Re: CDMA Product Approvals
I read in !emc-pstc that garymcintu...@aol.com wrote (in 37.3cd8d6ac.2 c725...@aol.com) about 'CDMA Product Approvals' on Mon, 18 Aug 2003: So I'm curious what was CDMA originally designed for? Anybody know. I suspect you will find an original paper back 50 years ago, or even more. The theory in this area was far in advance of the hardware capable of implementing it. Some of the information may still be classified. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: CDMA Product Approvals
The IS-95 implementation of CDMA was designed to improve call handling density by a factor of 10 or so over AMPS. I am not aware of any older versions of CDMA. D-AMPS (IS-54) was a TDMA variant. The Qualcomm CDMA performance testing were performend sometime in 1988/1989. So, it seems that the ethernet version predates the cellular version, but I could be wrong! Hans Mellberg Engineering Manager BACL 230 Commercial Street Sunnyvale CA 94085 USA 408-732-9162 x38 408-732-9164 fax - Original Message - From: garymcintu...@aol.com To: michael.sundst...@nokia.com ; lothar.schm...@cetecomusa.com ; cblac...@airspan.com ; alex.mcn...@ingenicofortronic.com ; emc-p...@majordomo.ieee.org Sent: Monday, August 18, 2003 8:56 AM Subject: Re: CDMA Product Approvals So now I'm curious, which came first Ethernet or cell phone. CDMA is also used on Ethernet. At least the original simplex versions - triple shielded coax, then cheaper net - essentially phone cables. It wasn't needed with full duplex PTP transmission, which some might argue isn't true Ethernet. I remember seeing those old brick sized cell (mobile?) phones but thought they were slightly behind LAN's and the precursor to the Internet ARPANET (probably have wildly misspelled that) seems to have been around much longer than that. So I'm curious what was CDMA originally designed for? Anybody know. Gary
RE: CDMA Product Approvals
From: garymcintu...@aol.com [mailto:garymcintu...@aol.com] Sent: Monday, August 18, 2003 8:56 AM To: michael.sundst...@nokia.com; lothar.schm...@cetecomusa.com; cblac...@airspan.com; alex.mcn...@ingenicofortronic.com; emc-p...@majordomo.ieee.org Subject: Re: CDMA Product Approvals So now I'm curious, which came first Ethernet or cell phone. CDMA is also used on Ethernet. At least the original simplex versions - triple shielded coax, then cheaper net - essentially phone cables. It wasn't needed with full duplex PTP transmission, which some might argue isn't true Ethernet. I remember seeing those old brick sized cell (mobile?) phones but thought they were slightly behind LAN's and the precursor to the Internet ARPANET (probably have wildly misspelled that) seems to have been around much longer than that. So I'm curious what was CDMA originally designed for? Anybody know. Gary Gary: I seem to recall Titan / Linkabit using CDMA for military data links around 1978. And did you ever lug around one of those Motorola FM handy-talkies from back in the early 60's? IIRC, they operated around 50 MHz, and must have weighed 20 pounds. Regards, Ed Ed Price ed.pr...@cubic.com WB6WSN NARTE Certified EMC Engineer Technician Electromagnetic Compatibility Lab Cubic Defense Systems San Diego, CA USA 858-505-2780 (Voice) 858-505-1583 (Fax) Military Avionics EMC Is Our Specialty
Re: CDMA Product Approvals
So now I'm curious, which came first Ethernet or cell phone. CDMA is also used on Ethernet. At least the original simplex versions - triple shielded coax, then cheaper net - essentially phone cables. It wasn't needed with full duplex PTP transmission, which some might argue isn't true Ethernet. I remember seeing those old brick sized cell (mobile?) phones but thought they were slightly behind LAN's and the precursor to the Internet ARPANET (probably have wildly misspelled that) seems to have been around much longer than that. So I'm curious what was CDMA originally designed for? Anybody know. Gary
RE: CDMA Product Approvals
But this is not what Alex is asking for. He is looking to implement a CDMA module, which I understand enables a certain device to communicate via the cellular phone service. Lothar Schmidt BQB Technical Manager EMC/Radio/SAR CETECOM Inc. 411 Dixon Landing Road Milpitas, CA 95035 ' +1 408 586 6214 7 +1 408 586 6299 From: Charles Blackham [mailto:cblac...@airspan.com] Sent: Friday, August 15, 2003 8:10 AM To: Lothar Schmidt; Alex McNeil; emc-p...@majordomo.ieee.org Subject: RE: CDMA Product Approvals CDMA is used in Europe for some Fixed radio application regards Charlie From: Lothar Schmidt [mailto:lothar.schm...@cetecomusa.com] Sent: 15 August 2003 15:33 To: Charles Blackham; Alex McNeil; emc-p...@majordomo.ieee.org Subject: RE: CDMA Product Approvals CDMA is a cellular phone technology, which is not used in Europe GSM is the used technology in this region. FCC requirements depending on the used frequency band FCC part 22 and 24 Lothar Schmidt BQB Technical Manager EMC/Radio/SAR CETECOM Inc. 411 Dixon Landing Road Milpitas, CA 95035 ' +1 408 586 6214 7 +1 408 586 6299 From: Charles Blackham [mailto:cblac...@airspan.com] Sent: Friday, August 15, 2003 5:33 AM To: Alex McNeil; emc-p...@majordomo.ieee.org Subject: RE: CDMA Product Approvals Alex Assuming the product is fixed, have a look at EN 301 753 for RF, and EN 301 489 family for EMC in Europe, available from www.etsi.org. FCC parts 2, 15 and 24. regards Charlie Blackham Approvals Manager Airspan Communications Ltd. From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sent: 15 August 2003 09:56 To: emc-p...@majordomo.ieee.org Subject: CDMA Product Approvals Hi Group, This is a technology I know nothing about (never heard off!) until my marketing friends emailed me the approvals question! What are the approval requirements for a product that employs a wireless CDMA module. I think I may be asking too much for worldwide standards (although it would be very much appreciated), Europe? N.America? I have also heard I need EIRP measurements? Thanks in advance for your expert help. Kind Regards Alex McNeil This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Download free spam killer at http://eliminatespam.com Download free spam killer at http://eliminatespam.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: CDMA Product Approvals
CDMA is used in Europe for some Fixed radio application regards Charlie From: Lothar Schmidt [mailto:lothar.schm...@cetecomusa.com] Sent: 15 August 2003 15:33 To: Charles Blackham; Alex McNeil; emc-p...@majordomo.ieee.org Subject: RE: CDMA Product Approvals CDMA is a cellular phone technology, which is not used in Europe GSM is the used technology in this region. FCC requirements depending on the used frequency band FCC part 22 and 24 Lothar Schmidt BQB Technical Manager EMC/Radio/SAR CETECOM Inc. 411 Dixon Landing Road Milpitas, CA 95035 ' +1 408 586 6214 7 +1 408 586 6299 From: Charles Blackham [mailto:cblac...@airspan.com] Sent: Friday, August 15, 2003 5:33 AM To: Alex McNeil; emc-p...@majordomo.ieee.org Subject: RE: CDMA Product Approvals Alex Assuming the product is fixed, have a look at EN 301 753 for RF, and EN 301 489 family for EMC in Europe, available from www.etsi.org. FCC parts 2, 15 and 24. regards Charlie Blackham Approvals Manager Airspan Communications Ltd. From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sent: 15 August 2003 09:56 To: emc-p...@majordomo.ieee.org Subject: CDMA Product Approvals Hi Group, This is a technology I know nothing about (never heard off!) until my marketing friends emailed me the approvals question! What are the approval requirements for a product that employs a wireless CDMA module. I think I may be asking too much for worldwide standards (although it would be very much appreciated), Europe? N.America? I have also heard I need EIRP measurements? Thanks in advance for your expert help. Kind Regards Alex McNeil This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Download free spam killer at http://eliminatespam.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: CDMA Product Approvals
CDMA is a cellular phone technology, which is not used in Europe GSM is the used technology in this region. FCC requirements depending on the used frequency band FCC part 22 and 24 Lothar Schmidt BQB Technical Manager EMC/Radio/SAR CETECOM Inc. 411 Dixon Landing Road Milpitas, CA 95035 ' +1 408 586 6214 7 +1 408 586 6299 From: Charles Blackham [mailto:cblac...@airspan.com] Sent: Friday, August 15, 2003 5:33 AM To: Alex McNeil; emc-p...@majordomo.ieee.org Subject: RE: CDMA Product Approvals Alex Assuming the product is fixed, have a look at EN 301 753 for RF, and EN 301 489 family for EMC in Europe, available from www.etsi.org. FCC parts 2, 15 and 24. regards Charlie Blackham Approvals Manager Airspan Communications Ltd. From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sent: 15 August 2003 09:56 To: emc-p...@majordomo.ieee.org Subject: CDMA Product Approvals Hi Group, This is a technology I know nothing about (never heard off!) until my marketing friends emailed me the approvals question! What are the approval requirements for a product that employs a wireless CDMA module. I think I may be asking too much for worldwide standards (although it would be very much appreciated), Europe? N.America? I have also heard I need EIRP measurements? Thanks in advance for your expert help. Kind Regards Alex McNeil This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Download free spam killer at http://eliminatespam.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: CDMA Product Approvals
Alex Assuming the product is fixed, have a look at EN 301 753 for RF, and EN 301 489 family for EMC in Europe, available from www.etsi.org. FCC parts 2, 15 and 24. regards Charlie Blackham Approvals Manager Airspan Communications Ltd. From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sent: 15 August 2003 09:56 To: emc-p...@majordomo.ieee.org Subject: CDMA Product Approvals Hi Group, This is a technology I know nothing about (never heard off!) until my marketing friends emailed me the approvals question! What are the approval requirements for a product that employs a wireless CDMA module. I think I may be asking too much for worldwide standards (although it would be very much appreciated), Europe? N.America? I have also heard I need EIRP measurements? Thanks in advance for your expert help. Kind Regards Alex McNeil This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
