Re: [PSES] NRTL invoices

2016-02-12 Thread John Allen
Morning

 

"Someone" really should have reported at least the first 2  of those
incidents to the relevant NTRL or to OSHA because that totally devalues the
FUS concept and is effectively fraud and could lead to dangerous products on
the US market L. OTOH, I doubt that anyone in the actual factories would
have worried much - anything for an "quiet life"!

 

Some of the others display a chronic lack of technical training and/or
expertise on the parts of the auditors in question, and could also lead to
cases where auditors don't spot safety-related discrepancies, and don't
issue stop shipment/variation notices, where they should have - and they
reflect very badly on the NTRLs which employ them. So what "qualifications"
(etc.) are the NRTLs required to ensure that their auditors have?

 

John Allen

W.London, UK

 

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: 11 February 2016 23:05
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] NRTL invoices

 

Refusal to pay for any audit services rendered that the NRTL deems necessary
will result in suspension of right to apply their mark to any products.

 

Stuff seen during various NRTL FUS audits:

- Asia sites - auditor arrives 0830, reads papers and drinks coffee until
1100, returns at 1300 with papers for QA to sign.

- Latin America site - auditor arrives 1030, asks what is in production,
logs times of 0800-1500 on audit form, then leaves about 1100.

- U.S. customer site - auditor arrives 0930, inspects units that do not bear
his agency's marks (and have never been assessed by any NRTL), writes
variation notice, then leaves about 1100.

- Canada customer site - auditor arrives 0730 goes directly to receiving
inspection and goes through files and component records then abruptly walks
out at 1600 with the audit report taped to the QA office door.

- Asia site - auditor writes variation notice because hi-pot test level is
too high. Their agency required 2500V, another wanted 3kV.

- Asia site - auditor writes variation notice because product is being
hi-potted twice during production process, and because one test level is a
bit higher than the report.

- Latin America site - auditor issues variation notice because cord sets
were bulk-packed in a separate box. 

- Latin America site - auditor issues variation notice because no ground
bond test is being done on a class II construction (auditor previously saw
it being done on a class I product). And there was no requirement in the
construction report.

 

Brian

 

-Original Message-

From: Richard Nute [ <mailto:ri...@ieee.org> mailto:ri...@ieee.org]

Sent: Thursday, February 11, 2016 2:27 PM

To: Brian O'Connell;  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
EMC-PSTC@LISTSERV.IEEE.ORG

Subject: RE: [PSES] NRTL invoices

 

When I was hosting the FUS, I had a rule that inspection would not interrupt
or disrupt production.  I insisted that the inspector identify the products
to be inspected, the construction, and the components before we went to the
factory floor.  If the product was not in production that day, then it could
not be inspected.  I determined when it would be in production, and the
inspector could return on that date.  (Never happened.)  I refused to pay
for a non-inspection. 

 

I set a goal of zero variances from an inspection.

I did my own inspection in advance of when the unannounced inspection would
take place.

(Inspections at that time were quarterly; I could anticipate a window in
which the inspection would

occur.)  I found and corrected either the construction or the report.  The
certification house couldn't believe we could go so long -- two years --
without a variance, so they sent managers to oversee the inspections.  Zero
variances.

 

Rich

 

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Fo

[PSES] NRTL invoices

2016-02-11 Thread Brian O'Connell
Starting last year, noticed that some NRTLs are charging twice for same audit. 
For example - same equipment category, same file reference, but getting charged 
factory FUS audit fees for both audit of products in production and 'Production 
Ready'. Previously, was charged for PR audit only when nothing from that 
file/volume in production. When asked, these NRTLs either ignore the question, 
or kindly inform us to go somewhere else.

Anyone else able to successfully push back these double charges for factory 
audits?

Thanks,
Brian

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Re: [PSES] NRTL invoices

2016-02-11 Thread Richard Nute
Check your contract!


> -Original Message-
> 
> Starting last year, noticed that some NRTLs are
charging
> twice for same audit. For example - same
equipment
> category, same file reference, but getting
charged
> factory FUS audit fees for both audit of
products in
> production and 'Production Ready'. Previously,
was
> charged for PR audit only when nothing from that
> file/volume in production. When asked, these
NRTLs
> either ignore the question, or kindly inform us
to go
> somewhere else.
> 
> Anyone else able to successfully push back these
> double charges for factory audits?
> 
> Thanks,
> Brian
> 

-

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Re: [PSES] NRTL invoices

2016-02-11 Thread Brian O'Connell
Generally good advice, and that was the first thing looked at -> just generic, 
vague stuff about fees.

