> customers and products.  If you've been involved in any STP's, it's hard to
> avoid the feeling that there are some making hay out of increased
> regulatory oversight, including many ways that help consultants more than
> end users.
>
>
> Colorado Brian
>
> -- Original Message --
> From: "gdstuyvenb...@yahoo.com"  <
> 058ee1229c70-dmarc-requ...@ieee.org>
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC
> compliance?
> Date: Fri, 15 Jan 2016 13:29:10 +
>
> Ken, wasn't suggesting increased government regulation, rather useful tips
> for our own consideration.
>
> Gary Stuyvenberg
> Thompson Consulting
>
> --
> *From:* Ken Javor 
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Sent:* Thursday, January 14, 2016 10:59 PM
> *Subject:* Re: [PSES] Is your company doing enough to ensure adequate EMC
> compliance?
>
> “Last week was a good one for the compliance profession. “
>
> Could not disagree more.  This is big brother, or socialism, call it what
> you will.  A product either meets requirements, or it doesn't. The gov’t
> instructing the private sector on how to get there is worse than
> superfluous, it’s damaging.
>
> Ken Javor
> Phone: (256) 650-5261
>
>
> --
> *From: *"gdstuyvenb...@yahoo.com" <058ee1229c70-dmarc-requ...@ieee.org
> >
> *Reply-To: *"gdstuyvenb...@yahoo.com" 
> *Date: *Fri, 15 Jan 2016 03:33:42 +
> *To: *
> *Subject: *[PSES] Is your company doing enough to ensure adequate EMC
> compliance?
>
> As this is a board that deals primarily with regulatory/compliance issues,
> I thought the following article was pertinent to our cause and deserving of
> consideration.
>
>
> *FEDS AS THOUGHT LEADERS: A BACK-DOOR COMPLIANCE DEFENSE TAKES SHAPE
> 
> 
> *By Richard L. Cassin 
>   | Wednesday, November 11,
> 2015 at 7:53AM
> Assistant Attorney General Leslie Caldwell said last week the DOJ's hiring
> of a compliance counsel doesn't mean the agency is "moving toward
> recognizing or instituting a 'compliance defense.'"
> What then will the compliance counsel do?
> "She will help us evaluate each compliance program on a case-by-case basis
> -- just as the department always has -- but with a more expert eye," AAG
> Caldwell *told a gethering
> 
> 
>  *of compliance officers in New York.
> Caldwell, pictured above, then set out the factors the DOJ compliance
> counsel will assess:
>
>- Does the institution ensure that its directors and senior managers
>provide strong, explicit and visible support for its corporate compliance
>policies?
>- Do the people who are responsible for compliance have stature within
>the company? Do compliance teams get adequate funding and access to
>necessary resources? Of course, we won’t expect that a smaller company has
>the same compliance resources as a Fortune-50 company.
>- Are the institution’s compliance policies clear and in writing? Are
>they easily understood by employees? Are the policies translated into
>languages spoken by the com

Re: [PSES] Is your company doing enough to ensure adequate EMC complia nce?

[Brian Gregory]

  If you read the article (and others) it can be read either way.  The blog's 
purpose is to give Compliance Officers tools, reference information and 
background as to what is going on.   That the SEC is getting involved in 
Compliance investigations indicates to me increased scrutiny of companies' 
compliance issues.  As a technical issue, this appears to me to be bureaucratic 
overreach at the least, since SEC and DOJ aren't safety organizations like 
OSHA.  I think out-of-compliance issues should be (1) safety based and (2) 
customer sourced.  SEC or DOJ get involved when there's a user-related problem 
or clear malfeasance (altering of documentation, unsubstantiated claims, etc.), 
which are covered under existing laws. As I see IEC regulations leaning more 
towards risk management/aversion, I get the feeling that standards 
organizations are also contributing to this overreach by trying to solve 
problems, via regulation/standardization that haven't been proven yet to be 
problems in the actual marketplace of people, customers and products.  If 
you've been involved in any STP's, it's hard to avoid the feeling that there 
are some making hay out of increased regulatory oversight, including many ways 
that help consultants more than end users.  Colorado Brian 

-- Original Message --
From: "gdstuyvenb...@yahoo.com"  
<058ee1229c70-dmarc-requ...@ieee.org>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
Date: Fri, 15 Jan 2016 13:29:10 +


Ken, wasn't suggesting increased government regulation, rather useful tips for 
our own consideration.  
Gary StuyvenbergThompson Consulting From: Ken Javor 

 To: EMC-PSTC@LISTSERV.IEEE.ORG 
 Sent: Thursday, January 14, 2016 10:59 PM
 Subject: Re: [PSES] Is your company doing enough to ensure adequate EMC 
compliance?
 
“Last week was a good one for the compliance profession. “  Could 
not disagree more.  This is big brother, or socialism, call it what you will.  
A product either meets requirements, or it doesn't. The gov’t instructing 
the private sector on how to get there is worse than superfluous, it’s 
damaging.  Ken Javor Phone: (256) 650-5261   From: "gdstuyvenb...@yahoo.com" 
<058ee1229c70-dmarc-requ...@ieee.org> Reply-To: "gdstuyvenb...@yahoo.com" 
 Date: Fri, 15 Jan 2016 03:33:42 + To: 
 Subject: [PSES] Is your company doing enough to 
ensure adequate EMC compliance?  As this is a board that deals primarily with 
regulatory/compliance issues, I thought the following article was pertinent to 
our cause and deserving of consideration.FEDS AS THOUGHT LEADERS: A 
BACK-DOOR COMPLIANCE DEFENSE TAKES SHAPE 

  By Richard L. Cassin   | 
Wednesday, November 11, 2015 at 7:53AM Assistant Attorney General Leslie 
Caldwell said last week the DOJ's hiring of a compliance counsel doesn't mean 
the agency is "moving toward recognizing or instituting a 'compliance 
defense.'" What then will the compliance counsel do? "She will help us evaluate 
each compliance program on a case-by-case basis -- just as the department 
always has -- but with a more expert eye," AAG Caldwell told a gethering 

  of compliance officers in New York. Caldwell, pictured above, then set out 
the factors the DOJ compliance counsel will assess: Does the institution ensure 
that its directors and senior managers provide strong, explicit and visible 
support for its corporate compliance policies? 
Do the people who are responsible for compliance have stature within the 
company? Do compliance teams get adequate funding and access to necessary 
resources? Of course, we won’t expect that a smaller company has the same 
compliance resources as a Fortune-50 company. 
Are the institution’s compliance policies clear and in writing? Are they 
easily understood by employees? Are the policies translated into languages 
spoken by the company’s employees? 
Does the institution ensure that its compliance policies are effectively 
communicated to all employees? Are its written policies easy for employees to 
find? Do employees have repeated training, which should include direction 
regarding what to do or with whom to consult when issues arise? 
Does the institution review its policies and practices to keep them up to date 
with evolving risks and circumstances? This is especially important if a 
U.S.-based entity acquires or merges with another business, especially a 
foreign one. 
Are there mechanisms to enforce compliance policies? Those include both 
incentivizing good compliance and disciplining violations. Is discipline even 
handed? The department does not look favorably on situations in which low-level 
employees who may h