CDMA Product Approvals
Hi Group, This is a technology I know nothing about (never heard off!) until my marketing friends emailed me the approvals question! What are the approval requirements for a product that employs a wireless CDMA module. I think I may be asking too much for worldwide standards (although it would be very much appreciated), Europe? N.America? I have also heard I need EIRP measurements? Thanks in advance for your expert help. Kind Regards Alex McNeil This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
SV: CDMA Product Approvals
Hello Alex, For Europe you may check for the appropriate standards for approval on http://europa.eu.int/comm/enterprise/newapproach/standardization/harmstds/re flist/radiotte.html Check: * EN 50385:2002 Product standard to demonstrate the compliance of radio base stations and fixed terminal stations for wireless telecommunication systems with the basic restrictions or the reference levels related to human exposure to radio frequency electromagnetic fields (110 MHz - 40 GHz) - General public * To see if you need EIRP measurements, EN 50385 is on the list above. Best regards Helge Knudsen Test Approval manager Niros Telecommunication Hirsemarken 5 DK-3520 Farum Denmark Tel +45 44 34 22 51 Fax +45 44 99 28 08 email h.knud...@niros.com Fra: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sendt: 15. august 2003 10:56 Til: emc-p...@majordomo.ieee.org Emne: CDMA Product Approvals Hi Group, This is a technology I know nothing about (never heard off!) until my marketing friends emailed me the approvals question! What are the approval requirements for a product that employs a wireless CDMA module. I think I may be asking too much for worldwide standards (although it would be very much appreciated), Europe? N.America? I have also heard I need EIRP measurements? Thanks in advance for your expert help. Kind Regards Alex McNeil This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Multiplex TTE Product Approvals
Hi Group, I thought I was handling this RTTE standards applicability quite well until the latest proposed product specification for Europe, Australia and N.America (I have to fill in the blank approvals stuff myself) landed on my desk. It has placed me in a state of uncertainty...am I covering all Approvals issues I am seeking members advice on what standards I should be seeking. As you can see I have attempted this myself but is it correct and blanks need to be filled in? I would appreciate replies from those members even though they may be only familiar with a particular continent. EMC, General EU: EN55022 Class B, EN55024, Automotive Directive 95/94/EC (to allow vehicle use) USA: FCC Part 15 (or ICES-003 or CISPR22) Canada: ICES-003 (or FCC Part 15 or CISPR22) Australia: EN55022 Safety, General EU: EN60950-1:2001 NAmerica: ULC60950:2000 Australia: IEC60950-1:2001 CB Certificate Dual Band GSM/GPRS 900-1800MHZ and/or 850-1900MHz modules, requirements: GSM(11.10): ETS 300 607-1 NAmerica? Australia? RF EU: EN 301 489-1, EN 301 489-7 NAmerica RF? Australia RF? EMC: EN 301 419-1 NAmerica EMC? Australia EMC? SAR (EU): ES 59005:1998 per ICNIRP guidelines SAR (NA): ANSI C95.1:1992 SAR (AUS): AS/NZ 2772.1 Bluetooth module (100m) Bluetooth RF EU: EN300 328 Bluetooth RF USA: FCC Part 15 Bluetooth RF Canada: IC GL36 Bluetooth RF Australia: ?? EMC EU: ETS300 826, EN301-489-1 and EN301 489-3 EMC NAmerica? EMC Australia? Analogue Modem EU: TBR21 (guideline only not mandatory) USA: TIA/EIA/IS-968 (or CS-03) Canada: CS-03 (or TIA/EIA/IS-968) Australia: TS002 Laser Bar Code scanner module (IEC Class 2) Safety EU:EN60825-2 NAmerica:CDRH 1040 Australia?? Touchscreen Part of above Safety Standards, no special requirements? CDMA Interface No special requirements LAN802.11b Interface No special requirements WAN Interface No special requirements Again, I would appreciate any feedback. Kind Regards Alex McNeil Principal Engineer Tel: +44 (0)131 479 8375 Fax: +44 (0)131 479 8321 email: alex.mcn...@ingenicofortronic.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: Quality Assurance and Product Approvals
Interesting thread . . . At the companies for which I managed the regulatory programs over the last 20 years, it has always been engineering's responsibility to release to production a compliant product,and I have always been a member of the engineering department. In the early days, before regualtory compliance became the industry that it is now, it was basically 'putting out the fires' after formal evaluation. After a couple of costly rework projects, 'design for compliance' became my mantra, and I have been able to carry that along to other companies as well. And fortunately for me, it has been well received. As part of the design team, I am able review all product designs before and during the prototype stage and provide guidance/input as necessary. Each time I announce that the product passed the first time (don't get me wrong, I do have the occassional 'gotcha') it gets easier to justify the 'design for compliance' concept. It's a lot more difficult to cost-effectively rework a product. So, besides making my job easier (and the cognizant design engineer's as well), 'design for compliance' does save costs in the long run. Additionally, as part of the corporation's quality team providing the opportunity to ensure continued compliance. John Juhasz Fiber Options Bohemia, NY -Original Message- From: Tania Grant [mailto:taniagr...@msn.com] Sent: Wednesday, November 28, 2001 11:15 PM To: John Woodgate; emc-p...@majordomo.ieee.org Subject: Re: Quality Assurance and Product Approvals My personal experience agrees with John. I prefer to work with Engineering and reporting someplace in Engineering;-- it makes my job easier when compliance is designed right from the very beginning rather than be responsible later to get it past agencies. At that point, it suddenly became my problem when it did not comply! When I told management that they should fix things before we submitted the product formally, the response was let's see what the agency will do This left me frustrated and embarrassed my ego. If you catch things in the very beginning, engineering is usually amenable to changing things. Later, it is very difficult and, obviously, much more costly. taniagr...@msn.com mailto:taniagr...@msn.com - Original Message - From: John Woodgate Sent: Wednesday, November 28, 2001 2:48 PM To: emc-p...@majordomo.ieee.org Subject: Re: Quality Assurance and Product Approvals I read in !emc-pstc that Mark Werlwas mark.werl...@home.com wrote (in 006701c1782b$69f56020$6401a...@frmt1.sfba.home.com) about 'Quality Assurance and Product Approvals', on Wed, 28 Nov 2001: On the aspect of the where to put Product Safety/Compliance in the organization discussion bears mentioning on the forum. In general I advocate that the Product Safety/Compliance department be separate from Engineering, Sales, and Operations. The Safety/Compliance group should avoid conflicts of interest (real or apparent) that may arise in the above mentioned groups. Even the occasional appearance of a conflicting interest can undermine the credibility of the Safety/Compliance team. But this militates strongly against 'designing-in compliance', and is very liable to create a 'them and us' conflict between Design Engineering and Compliance. The *maintenance* of compliance in manufacture is a Quality function. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk After swimming across the Hellespont, I felt like a Hero. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Re: Quality Assurance and Product Approvals
Hi All, When I was with Xerox, Versatec Division, we were placed in the Engineering Services Dept. with Drafting and Component engineering. This worked very well and gave us input to the purchasing specifications as well as design considerations. Our relationship with Engineering was very good, with our manager sitting on the change review and material review boards. We reported ultimately to a Director of Engineering Services (and a good Director if you are out there Joyce), but not a VP. Scott leeschm...@aol.com wrote: Hi all, Interesting discussion. Here is my 2 cents. Must be about $1.00 worth by now. I once came upon an interesting compromise as to the organization chart position of compliance. They put it in test or quality, but funded it through the engineering budget. Not perfect, but it prevented engineering from squeezing the last 0.5 dB or hi pot voltage from the device. However it does encourage them to save money and design in compliance. I suppose in the best of all possible worlds this would not be necessary but it did seem to work. A VP of compliance is probably work the best, of course if they chose me for the position. Lee Schmitz Electrical safety compliance consultant --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Re: Quality Assurance and Product Approvals
Hi all, Interesting discussion. Here is my 2 cents. Must be about $1.00 worth by now. I once came upon an interesting compromise as to the organization chart position of compliance. They put it in test or quality, but funded it through the engineering budget. Not perfect, but it prevented engineering from squeezing the last 0.5 dB or hi pot voltage from the device. However it does encourage them to save money and design in compliance. I suppose in the best of all possible worlds this would not be necessary but it did seem to work. A VP of compliance is probably work the best, of course if they chose me for the position. Lee Schmitz Electrical safety compliance consultant --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Re: FW: Quality Assurance and Product Approvals - 2