Methinks the days of having multiple agency marks on our stuff are ending. The 
remaining agency mark(s) will be those whose services actually add value to my 
employer's products. The compliance engineering community should push back. No 
longer view many compliance agencies as being part of a sustainable and 
rational economic model. 

Brian

-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Thursday, February 11, 2016 11:31 AM
To: Brian O'Connell; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] NRTL invoices

Check your contract!


> -Original Message-
> 
> Starting last year, noticed that some NRTLs are
charging
> twice for same audit. For example - same
equipment
> category, same file reference, but getting
charged
> factory FUS audit fees for both audit of
products in
> production and 'Production Ready'. Previously,
was
> charged for PR audit only when nothing from that
> file/volume in production. When asked, these
NRTLs
> either ignore the question, or kindly inform us
to go
> somewhere else.
> 
> Anyone else able to successfully push back these
> double charges for factory audits?
> 
> Thanks,
> Brian
> 

-

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Re: [PSES] NRTL invoices

2016-02-11 Thread Richard Nute
> - U.S. customer site - auditor arrives 0930,
inspects
> units that do not bear his agency's marks (and
have
> never been assessed by any NRTL), writes
variation
> notice, then leaves about 1100.

Why was the inspector allowed to inspect units
that do not bear his certification house's mark?
Do not pay for this inspection.


Rich

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Re: [PSES] NRTL invoices

2016-02-11 Thread Richard Nute
> - Asia site - auditor writes variation notice
because hi-
> pot test level is too high. Their agency
required 2500V,
> another wanted 3kV.

> - Asia site - auditor writes variation notice
because
> product is being hi-potted twice during
production
> process, and because one test level is a bit
higher than
> the report.

Conventional wisdom is that too high hi-pot test
voltage or repeated hi-pot test damages solid
insulation. 

Demonstrates a lack of science and engineering.

There is no evidence of this.  Damage to solid
insulation is due to partial discharge which
occurs in small voids in the solid insulation.
And, at much higher than 3000 volts. 


Rich

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Re: [PSES] NRTL invoices

2016-02-11 Thread Richard Nute
> Refusal to pay for any audit services rendered
that the
> NRTL deems necessary will result in suspension
of right
> to apply their mark to any products.

Pay for services rendered.  If no service is
rendered, then don't sign that there was service
(and indicate at that time that there was no
service and you won't pay).   Or indicate on the
service slip that there was no service.  The
inspector will object, but you can do it.  Be
hard-nosed.  Certification houses are not
altruistic; they don't like to lose a customer and
the revenue.  


Rich

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Re: [PSES] NRTL invoices

2016-02-11 Thread Brian O'Connell
Refusal to pay for any audit services rendered that the NRTL deems necessary 
will result in suspension of right to apply their mark to any products.

Stuff seen during various NRTL FUS audits:
- Asia sites - auditor arrives 0830, reads papers and drinks coffee until 1100, 
returns at 1300 with papers for QA to sign.
- Latin America site - auditor arrives 1030, asks what is in production, logs 
times of 0800-1500 on audit form, then leaves about 1100.
- U.S. customer site - auditor arrives 0930, inspects units that do not bear 
his agency's marks (and have never been assessed by any NRTL), writes variation 
notice, then leaves about 1100.
- Canada customer site - auditor arrives 0730 goes directly to receiving 
inspection and goes through files and component records then abruptly walks out 
at 1600 with the audit report taped to the QA office door.
- Asia site - auditor writes variation notice because hi-pot test level is too 
high. Their agency required 2500V, another wanted 3kV.
- Asia site - auditor writes variation notice because product is being 
hi-potted twice during production process, and because one test level is a bit 
higher than the report.
- Latin America site - auditor issues variation notice because cord sets were 
bulk-packed in a separate box. 
- Latin America site - auditor issues variation notice because no ground bond 
test is being done on a class II construction (auditor previously saw it being 
done on a class I product). And there was no requirement in the construction 
report.

Brian

-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Thursday, February 11, 2016 2:27 PM
To: Brian O'Connell; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] NRTL invoices

When I was hosting the FUS, I had a rule that
inspection would not interrupt or disrupt
production.  I insisted that the inspector
identify the products to be inspected, the
construction, and the components before we went to
the factory floor.  If the product was not in
production that day, then it could not be
inspected.  I determined when it would be in
production, and the inspector could return on that
date.  (Never happened.)  I refused to pay for a
non-inspection. 