I read in !emc-pstc that Charles Grasso chasgra...@hotmail.com wrote (in f32rklpgtfur2iz2mb100022...@hotmail.com) about 'FW: Quality Assurance and Product Approvals - 2', on Wed, 28 Nov 2001: My point is that IF the regulatory agencies allow ( however inadvertantly) products on the market place that fail then the message managers get is that it can't be that important. Incidentally it is my understanding that the FCC Class B procedures have resulted in PC that exceed the ClassB spec by as much as 20db. In principle, emission limits are accepted as satisfactory and retained if the number of complaints of interference is acceptably low. The emission level that causes interference is not a fixed value but depends very greatly on the location of the emitting equipment relative to potential victim equipment. So even emitters that are seriously non- compliant **may** not cause actual interference. As the disclaimers in many EMC emission standards say, the emission level that causes interference at a particular site may be *lower* than the established limit. While there are few survey results publicly available, AFAIK, 'thought experiments' indicate that in any given geographical area, there are 'hot spots' where emission levels are critical, and the total area of these hot spots may be less than 0.1% of the whole area. It is possible to calculate the effects of introducing emitters into such an area, taking into account numbers of emitters, their distribution of emission levels and the number and sensitivity of hot spots. I have not heard that there is any uniformity in the results of such calculations that allow useful conclusions to be drawn. So, in practice, releasing non-compliant products is like shooting at an unknown number of invisible targets of different sizes, with the intention of **missing** all of them! -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk After swimming across the Hellespont, I felt like a Hero. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Re: Quality Assurance and Product Approvals
My personal experience agrees with John. I prefer to work with Engineering and reporting someplace in Engineering;-- it makes my job easier when compliance is designed right from the very beginning rather than be responsible later to get it past agencies. At that point, it suddenly became my problem when it did not comply! When I told management that they should fix things before we submitted the product formally, the response was let's see what the agency will do This left me frustrated and embarrassed my ego. If you catch things in the very beginning, engineering is usually amenable to changing things. Later, it is very difficult and, obviously, much more costly. taniagr...@msn.com - Original Message - From: John Woodgate Sent: Wednesday, November 28, 2001 2:48 PM To: emc-p...@majordomo.ieee.org Subject: Re: Quality Assurance and Product Approvals I read in !emc-pstc that Mark Werlwas mark.werl...@home.com wrote (in 006701c1782b$69f56020$6401a...@frmt1.sfba.home.com) about 'Quality Assurance and Product Approvals', on Wed, 28 Nov 2001: On the aspect of the where to put Product Safety/Compliance in the organization discussion bears mentioning on the forum. In general I advocate that the Product Safety/Compliance department be separate from Engineering, Sales, and Operations. The Safety/Compliance group should avoid conflicts of interest (real or apparent) that may arise in the above mentioned groups. Even the occasional appearance of a conflicting interest can undermine the credibility of the Safety/Compliance team. But this militates strongly against 'designing-in compliance', and is very liable to create a 'them and us' conflict between Design Engineering and Compliance. The *maintenance* of compliance in manufacture is a Quality function. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk After swimming across the Hellespont, I felt like a Hero. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
RE: FW: Quality Assurance and Product Approvals - 2
Hi Dan, No arguement here. My point is that IF the regulatory agencies allow ( however inadvertantly) products on the market place that fail then the message managers get is that it can't be that important. Incidentally it is my understanding that the FCC Class B procedures have resulted in PC that exceed the ClassB spec by as much as 20db. From: Dan Teninty dteni...@dtec-associates.com Reply-To: Dan Teninty dteni...@dtec-associates.com To: Charles Grasso chasgra...@hotmail.com, emc-p...@majordomo.ieee.org Subject: RE: FW: Quality Assurance and Product Approvals Date: Wed, 28 Nov 2001 10:15:43 -0800 Charles, I would like to offer an explanation for EMC limits being set where they are and a reason for meeting or beating the limits. I agree, 0.5 dB doesn't seem like the end of the world and under management guidance/pressure to ship product and produce revenue, it takes a lot of conviction to announce that an additional turn or some tweaking of the design is required. Those who have ever supplied avionics or anything electric to Boeing have read somewhere in the spec that Boeing guarantees a certain level of performance from the aircraft electrical system. Frequency stability, THC, Voltage tolerance, etc. GREAT NEWS ! think the designers, until later in the spec they read the part about the stringent requirements on the box going into the airplane. It seems you can't have clean power without having clean boxes. The EMC limits in the standards are derived with some exceptions more or less along the limits established long ago by MIL-STD 461/462. These limits are well below where they would create problems in the environment, but allow for the inevitable degradation in product performance that can occur through component value shift, environmental conditions, and other fugitive variables. In order to be able to set limits for Radiated/Conducted susceptibility, an assumption has to be made about the Radiated/Conducted emissions and how much radiated/conducted noise there is in an intended environment. If, the product works fine was the criteria for emissions, then the task of hardening products against radiated and conducted energy would become much more difficult. My $0.02 Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: Charles Grasso [mailto:chasgra...@hotmail.com] Sent: Wednesday, November 28, 2001 9:29 AM To: dteni...@dtec-associates.com; emc-p...@majordomo.ieee.org Subject: Re: FW: Quality Assurance and Product Approvals Hi all, I have been following this discussion with great interest and could not resist adding my 2c. Lest face it - EMC is nothing more than pure overhead to any corporation. We all have experience of products that work perfectly fine yet fail the emissions profile by 0.5dB. I will contend that this experience far outweighs the opposite .Spinning a board or adding ferrites or adding shielding does nothing to help our discipline reputation. Couple that with the twilight zone impression of EMC and one can easily understand why most companies implement EMC into their process reluctantly. I will add to that one important factor The regulatory bodies - especially the FCC. Thanks in large part to the new FCC Class B compliance procedure ( which inadvertantly allows failing products into the market place) companies are more convinced that ever that EMC is more of an annoyance than a necessity. ( Some exceptions duly noted..) Unlike safety, there is no perceived benefit in squeezing that extra 0.5db out of the emissions profile at a cost od even .03c. The saving grace might be the immunity standards. I have had a whole lot more help when the design engineer actually witnesses his product doing wierd things. NARTE is straying in the direction of elitism. Worse than that they now have professors offering questions for inclusion in the NARTE exam. We need to be vigilant and keep the infulence of the academics to a minimum. Example: The ACES (Applied Computations Society) started a a group with the goal of PRACTICAL applications for comutation ..sound familiar. ?? It wasn't long before the academics (Phds the like) dominated the group and turned it to a purely theoretical group - a place to publish papers etc Now don't get me wrong.I am all for professors that are willing to teach and guide and mentor. There is how ever a human tendancy towards creeping elegance and we ned to ensure that the EMC discipline does not tend in that direction. My 2c Charles Grasso Ansoft Corporation From: Dan Teninty dteni...@dtec-associates.com Reply-To: Dan Teninty dteni...@dtec-associates.com To: PSTC IEEE-EMC emc-p...@majordomo.ieee.org Subject: FW: Quality Assurance and Product Approvals Date: Tue, 27 Nov 2001 12:11:38 -0800 Rich, After sending you my reply, I thought that I would open it up
Re: Quality Assurance and Product Approvals
I read in !emc-pstc that Mark Werlwas mark.werl...@home.com wrote (in 006701c1782b$69f56020$6401a...@frmt1.sfba.home.com) about 'Quality Assurance and Product Approvals', on Wed, 28 Nov 2001: On the aspect of the where to put Product Safety/Compliance in the organization discussion bears mentioning on the forum. In general I advocate that the Product Safety/Compliance department be separate from Engineering, Sales, and Operations. The Safety/Compliance group should avoid conflicts of interest (real or apparent) that may arise in the above mentioned groups. Even the occasional appearance of a conflicting interest can undermine the credibility of the Safety/Compliance team. But this militates strongly against 'designing-in compliance', and is very liable to create a 'them and us' conflict between Design Engineering and Compliance. The *maintenance* of compliance in manufacture is a Quality function. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk After swimming across the Hellespont, I felt like a Hero. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
RE: Quality Assurance and Product Approvals
Maybe this problem is even more insidious: Ask your HR department if they have a Radford Benchmark Salary Survey Job Description -for the work you do. (or equivalent to AON Consulting/Radford Associates service) I became aware some months ago that in some parts of the industry do not have a job description for the product safety functionary!! Maybe RBSS is unique in this, or my case is unusual, but the closest they could come for me was job code 8284 Software Technician 4. Beyond the 'specialist' level...there should be an 'esoteric level'.. heh, heh -obviously this is not close- So I've been listing what it is that I do. I'm up to 4 pages so far... Kyle MOO!
Re: Quality Assurance and Product Approvals
On the aspect of the where to put Product Safety/Compliance in the organization discussion bears mentioning on the forum. In general I advocate that the Product Safety/Compliance department be separate from Engineering, Sales, and Operations. The Safety/Compliance group should avoid conflicts of interest (real or apparent) that may arise in the above mentioned groups. Even the occasional appearance of a conflicting interest can undermine the credibility of the Safety/Compliance team. Over the years, I've been a member of various organizations, but always doing the same function (job). Regardless of organization, I did the same job. I've found that my effectiveness in doing the job is much better when I have been physically close to the RD teams. Likewise, I've found that my effectiveness in doing the job is much better when I have been a part of the same organization as RD. I've always taken the approach that safety is designed into the product from the very start of the project. Safety is an engineering discipline that, unfortunately, is not a part of engineering school curricula. So, it must be learned on the job, and I am the teacher. The RD engineer is responsible for designing the safety of the product; I am the consultant who explains the safety function, offers examples of acceptable designs, provides criteria for acceptable designs, evaluates and tests proposed designs, and ultimately agrees that the specific design meets the safety function requirement. Its a team effort. Credibility and expertise of the safety engineer is a key element to being accepted as a part of the team. Externally imposed organizational requirements that the Product Safety group be organizationally positioned to avoid conflict of interest seem to presuppose a management style and philosophy that I have not experienced. (I'm sure I've lived a sheltered life in terms of management style and philosophy!) :-) In an ideal world, the RD engineer would be trained in product safety. There would be no need for the product safety engineer I've described above. Safety testing would be included in the product functional testing, not as a separate entity. Third-party certifications would be obtained by a procurement group (charged with buying the right to use the mark). Best regards, Rich --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
RE: FW: Quality Assurance and Product Approvals
Charles, I would like to offer an explanation for EMC limits being set where they are and a reason for meeting or beating the limits. I agree, 0.5 dB doesn't seem like the end of the world and under management guidance/pressure to ship product and produce revenue, it takes a lot of conviction to announce that an additional turn or some tweaking of the design is required. Those who have ever supplied avionics or anything electric to Boeing have read somewhere in the spec that Boeing guarantees a certain level of performance from the aircraft electrical system. Frequency stability, THC, Voltage tolerance, etc. GREAT NEWS ! think the designers, until later in the spec they read the part about the stringent requirements on the box going into the airplane. It seems you can't have clean power without having clean boxes. The EMC limits in the standards are derived with some exceptions more or less along the limits established long ago by MIL-STD 461/462. These limits are well below where they would create problems in the environment, but allow for the inevitable degradation in product performance that can occur through component value shift, environmental conditions, and other fugitive variables. In order to be able to set limits for Radiated/Conducted susceptibility, an assumption has to be made about the Radiated/Conducted emissions and how much radiated/conducted noise there is in an intended environment. If, the product works fine was the criteria for emissions, then the task of hardening products against radiated and conducted energy would become much more difficult. My $0.02 Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: Charles Grasso [mailto:chasgra...@hotmail.com] Sent: Wednesday, November 28, 2001 9:29 AM To: dteni...@dtec-associates.com; emc-p...@majordomo.ieee.org Subject: Re: FW: Quality Assurance and Product Approvals Hi all, I have been following this discussion with great interest and could not resist adding my 2c. Lest face it - EMC is nothing more than pure overhead to any corporation. We all have experience of products that work perfectly fine yet fail the emissions profile by 0.5dB. I will contend that this experience far outweighs the opposite .Spinning a board or adding ferrites or adding shielding does nothing to help our discipline reputation. Couple that with the twilight zone impression of EMC and one can easily understand why most companies implement EMC into their process reluctantly. I will add to that one important factor The regulatory bodies - especially the FCC. Thanks in large part to the new FCC Class B compliance procedure ( which inadvertantly allows failing products into the market place) companies are more convinced that ever that EMC is more of an annoyance than a necessity. ( Some exceptions duly noted..) Unlike safety, there is no perceived benefit in squeezing that extra 0.5db out of the emissions profile at a cost od even .03c. The saving grace might be the immunity standards. I have had a whole lot more help when the design engineer actually witnesses his product doing wierd things. NARTE is straying in the direction of elitism. Worse than that they now have professors offering questions for inclusion in the NARTE exam. We need to be vigilant and keep the infulence of the academics to a minimum. Example: The ACES (Applied Computations Society) started a a group with the goal of PRACTICAL applications for comutation ..sound familiar. ?? It wasn't long before the academics (Phds the like) dominated the group and turned it to a purely theoretical group - a place to publish papers etc Now don't get me wrong.I am all for professors that are willing to teach and guide and mentor. There is how ever a human tendancy towards creeping elegance and we ned to ensure that the EMC discipline does not tend in that direction. My 2c Charles Grasso Ansoft Corporation From: Dan Teninty dteni...@dtec-associates.com Reply-To: Dan Teninty dteni...@dtec-associates.com To: PSTC IEEE-EMC emc-p...@majordomo.ieee.org Subject: FW: Quality Assurance and Product Approvals Date: Tue, 27 Nov 2001 12:11:38 -0800 Rich, After sending you my reply, I thought that I would open it up to the group for comment. I thought I would pass on the information about the NARTE certification for Product Safety engineers. Best regards, Dan Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: Dan Teninty [mailto:dteni...@dtec-associates.com] Sent: Tuesday, November 27, 2001 12:01 PM To: Rich Nute Subject: RE: Quality Assurance and Product Approvals Rich, I don't disagree with your point of view. It seems that there are a lot of MBA's
RE: Quality Assurance and Product Approvals
Charles, Yup, I knew that. I think that Dell recognizes that the whole compliance picture involves more than just getting some certification marks slapped on the product. Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: Charles Grasso [mailto:chasgra...@hotmail.com] Sent: Wednesday, November 28, 2001 9:33 AM To: dteni...@dtec-associates.com; ri...@sdd.hp.com; nutwoo...@nutwood.eu.com Cc: emc-p...@majordomo.ieee.org Subject: RE: Quality Assurance and Product Approvals One comment on the VP for compliance.. It is my undersyand that the Dell VP position does ALL the functions that are imposed by legislation on a compamy. EMC is one part. There is of course Safety, Environmental Issues, Lead-free solder etc.. Dell is taking a very professional approach to addresses ALL the issues - not just EMC. From: Dan Teninty dteni...@dtec-associates.com Reply-To: Dan Teninty dteni...@dtec-associates.com To: Rich Nute ri...@sdd.hp.com, nutwoo...@nutwood.eu.com CC: emc-p...@majordomo.ieee.org Subject: RE: Quality Assurance and Product Approvals Date: Tue, 27 Nov 2001 01:24:35 -0800 Rich, Dell Computers, as well as a few other major players, take a proactive approach to compliance and actually have a VP position for compliance. With a little investigation into the benefits of having a first rate compliance department with the ability to design for compliance, test to relevant standards, compile reports, participate on standards committees, and deal directly with world wide agencies I would think that most companies that have global markets would see both the short term and long term benefits to the bottom line. I would tend to include PC's into the ordinary products pile, wouldn't you? Companies that choose to take the adversarial approach to compliance by cutting corners or only doing the minimum to comply, save dollars in the short term, but pay later in lost customers, or worse, lawsuits. One of our clients, had a management team that took this denial/avoidance approach to NEBS. When the Telecom downturn came, they were left in a position where there was lots less demand and what demand there was, was for NEBS compliant products. Most of the management team that made those decisions have either left the company in recent right-sizing exercises, or are working in lesser positions. It seems that hindsight is always able to find a goat. When I explain the benefits of compliance to management teams, I try to focus on the bottom line benefits of having a product that is marketable everywhere. The costs for compliance, when compared to the total development cost for a new product tend to be in the noise. If these costs are amortized over reasonable quantities, then the unit cost for compliance tends to be a bargain. Its not hard to dig up a few good case studies in Product Liability to drive home the point. Best regards, Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Rich Nute Sent: Monday, November 26, 2001 12:36 PM To: nutwoo...@nutwood.eu.com Cc: emc-p...@majordomo.ieee.org Subject: Re: Quality Assurance and Product Approvals Hi Alan: Two questions, does the group see a time when we have a VP Compliance on level terms with VP Finance, VP Marketing etc, or is this already happening in the US. No. And not likely to happen in companies with ordinary products. As a general rule, compliance is seen as a necessary evil. It is a cost without an associated revenue (or customer-recognized need or benefit). Few companies want to give VP status (and an empire) to a non-revenue- generating function. Many companies measure the product incremental cost for compliance. The objective is to find methods and means for minimizing these product costs. Furthermore, few companies recognize the work of compliance folks as prevention of future unanticipated costs such as failure of sales due to non-compliance, product liability, or even product recalls. The reason the work is not recognized is the difficulty of measuring the future cost of non-compliance, especially if the company has never had such an incident. Second Question. Does the group think a formal qualification in Compliance Management CE Marking would be a good idea. While we may think this is a good idea, most professional managers in the field of compliance consider the job as one interim step in their career. If compliance is a non- revenue-generating activity, then the step to personal growth is to measure the cost of compliance for the duration of one's leadership, and add this to one's
RE: Quality Assurance and Product Approvals