I set a goal of zero variances from an inspection.
I did my own inspection in advance of when the
unannounced inspection would take place.
(Inspections at that time were quarterly; I could
anticipate a window in which the inspection would
occur.)  I found and corrected either the
construction or the report.  The certification
house couldn't believe we could go so long -- two
years -- without a variance, so they sent managers
to oversee the inspections.  Zero variances.

Rich

-

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discussion list. To post a message to the list, send your e-mail to 
<emc-p...@ieee.org>

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Re: [PSES] NRTL invoices

2016-02-11 Thread John Allen
Richard

 

Almost ditto over a 4 year period at HP in Bristol with UL FUS and CSA
Certification, and then Category Certification FUS, for the same reasons.

 

The "almost" ?

 

We had a UL FUS inspection (done then by BSI inspectors) that included a
product where D.A. was with a US division,  but they had changed the product
"very" slightly by changing a plastic material from V-2 to HB for physical
properties reasons without clearing that with UL - the UL report still said
V-2  but the material was actually HB and the suppliers'  certificates
confirmed the latter. The inspector spotted that and promptly, and quite
correctly (!), issued a non-compliance and so we got a "stop ship". The US
division then  took it up with UL and it gave a 90-day extension for use of
the HB material because it was in a location where ignition was very
unlikely in the event of any internal component failure. We restarted
shipment within a week IIRC.

 

Anyone in the UK need some "help" on issues like this because I would be
delighted to assist J?

 

As for the original reason for this series of posts, I have considerable
sympathy for the complaint, and I would either ask for "clarification" from
the NTRL or just walk away to some other NTRL after confirming that they
would not be doing the same thing (might consider a slight uplift for
covering multiple products, but only by prior agreement! 

 

John Allen

W.London, UK

 

-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 11 February 2016 22:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] NRTL invoices

 

When I was hosting the FUS, I had a rule that inspection would not interrupt
or disrupt production.  I insisted that the inspector identify the products
to be inspected, the construction, and the components before we went to the
factory floor.  If the product was not in production that day, then it could
not be inspected.  I determined when it would be in production, and the
inspector could return on that date.  (Never happened.)  I refused to pay
for a non-inspection. 

 

I set a goal of zero variances from an inspection.

I did my own inspection in advance of when the unannounced inspection would
take place.

(Inspections at that time were quarterly; I could anticipate a window in
which the inspection would

occur.)  I found and corrected either the construction or the report.  The
certification house couldn't believe we could go so long -- two years --
without a variance, so they sent managers to oversee the inspections.  Zero
variances.

 

 

Rich

 

 

 

 

> -Original Message-

> From: Brian O'Connell

> [ <mailto:oconne...@tamuracorp.com> mailto:oconne...@tamuracorp.com]

> Sent: Thursday, February 11, 2016 11:47 AM

> To:  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG

> Subject: Re: [PSES] NRTL invoices

> 

> Generally good advice, and that was the first

thing

> looked at -> just generic, vague stuff about

fees.

> 

> Methinks the days of having multiple agency

marks on

> our stuff are ending. The remaining agency

mark(s) will

> be those whose services actually add value to my employer's products. 

> The compliance engineering community should push back. No longer view 

> many compliance agencies as being part of a

sustainable and

> rational economic model.

> 

> Brian

> 

> -Original Message-

> From: Richard Nute [ <mailto:ri...@ieee.org> mailto:ri...@ieee.org]

> Sent: Thursday, February 11, 2016 11:31 AM

> To: Brian O'Connell; EMC-

>  <mailto:p...@listserv.ieee.org> p...@listserv.ieee.org

> Subject: RE: [PSES] NRTL invoices

> 

> Check your contract!

> 

> 

> > -Original Message-

> >

> > Starting last year, noticed that some NRTLs

are

> charging

> > twice for same audit. For example - same

> equipment

> > category, same file reference, but getting

> charged

> > factory FUS audit fees for both audit of

> products in

> > production and 'Production Ready'. Previously,

> was

> > charged for PR audit only when nothing from

that

> > file/volume in production. When asked, these

> NRTLs

> > either ignore the question, or kindly inform

us

> to go

> > somewhere else.

> >

> > Anyone else able to successfully push back

these

> > double charges for factory audits?