One comment on the VP for compliance.. It is my undersyand that the Dell VP position does ALL the functions that are imposed by legislation on a compamy. EMC is one part. There is of course Safety, Environmental Issues, Lead-free solder etc.. Dell is taking a very professional approach to addresses ALL the issues - not just EMC. From: Dan Teninty dteni...@dtec-associates.com Reply-To: Dan Teninty dteni...@dtec-associates.com To: Rich Nute ri...@sdd.hp.com, nutwoo...@nutwood.eu.com CC: emc-p...@majordomo.ieee.org Subject: RE: Quality Assurance and Product Approvals Date: Tue, 27 Nov 2001 01:24:35 -0800 Rich, Dell Computers, as well as a few other major players, take a proactive approach to compliance and actually have a VP position for compliance. With a little investigation into the benefits of having a first rate compliance department with the ability to design for compliance, test to relevant standards, compile reports, participate on standards committees, and deal directly with world wide agencies I would think that most companies that have global markets would see both the short term and long term benefits to the bottom line. I would tend to include PC's into the ordinary products pile, wouldn't you? Companies that choose to take the adversarial approach to compliance by cutting corners or only doing the minimum to comply, save dollars in the short term, but pay later in lost customers, or worse, lawsuits. One of our clients, had a management team that took this denial/avoidance approach to NEBS. When the Telecom downturn came, they were left in a position where there was lots less demand and what demand there was, was for NEBS compliant products. Most of the management team that made those decisions have either left the company in recent right-sizing exercises, or are working in lesser positions. It seems that hindsight is always able to find a goat. When I explain the benefits of compliance to management teams, I try to focus on the bottom line benefits of having a product that is marketable everywhere. The costs for compliance, when compared to the total development cost for a new product tend to be in the noise. If these costs are amortized over reasonable quantities, then the unit cost for compliance tends to be a bargain. Its not hard to dig up a few good case studies in Product Liability to drive home the point. Best regards, Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Rich Nute Sent: Monday, November 26, 2001 12:36 PM To: nutwoo...@nutwood.eu.com Cc: emc-p...@majordomo.ieee.org Subject: Re: Quality Assurance and Product Approvals Hi Alan: Two questions, does the group see a time when we have a VP Compliance on level terms with VP Finance, VP Marketing etc, or is this already happening in the US. No. And not likely to happen in companies with ordinary products. As a general rule, compliance is seen as a necessary evil. It is a cost without an associated revenue (or customer-recognized need or benefit). Few companies want to give VP status (and an empire) to a non-revenue- generating function. Many companies measure the product incremental cost for compliance. The objective is to find methods and means for minimizing these product costs. Furthermore, few companies recognize the work of compliance folks as prevention of future unanticipated costs such as failure of sales due to non-compliance, product liability, or even product recalls. The reason the work is not recognized is the difficulty of measuring the future cost of non-compliance, especially if the company has never had such an incident. Second Question. Does the group think a formal qualification in Compliance Management CE Marking would be a good idea. While we may think this is a good idea, most professional managers in the field of compliance consider the job as one interim step in their career. If compliance is a non- revenue-generating activity, then the step to personal growth is to measure the cost of compliance for the duration of one's leadership, and add this to one's CV. Then, move on. Candidates for compliance management might find courses useful. However, the value of such qualifications is not for the long term. Another problem is that upper management doesn't want to be told that they are restricted by compliance rules insofar as setting objectives for the products and the company. They certainly don't want to feel that the only management folks qualified for managing a compliance function are those that are trained and qualified in compliance management. Formal qualification in compliance management may be seen by upper management as a power play where the compliance manager uses his knowledge
Re: FW: Quality Assurance and Product Approvals
Hi all, I have been following this discussion with great interest and could not resist adding my 2c. Lest face it - EMC is nothing more than pure overhead to any corporation. We all have experience of products that work perfectly fine yet fail the emissions profile by 0.5dB. I will contend that this experience far outweighs the opposite .Spinning a board or adding ferrites or adding shielding does nothing to help our discipline reputation. Couple that with the twilight zone impression of EMC and one can easily understand why most companies implement EMC into their process reluctantly. I will add to that one important factor The regulatory bodies - especially the FCC. Thanks in large part to the new FCC Class B compliance procedure ( which inadvertantly allows failing products into the market place) companies are more convinced that ever that EMC is more of an annoyance than a necessity. ( Some exceptions duly noted..) Unlike safety, there is no perceived benefit in squeezing that extra 0.5db out of the emissions profile at a cost od even .03c. The saving grace might be the immunity standards. I have had a whole lot more help when the design engineer actually witnesses his product doing wierd things. NARTE is straying in the direction of elitism. Worse than that they now have professors offering questions for inclusion in the NARTE exam. We need to be vigilant and keep the infulence of the academics to a minimum. Example: The ACES (Applied Computations Society) started a a group with the goal of PRACTICAL applications for comutation ..sound familiar. ?? It wasn't long before the academics (Phds the like) dominated the group and turned it to a purely theoretical group - a place to publish papers etc Now don't get me wrong.I am all for professors that are willing to teach and guide and mentor. There is how ever a human tendancy towards creeping elegance and we ned to ensure that the EMC discipline does not tend in that direction. My 2c Charles Grasso Ansoft Corporation From: Dan Teninty dteni...@dtec-associates.com Reply-To: Dan Teninty dteni...@dtec-associates.com To: PSTC IEEE-EMC emc-p...@majordomo.ieee.org Subject: FW: Quality Assurance and Product Approvals Date: Tue, 27 Nov 2001 12:11:38 -0800 Rich, After sending you my reply, I thought that I would open it up to the group for comment. I thought I would pass on the information about the NARTE certification for Product Safety engineers. Best regards, Dan Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: Dan Teninty [mailto:dteni...@dtec-associates.com] Sent: Tuesday, November 27, 2001 12:01 PM To: Rich Nute Subject: RE: Quality Assurance and Product Approvals Rich, I don't disagree with your point of view. It seems that there are a lot of MBA's devoting allot of time to reducing costs. This is how business is run. The days are gone when, like the founders of your organization, companies could compete on quality, reliability, features, and perceived value. Now everything boils down to how can we shave unit cost another $0.03? General Motors has had some high profile cases where this philosophy has led to injuries and deaths. The world is changing, not always for the better and I will continue to tilt at windmills. I believe that consumers expect/assume that products they purchase are safe and won't scramble their TV's picture during the Super Bowl. Quantifying this perception into a benefit that can be placed into a spread sheet is, I agree, a difficult if not impossible task, but a good actuary could probably come up with a defensible number. The point is that the philosophy of corporate management sets the tone for the rest of the company and if regulatory compliance is not a priority for management, then it won't be a priority for the compliance department. Reducing the amount of flame retardant plastic in a product is commendable if it doesn't compromise the protection it provides. Engineering is about trade-offs of conflicting requirements. Integrating compliance into a product should trade off the risk/consequence of non-compliance leading to an event. Events lead to lawsuits. I've always made a distinction between standards requirements and safety. Walt Hart at Fluke was an early mentor in product safety and taught me to differentiate between a requirement for a wire to be blue and a requirement that 5000 Volts not reach an end user. Harking back to an earlier thread, there are compliance engineers like yourself who go far beyond the requirements in the standards and understand the basic principles involved and how this basic science leads to standards. Then there are the folks who have compliance thrust upon them and at the extreme, haven't got a clue. In the commercial world of putting up buildings and other public structures
Re: FW: Quality Assurance and Product Approvals
The Board of Certified Safety Processionals used to have a Certification Specialty in Product Safety. There was so little interest in it that it was dropped. The closest that they have now is a Specialty in System Safety. Just like Dan says below about the requirement for PEs to sign off drawings, where is there any requirement for a Safety Professional to sign off on the safety approvals, either from a third party or the owning/design company. It will require the government or industry to require someone to hold a safety certification to perform certain tasks before there will ever be any legitimacy. OSHA requires a NRTL approval but it does not set any standards for the person that does the sign-off. Oscar MOO (My Opinions Only) Dan Teninty dteninty%dtec-associates@interlock.lexmark.com on 11/27/2001 03:11:38 PM Please respond to Dan Teninty dteninty%dtec-associates@interlock.lexmark.com To: PSTC IEEE-EMC emc-pstc%majordomo.ieee@interlock.lexmark.com cc:(bcc: Oscar Overton/Lex/Lexmark) Subject: FW: Quality Assurance and Product Approvals Rich, After sending you my reply, I thought that I would open it up to the group for comment. I thought I would pass on the information about the NARTE certification for Product Safety engineers. Best regards, Dan Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: Dan Teninty [mailto:dteni...@dtec-associates.com] Sent: Tuesday, November 27, 2001 12:01 PM To: Rich Nute Subject: RE: Quality Assurance and Product Approvals Rich, I don't disagree with your point of view. It seems that there are a lot of MBA's devoting allot of time to reducing costs. This is how business is run. The days are gone when, like the founders of your organization, companies could compete on quality, reliability, features, and perceived value. Now everything boils down to how can we shave unit cost another $0.03? General Motors has had some high profile cases where this philosophy has led to injuries and deaths. The world is changing, not always for the better and I will continue to tilt at windmills. I believe that consumers expect/assume that products they purchase are safe and won't scramble their TV's picture during the Super Bowl. Quantifying this perception into a benefit that can be placed into a spread sheet is, I agree, a difficult if not impossible task, but a good actuary could probably come up with a defensible number. The point is that the philosophy of corporate management sets the tone for the rest of the company and if regulatory compliance is not a priority for management, then it won't be a priority for the compliance department. Reducing the amount of flame retardant plastic in a product is commendable if it doesn't compromise the protection it provides. Engineering is about trade-offs of conflicting requirements. Integrating compliance into a product should trade off the risk/consequence of non-compliance leading to an event. Events lead to lawsuits. I've always made a distinction between standards requirements and safety. Walt Hart at Fluke was an early mentor in product safety and taught me to differentiate between a requirement for a wire to be blue and a requirement that 5000 Volts not reach an end user. Harking back to an earlier thread, there are compliance engineers like yourself who go far beyond the requirements in the standards and understand the basic principles involved and how this basic science leads to standards. Then there are the folks who have compliance thrust upon them and at the extreme, haven't got a clue. In the commercial world of putting up buildings and other public structures there is a requirement that a registered professional engineer review and sign off on drawings. This is not a perfect solution and there are bad apples, but there is a minimum level of competence assumed that does not exist in the product safety world. EMC engineers have NARTE certification to add to their qualifications and most of the NARTE certified EMC engineers I've encountered were competent to say the least. NARTE has just recently, at the EMC meeting in Montreal, announced a similar certification for product safety engineers. Some will say this is an attempt at empire building or elitism, but I contend that raising the bar will benefit society as a whole and perhaps eventually elevate the status of compliance engineers from, as we were affectionately known at Fluke, Those *%holes downstairs to respected professionals. My 2 cents, Best regards, Dan Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: Rich Nute [mailto:ri...@sdd.hp.com] Sent: Tuesday, November 27, 2001 10
FW: Quality Assurance and Product Approvals
Rich, After sending you my reply, I thought that I would open it up to the group for comment. I thought I would pass on the information about the NARTE certification for Product Safety engineers. Best regards, Dan Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: Dan Teninty [mailto:dteni...@dtec-associates.com] Sent: Tuesday, November 27, 2001 12:01 PM To: Rich Nute Subject: RE: Quality Assurance and Product Approvals Rich, I don't disagree with your point of view. It seems that there are a lot of MBA's devoting allot of time to reducing costs. This is how business is run. The days are gone when, like the founders of your organization, companies could compete on quality, reliability, features, and perceived value. Now everything boils down to how can we shave unit cost another $0.03? General Motors has had some high profile cases where this philosophy has led to injuries and deaths. The world is changing, not always for the better and I will continue to tilt at windmills. I believe that consumers expect/assume that products they purchase are safe and won't scramble their TV's picture during the Super Bowl. Quantifying this perception into a benefit that can be placed into a spread sheet is, I agree, a difficult if not impossible task, but a good actuary could probably come up with a defensible number. The point is that the philosophy of corporate management sets the tone for the rest of the company and if regulatory compliance is not a priority for management, then it won't be a priority for the compliance department. Reducing the amount of flame retardant plastic in a product is commendable if it doesn't compromise the protection it provides. Engineering is about trade-offs of conflicting requirements. Integrating compliance into a product should trade off the risk/consequence of non-compliance leading to an event. Events lead to lawsuits. I've always made a distinction between standards requirements and safety. Walt Hart at Fluke was an early mentor in product safety and taught me to differentiate between a requirement for a wire to be blue and a requirement that 5000 Volts not reach an end user. Harking back to an earlier thread, there are compliance engineers like yourself who go far beyond the requirements in the standards and understand the basic principles involved and how this basic science leads to standards. Then there are the folks who have compliance thrust upon them and at the extreme, haven't got a clue. In the commercial world of putting up buildings and other public structures there is a requirement that a registered professional engineer review and sign off on drawings. This is not a perfect solution and there are bad apples, but there is a minimum level of competence assumed that does not exist in the product safety world. EMC engineers have NARTE certification to add to their qualifications and most of the NARTE certified EMC engineers I've encountered were competent to say the least. NARTE has just recently, at the EMC meeting in Montreal, announced a similar certification for product safety engineers. Some will say this is an attempt at empire building or elitism, but I contend that raising the bar will benefit society as a whole and perhaps eventually elevate the status of compliance engineers from, as we were affectionately known at Fluke, Those *%holes downstairs to respected professionals. My 2 cents, Best regards, Dan Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: Rich Nute [mailto:ri...@sdd.hp.com] Sent: Tuesday, November 27, 2001 10:35 AM To: dteni...@dtec-associates.com Cc: nutwoo...@nutwood.eu.com; emc-p...@majordomo.ieee.org Subject: Re: Quality Assurance and Product Approvals Hi Dan: Dell Computers, as well as a few other major players, take a proactive approach to compliance and actually have a VP position for compliance. With a little investigation into the benefits of having a first rate compliance department with the ability to design for compliance, test to relevant standards, compile reports, participate on standards committees, and deal directly with world wide agencies I would think that most companies that have global markets would see both the short term and long term benefits to the bottom line. I would tend to include PC's into the ordinary products pile, wouldn't you? I do agree with (and we practice) a pro-active approach to compliance. In my experience, though, I am surprised that a compliance manager would be a VP position (in a company making ordinary products as compared to a company making medical products or similar products subject to a high degree
Re: Quality Assurance and Product Approvals
Hi Dan: Dell Computers, as well as a few other major players, take a proactive approach to compliance and actually have a VP position for compliance. With a little investigation into the benefits of having a first rate compliance department with the ability to design for compliance, test to relevant standards, compile reports, participate on standards committees, and deal directly with world wide agencies I would think that most companies that have global markets would see both the short term and long term benefits to the bottom line. I would tend to include PC's into the ordinary products pile, wouldn't you? I do agree with (and we practice) a pro-active approach to compliance. In my experience, though, I am surprised that a compliance manager would be a VP position (in a company making ordinary products as compared to a company making medical products or similar products subject to a high degree of regulation). As you mention, there can be short-term and long-term benefits to the compliance activities you mention. However, the benefits must outweigh the costs of the activities. Quantifying and measuring the benefits of some compliance activities is often very difficult. Management philosophy of the particular company is another significant variable in the extent of compliance activity. Some companies believe that safety certification is sufficient safety. Others believe that safety and safety certification are independent although overlapping activities. At one time, I knew of a company that addressed safety not in the product, but in liability avoidance through instruction manuals, through insurance, and by passing liability on to its suppliers. Cost effective, yes. Morally effective, questionable. Companies that choose to take the adversarial approach to compliance by cutting corners or only doing the minimum to comply, save dollars in the short term, but pay later in lost customers, or worse, lawsuits. One of our clients, had a management team that took this denial/avoidance approach to NEBS. When the Telecom downturn came, they were left in a position where there was lots less demand and what demand there was, was for NEBS compliant products. Most of the management team that made those decisions have either left the company in recent right-sizing exercises, or are working in lesser positions. Reducing the cost of compliance does not in any way imply an adversarial approach to compliance. Neither does cost reduction imply a reduction in the compliance performance of the product. For example, some years ago a RD engineer came to me and said, The cost of safety is too high. My immediate response was, Not if you design in safety from the start of the project. He replied, No. I mean that safety requires me to use a power switch and a fuse. These cost money. The switch serves no benefit to the user since the unit is left on continuously. (This was back in the days when the plug was not considered a disconnect device.) So, I started a project to determine alternatives to switches and fuses and other safety components (for the specific products we were building at that time). In terms of EMC compliance, I know one engineer who keeps track of the number and cost of components used exclusively for EMC control. His objective was to reduce the total cost of EMC control. This in no way is cutting corners of compliance, or doing the minimum to comply. The result was still full compliance -- but at least cost. It seems that hindsight is always able to find a goat. When I explain the benefits of compliance to management teams, I try to focus on the bottom line benefits of having a product that is marketable everywhere. The costs for compliance, when compared to the total development cost for a new product tend to be in the noise. If these costs are amortized over reasonable quantities, then the unit cost for compliance tends to be a bargain. There are two kinds of costs associated with compliance. The first kind is the cost of compliance in the product development. I agree that these costs are indeed in the noise compared to the overall development costs. The second kind of cost of compliance is the cost of labor and components that are installed solely for compliance. For high-volume products, these costs are far more important than the costs of development because they affect the price competitiveness of the product. A flame-retardant plastic costs more than a non-flame-retardant plastic. How can we design a product to minimize the use of flame-retardant plastic yet comply with the standards as well as being a truly safe product? For me, this second cost, the per-unit cost of compliance, is a very significant part of my job. Best regards, Rich --- This message is from the IEEE EMC Society Product Safety Technical
Re: Quality Assurance and Product Approvals
I read in !emc-pstc that Dan Teninty dteni...@dtec-associates.com wrote (in nfbbjpdpilfhdjcppoadeeakcoaa.dteni...@dtec-associates.com) about 'Quality Assurance and Product Approvals', on Tue, 27 Nov 2001: Rich, Dell Computers, as well as a few other major players, take a proactive approach to compliance and actually have a VP position for compliance. With a little investigation into the benefits of having a first rate compliance department with the ability to design for compliance, test to relevant standards, compile reports, participate on standards committees, and deal directly with world wide agencies I would think that most companies that have global markets would see both the short term and long term benefits to the bottom line. I would tend to include PC's into the ordinary products pile, wouldn't you? This is indeed the enlightened view. I started advocating this 30 years ago. It's been a long struggle. Companies that choose to take the adversarial approach to compliance by cutting corners or only doing the minimum to comply, save dollars in the short term, but pay later in lost customers, or worse, lawsuits. One of our clients, had a management team that took this denial/avoidance approach to NEBS. When the Telecom downturn came, they were left in a position where there was lots less demand and what demand there was, was for NEBS compliant products. Most of the management team that made those decisions have either left the company in recent right-sizing exercises, or are working in lesser positions. Compliance with standards is now a regular customer demand, sometimes carried to excess, usually through lazily or ignorantly attempting to over-simplify the subject, e.g. 'All equipment used shall comply with all British, European and International standards'. It seems that hindsight is always able to find a goat. When I explain the benefits of compliance to management teams, I try to focus on the bottom line benefits of having a product that is marketable everywhere. The costs for compliance, when compared to the total development cost for a new product tend to be in the noise. If these costs are amortized over reasonable quantities, then the unit cost for compliance tends to be a bargain. I regard the cost of compliance as part of the costs of being present in the market, not as part of the cost of making a product that works. Seriously non-compliant product can still work. That way, you get to compare the cost of compliance with, for example, the cost of advertising or even the cost of participating in exhibitions. Its not hard to dig up a few good case studies in Product Liability to drive home the point. Indeed, and however circumspect everyone is, there is always a finite probability... -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk After swimming across the Hellespont, I felt like a Hero. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
RE: Quality Assurance and Product Approvals