> >

> > Thanks,

> > 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 mailto:p...@ieee.org>
p...@ieee.org>

> 

> All emc-pstc postings are archived and

searchab

Re: [PSES] NRTL invoices

2016-02-11 Thread Richard Nute
When I was hosting the FUS, I had a rule that
inspection would not interrupt or disrupt
production.  I insisted that the inspector
identify the products to be inspected, the
construction, and the components before we went to
the factory floor.  If the product was not in
production that day, then it could not be
inspected.  I determined when it would be in
production, and the inspector could return on that
date.  (Never happened.)  I refused to pay for a
non-inspection. 

I set a goal of zero variances from an inspection.
I did my own inspection in advance of when the
unannounced inspection would take place.
(Inspections at that time were quarterly; I could
anticipate a window in which the inspection would
occur.)  I found and corrected either the
construction or the report.  The certification
house couldn't believe we could go so long -- two
years -- without a variance, so they sent managers
to oversee the inspections.  Zero variances.


Rich




> -Original Message-
> From: Brian O'Connell
> [mailto:oconne...@tamuracorp.com]
> Sent: Thursday, February 11, 2016 11:47 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] NRTL invoices
> 
> Generally good advice, and that was the first
thing
> looked at -> just generic, vague stuff about
fees.
> 
> Methinks the days of having multiple agency
marks on
> our stuff are ending. The remaining agency
mark(s) will
> be those whose services actually add value to my
> employer's products. The compliance engineering
> community should push back. No longer view many
> compliance agencies as being part of a
sustainable and
> rational economic model.
> 
> Brian
> 
> -Original Message-
> From: Richard Nute [mailto:ri...@ieee.org]
> Sent: Thursday, February 11, 2016 11:31 AM
> To: Brian O'Connell; EMC-
> p...@listserv.ieee.org
> Subject: RE: [PSES] NRTL invoices
> 
> Check your contract!
> 
> 
> > -Original Message-
> >
> > Starting last year, noticed that some NRTLs
are
> charging
> > twice for same audit. For example - same
> equipment
> > category, same file reference, but getting
> charged
> > factory FUS audit fees for both audit of
> products in
> > production and 'Production Ready'. Previously,
> was
> > charged for PR audit only when nothing from
that
> > file/volume in production. When asked, these
> NRTLs
> > either ignore the question, or kindly inform
us
> to go
> > somewhere else.
> >
> > Anyone else able to successfully push back
these
> > double charges for factory audits?
> >
> > Thanks,
> > Brian
> >
> 
> -
>
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--
> This message is from the IEEE Product Safety
> Engineering Society emc-pstc discussion list. To
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> 
> All emc-pstc postings are archived and
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> 
> 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:
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> (including how to unsubscribe)
> List rules:
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> Mike Cantwell <mcantw...@ieee.org>
> 
> For policy questions, send mail to:
> Jim Bacher:  <j.bac...@ieee.org>
> David Heald: <dhe...@gmail.com>

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David Heald: <dhe...@gmail.com>


Re: [PSES] NRTL invoices

2016-02-11 Thread Nyffenegger, Dave
I certainly question the need for multiple OSHA NRTL marks on a product when 
they should all represent the same thing.  I don't do it for my products.   I 
expect no getting around multiple marks each meeting the needs for different 
markets served if the marks are in fact required.

-Dave

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: Thursday, February 11, 2016 2:47 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] NRTL invoices

Generally good advice, and that was the first thing looked at -> just generic, 
vague stuff about fees.

Methinks the days of having multiple agency marks on our stuff are ending. The 
remaining agency mark(s) will be those whose services actually add value to my 
employer's products. The compliance engineering community should push back. No 
longer view many compliance agencies as being part of a sustainable and 
rational economic model. 

Brian

-Original Message-
From: Richard Nute [mailto:ri...@ieee.org]
Sent: Thursday, February 11, 2016 11:31 AM
To: Brian O'Connell; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] NRTL invoices

Check your contract!


> -Original Message-
> 
> Starting last year, noticed that some NRTLs are
charging
> twice for same audit. For example - same
equipment
> category, same file reference, but getting
charged
> factory FUS audit fees for both audit of
products in
> production and 'Production Ready'. Previously,
was
> charged for PR audit only when nothing from that file/volume in 
> production. When asked, these
NRTLs
> either ignore the question, or kindly inform us
to go
> somewhere else.
> 
> Anyone else able to successfully push back these double charges for 
> factory audits?
> 
> Thanks,
> Brian
> 

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This message is from the IEEE Product Safety Engineering Society emc-pstc 
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All emc-pstc postings are archived and searchable on the web at:
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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

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