Rich, Dell Computers, as well as a few other major players, take a proactive approach to compliance and actually have a VP position for compliance. With a little investigation into the benefits of having a first rate compliance department with the ability to design for compliance, test to relevant standards, compile reports, participate on standards committees, and deal directly with world wide agencies I would think that most companies that have global markets would see both the short term and long term benefits to the bottom line. I would tend to include PC's into the ordinary products pile, wouldn't you? Companies that choose to take the adversarial approach to compliance by cutting corners or only doing the minimum to comply, save dollars in the short term, but pay later in lost customers, or worse, lawsuits. One of our clients, had a management team that took this denial/avoidance approach to NEBS. When the Telecom downturn came, they were left in a position where there was lots less demand and what demand there was, was for NEBS compliant products. Most of the management team that made those decisions have either left the company in recent right-sizing exercises, or are working in lesser positions. It seems that hindsight is always able to find a goat. When I explain the benefits of compliance to management teams, I try to focus on the bottom line benefits of having a product that is marketable everywhere. The costs for compliance, when compared to the total development cost for a new product tend to be in the noise. If these costs are amortized over reasonable quantities, then the unit cost for compliance tends to be a bargain. Its not hard to dig up a few good case studies in Product Liability to drive home the point. Best regards, Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC Streamlining The Compliance Process Advancing New Products To Market http://www.dtec-associates.com (509) 443-0215 (509) 443-0181 fax -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Rich Nute Sent: Monday, November 26, 2001 12:36 PM To: nutwoo...@nutwood.eu.com Cc: emc-p...@majordomo.ieee.org Subject: Re: Quality Assurance and Product Approvals Hi Alan: Two questions, does the group see a time when we have a VP Compliance on level terms with VP Finance, VP Marketing etc, or is this already happening in the US. No. And not likely to happen in companies with ordinary products. As a general rule, compliance is seen as a necessary evil. It is a cost without an associated revenue (or customer-recognized need or benefit). Few companies want to give VP status (and an empire) to a non-revenue- generating function. Many companies measure the product incremental cost for compliance. The objective is to find methods and means for minimizing these product costs. Furthermore, few companies recognize the work of compliance folks as prevention of future unanticipated costs such as failure of sales due to non-compliance, product liability, or even product recalls. The reason the work is not recognized is the difficulty of measuring the future cost of non-compliance, especially if the company has never had such an incident. Second Question. Does the group think a formal qualification in Compliance Management CE Marking would be a good idea. While we may think this is a good idea, most professional managers in the field of compliance consider the job as one interim step in their career. If compliance is a non- revenue-generating activity, then the step to personal growth is to measure the cost of compliance for the duration of one's leadership, and add this to one's CV. Then, move on. Candidates for compliance management might find courses useful. However, the value of such qualifications is not for the long term. Another problem is that upper management doesn't want to be told that they are restricted by compliance rules insofar as setting objectives for the products and the company. They certainly don't want to feel that the only management folks qualified for managing a compliance function are those that are trained and qualified in compliance management. Formal qualification in compliance management may be seen by upper management as a power play where the compliance manager uses his knowledge to gain some degree of control over other managers. If formal qualification in compliance management is principally that of methodology for measuring and reducing cost of compliance, then I would think this would be a very good idea. Best regards, Rich --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list
Re: Quality Assurance and Product Approvals
Hi Alan: Two questions, does the group see a time when we have a VP Compliance on level terms with VP Finance, VP Marketing etc, or is this already happening in the US. No. And not likely to happen in companies with ordinary products. As a general rule, compliance is seen as a necessary evil. It is a cost without an associated revenue (or customer-recognized need or benefit). Few companies want to give VP status (and an empire) to a non-revenue- generating function. Many companies measure the product incremental cost for compliance. The objective is to find methods and means for minimizing these product costs. Furthermore, few companies recognize the work of compliance folks as prevention of future unanticipated costs such as failure of sales due to non-compliance, product liability, or even product recalls. The reason the work is not recognized is the difficulty of measuring the future cost of non-compliance, especially if the company has never had such an incident. Second Question. Does the group think a formal qualification in Compliance Management CE Marking would be a good idea. While we may think this is a good idea, most professional managers in the field of compliance consider the job as one interim step in their career. If compliance is a non- revenue-generating activity, then the step to personal growth is to measure the cost of compliance for the duration of one's leadership, and add this to one's CV. Then, move on. Candidates for compliance management might find courses useful. However, the value of such qualifications is not for the long term. Another problem is that upper management doesn't want to be told that they are restricted by compliance rules insofar as setting objectives for the products and the company. They certainly don't want to feel that the only management folks qualified for managing a compliance function are those that are trained and qualified in compliance management. Formal qualification in compliance management may be seen by upper management as a power play where the compliance manager uses his knowledge to gain some degree of control over other managers. If formal qualification in compliance management is principally that of methodology for measuring and reducing cost of compliance, then I would think this would be a very good idea. Best regards, Rich --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
SV: Quality Assurance and product approvals
Yes, I like the levels Procedures and Work Instructions. I think rigorous procedures at all levels in a company can produce the reverse of the desired effect. Check lists, I love them, even if 90% of them contains the result Not Applicable. You have at least made some evaluations on important topics. But I have experience with a company who has a lot of procedures / working instructions and trained engineering people also, but even though, they returned every year with the same EMC troubles. forgot to connect the cable screen to the metal connector housing ..and so on ... Amund -Opprinnelig melding- Fra: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av Brian McAuliffe Sendt: 21. november 2001 10:25 Til: Tania Grant; mike harris; am...@westin-emission.no; 'EMC-PSTC Discussion Group' Emne: RE: Quality Assurance and product approvals Tania has summed up the situation pretty well below, one that I can certainly relate to. What existed in my last company were: Procedures - to describe the high level policy; Work Instructions - for very specific, and sometimes critical (but not necessarily), usually repetitive tasks. Having separate WI's (1 or 2 pages at most) meant that they could be easily updated when required without loads of reviews by people at all levels of the organisation, because the Procedures were not being updated unless there was a significant policy change. But. While I agree that training people on the 'how' while also giving them the backgorund on the 'why' can achieve the goal (for the Regulatory function at least, which is what should really be talking about here), there must be documented in at least one place the procedure and work instructions i.e. the training manuals. Yes, by the letter of the gospel (ISO 9000:2000) there are only really 6 or 7 procedures that must be documented and 9000:2000 espouses the use of 'verbal procedures', but this will only work in very small companies which probably won't have a Regulatory Group anyway Trained people move on. The 'procedures' go with them. Brian -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Tania Grant Sent: 21 November 2001 05:18 To: mike harris; am...@westin-emission.no; 'EMC-PSTC Discussion Group' Subject: Re: Quality Assurance and product approvals Hello Mike, It sounds as if your efforts were very well spent. I probably did not clarify that, in my opinion, people use the term procedure very loosely. Without having read your document (and therefore leaving myself open for criticism; but that's O.K.) I would say that what you wrote is not a procedure but more of a guideline or a higher level policy document. You are mostly explaining many things, providing information as to who is responsible to do what, but I don't believe you are really describing how those who are responsible are to perform their tasks. Thus, a procedure addresses repetitive tasks in detail, where the details are many and could probably be even very complex, and where probably the sequence of tasks is very crucial, and where you don't want people making mistakes no matter what their level of training is. Your document explains and describes what and describes who is to do what. If it is multi-departmental, it really falls into a category of a company wide policy. I can see that engineering, purchasing, regulatory, etc, would have their own procedures to support this higher level document. Now, why am I so fixated on not labeling such documents procedures? The problem with procedures is that there is usually a very defined format (usually Outline format) that lends itself beautifully to order and also to bureaucracy. There are times when you want bureaucracy and strict order, and there are times when you want to communicate, when you want people to understand and follow guidelines but you don't want to institute needless bureaucracy. How many of you have worked in a procedurized bureaucracy where there were many procedures that hardly anyone could follow or wanted to follow? The reason is because either the procedures were badly written and, most likely, were written at the wrong level. Proper people with training have no trouble working without any procedures provided they know what is expected and who the other players are. You don't need a procedure to define this. But very often the purpose of actions, what is expected, and who the players are, are not explained, but the how is rendered in ludicrous detail. Thus, you end up with a procedure that is unworkable after 7 months. Procedures should be written either by the people who are performing the work, or at the next higher level; test engineering usually writes procedures for the test technicians to follow. However, I believe that it is better if the test
Quality Assurance and Product Approvals
Hi All I have been following with great interest the detailed and in-depth responses to this topic. I have noted that particularly in Europe as the list of New Approach Directives and other regulations grow, plus Safety and Quality issues, that companies are divesting more importance to this whole area. Two questions, does the group see a time when we have a VP Compliance on level terms with VP Finance, VP Marketing etc, or is this already happening in the US. Second Question. Does the group think a formal qualification in Compliance Management CE Marking would be a good idea. It seems amazing that considering the importance and complexity of this area there is not as yet one qualification that can prove a persons competence. At least in Europe I am not sure about the US and rest of the world. Any comments please. Alan E Hutley Editorial Publishing Director EMC Compliance journal www.compliance-club.com
Re: Quality Assurance and product approvals
Mike, Tania hits the nail on the head with her comments. Something that I find useful in this situation is a Process Flowchart. These can be used for more than just chemical production. It more graphically illustrates the processes, interrelationships, and possible sequencing involved, especially when multiple people/departments are involved. These can be nested so that a high level flow chart can be shown to upper management (who only need the big picture) or initial trainees (who haven't a clue). More detailed ones can be used within departments or functions. Each one gives those within the process a bigger picture of what is suppose to be happening and gives them more information and motivation with which to make informed decisions. If one knows the impact of a decision outside their immediate realm of influence they may (and I emphasize may) make a decision that is positive for the entire process and not just their own little piece of it. It also makes it easier to spot failures/faults in the process. This leads to the ability of fixing the problem or revising the process. Where necessary, each of the blocks on the flow chart can have a more detailed flow chart showing the internal process (nesting). This could be continued until you actually reach a level where you are writing procedures; but, its main use is higher level viewing. A point of Tania's response to which I wish to emphasize is the need to involve others in the development. That cannot be stressed to much. It is amazing what comes out of the discussions as to how a process operates when those doing the work are asked how they think the process works. You will usually find a very diverse understanding of what people think is actually going on. Expect to be surprised yourself as to what actually is going on beyond your daily sight and the understanding others have of their roles. It is only at this point that you find out how different the actual process is to the printed one. It is at this time that you have to decide which is better, the actual process, the printed one, or another one altogether. You will probably find that both the actual and the printed processes have good elements and that somewhere in the middle is a more optimum process. There are some good software packages that are intended for process flow development. You can do the same with slide presentation graphic package but those intended for flow charting allow you to spend your time thinking instead of drawing. Well worth the minor cost. Oscar Overton oover...@lexmark.com (OAMO) Opinions are my own. Tania Grant taniagrant%msn@interlock.lexmark.com on 11/21/2001 12:18:24 AM Please respond to Tania Grant taniagrant%msn@interlock.lexmark.com To: mike harris teccomco%i-cafe@interlock.lexmark.com, amund%westin-emission...@interlock.lexmark.com, 'EMC-PSTC Discussion Group' emc-pstc%majordomo.ieee@interlock.lexmark.com cc:(bcc: Oscar Overton/Lex/Lexmark) Subject: Re: Quality Assurance and product approvals Hello Mike, It sounds as if your efforts were very well spent. I probably did not clarify that, in my opinion, people use the term procedure very loosely. Without having read your document (and therefore leaving myself open for criticism; but that's O.K.) I would say that what you wrote is not a procedure but more of a guideline or a higher level policy document. You are mostly explaining many things, providing information as to who is responsible to do what, but I don't believe you are really describing how those who are responsible are to perform their tasks. Thus, a procedure addresses repetitive tasks in detail, where the details are many and could probably be even very complex, and where probably the sequence of tasks is very crucial, and where you don't want people making mistakes no matter what their level of training is. Your document explains and describes what and describes who is to do what. If it is multi-departmental, it really falls into a category of a company wide policy. I can see that engineering, purchasing, regulatory, etc, would have their own procedures to support this higher level document. Now, why am I so fixated on not labeling such documents procedures? The problem with procedures is that there is usually a very defined format (usually Outline format) that lends itself beautifully to order and also to bureaucracy. There are times when you want bureaucracy and strict order, and there are times when you want to communicate, when you want people to understand and follow guidelines but you don't want to institute needless bureaucracy. How many of you have worked in a procedurized bureaucracy where there were many procedures that hardly anyone could follow or wanted to follow? The reason is because either the procedures were badly written and, most likely, were written at the wrong level. Proper people with training have no trouble working without any procedures provided
RE: Quality Assurance and product approvals
Tania has summed up the situation pretty well below, one that I can certainly relate to. What existed in my last company were: Procedures - to describe the high level policy; Work Instructions - for very specific, and sometimes critical (but not necessarily), usually repetitive tasks. Having separate WI's (1 or 2 pages at most) meant that they could be easily updated when required without loads of reviews by people at all levels of the organisation, because the Procedures were not being updated unless there was a significant policy change. But. While I agree that training people on the 'how' while also giving them the backgorund on the 'why' can achieve the goal (for the Regulatory function at least, which is what should really be talking about here), there must be documented in at least one place the procedure and work instructions i.e. the training manuals. Yes, by the letter of the gospel (ISO 9000:2000) there are only really 6 or 7 procedures that must be documented and 9000:2000 espouses the use of 'verbal procedures', but this will only work in very small companies which probably won't have a Regulatory Group anyway Trained people move on. The 'procedures' go with them. Brian -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Tania Grant Sent: 21 November 2001 05:18 To: mike harris; am...@westin-emission.no; 'EMC-PSTC Discussion Group' Subject: Re: Quality Assurance and product approvals Hello Mike, It sounds as if your efforts were very well spent. I probably did not clarify that, in my opinion, people use the term procedure very loosely. Without having read your document (and therefore leaving myself open for criticism; but that's O.K.) I would say that what you wrote is not a procedure but more of a guideline or a higher level policy document. You are mostly explaining many things, providing information as to who is responsible to do what, but I don't believe you are really describing how those who are responsible are to perform their tasks. Thus, a procedure addresses repetitive tasks in detail, where the details are many and could probably be even very complex, and where probably the sequence of tasks is very crucial, and where you don't want people making mistakes no matter what their level of training is. Your document explains and describes what and describes who is to do what. If it is multi-departmental, it really falls into a category of a company wide policy. I can see that engineering, purchasing, regulatory, etc, would have their own procedures to support this higher level document. Now, why am I so fixated on not labeling such documents procedures? The problem with procedures is that there is usually a very defined format (usually Outline format) that lends itself beautifully to order and also to bureaucracy. There are times when you want bureaucracy and strict order, and there are times when you want to communicate, when you want people to understand and follow guidelines but you don't want to institute needless bureaucracy. How many of you have worked in a procedurized bureaucracy where there were many procedures that hardly anyone could follow or wanted to follow? The reason is because either the procedures were badly written and, most likely, were written at the wrong level. Proper people with training have no trouble working without any procedures provided they know what is expected and who the other players are. You don't need a procedure to define this. But very often the purpose of actions, what is expected, and who the players are, are not explained, but the how is rendered in ludicrous detail. Thus, you end up with a procedure that is unworkable after 7 months. Procedures should be written either by the people who are performing the work, or at the next higher level; test engineering usually writes procedures for the test technicians to follow. However, I believe that it is better if the test technicians wrote their own test procedure and gave it to the test engineers for review. It is amazing how much knowledge can suddenly be gained during this exercise by both sides! I have written many multi-functional multi-departmental procedures, but I went to a great deal of time and effort to obtain input from those performing the various tasks. I was often surprised to receive different inputs from workers and their managers. Beware of highly placed managers writing detailed procedures telling others how to do their jobs, without honest input. Bureaucracy reigns! taniagr...@msn.com - Original Message - From: mike harris Sent: Tuesday, November 20, 2001 3:29 AM To: Tania Grant; am...@westin-emission.no; 'EMC-PSTC Discussion Group' Subject: Re: Quality Assurance and product approvals Hi Tania, I just finished writing a procedure on agency certifications for a client (prompted by their ISO 9000 audit
Re: Quality Assurance and product approvals
Hello Mike, It sounds as if your efforts were very well spent. I probably did not clarify that, in my opinion, people use the term procedure very loosely. Without having read your document (and therefore leaving myself open for criticism; but that's O.K.) I would say that what you wrote is not a procedure but more of a guideline or a higher level policy document. You are mostly explaining many things, providing information as to who is responsible to do what, but I don't believe you are really describing how those who are responsible are to perform their tasks. Thus, a procedure addresses repetitive tasks in detail, where the details are many and could probably be even very complex, and where probably the sequence of tasks is very crucial, and where you don't want people making mistakes no matter what their level of training is. Your document explains and describes what and describes who is to do what. If it is multi-departmental, it really falls into a category of a company wide policy. I can see that engineering, purchasing, regulatory, etc, would have their own procedures to support this higher level document. Now, why am I so fixated on not labeling such documents procedures? The problem with procedures is that there is usually a very defined format (usually Outline format) that lends itself beautifully to order and also to bureaucracy. There are times when you want bureaucracy and strict order, and there are times when you want to communicate, when you want people to understand and follow guidelines but you don't want to institute needless bureaucracy. How many of you have worked in a procedurized bureaucracy where there were many procedures that hardly anyone could follow or wanted to follow? The reason is because either the procedures were badly written and, most likely, were written at the wrong level. Proper people with training have no trouble working without any procedures provided they know what is expected and who the other players are. You don't need a procedure to define this. But very often the purpose of actions, what is expected, and who the players are, are not explained, but the how is rendered in ludicrous detail. Thus, you end up with a procedure that is unworkable after 7 months. Procedures should be written either by the people who are performing the work, or at the next higher level; test engineering usually writes procedures for the test technicians to follow. However, I believe that it is better if the test technicians wrote their own test procedure and gave it to the test engineers for review. It is amazing how much knowledge can suddenly be gained during this exercise by both sides! I have written many multi-functional multi-departmental procedures, but I went to a great deal of time and effort to obtain input from those performing the various tasks. I was often surprised to receive different inputs from workers and their managers. Beware of highly placed managers writing detailed procedures telling others how to do their jobs, without honest input. Bureaucracy reigns! taniagr...@msn.com - Original Message - From: mike harris Sent: Tuesday, November 20, 2001 3:29 AM To: Tania Grant; am...@westin-emission.no; 'EMC-PSTC Discussion Group' Subject: Re: Quality Assurance and product approvals Hi Tania, I just finished writing a procedure on agency certifications for a client (prompted by their ISO 9000 audit). It became partly glossary partly encyclopedia so sales, marketing, etc could find definitions and explanations of what the agencies are and why we need the certifications. It identifies the different levels types of certifications why they are needed by various parties. It outlines who does what, as far as design (initial ongoing), purchasing (ongoing - no stealth changes of critical parts), parts/materials inventory (traceability), etc. It defines who gets notified of new certifications what records are kept for how long. I agree with you completely that it would be never-ending to try to write a procedure to allow the untrained to do it all, so it does not explain how to conduct a project at any agency except in the most basic terms (tell the agency what you want to certify, get their cost estimate, write PO, provide samples documentation, assist as needed). Much can be gained by having such a document, which will seem basic for any competent compliance engineer. It will so nice to refer people to the procedure for the routine questions, instead of doing Agency 101 for the umpteenth time. Mike Harris/Teccom -Original Message- From: Tania Grant taniagr...@msn.com To: am...@westin-emission.no am...@westin-emission.no; 'EMC-PSTC Discussion Group' emc-p...@majordomo.ieee.org List-Post: emc-pstc@listserv.ieee.org Date: Monday, November 19, 2001 1:18 AM Subject: Re: Quality Assurance and product approvals Amund, Since I transferred
RE: Quality Assurance and product approvals
You are all making some excellent points. It would seem that many of us share commonality. Perhaps that is one of the underlying purposes of the quality organizations. When followed, the effects are positive and things move correctly, and in synch, but when exceptions are present... In my case, the compliance group and the engineering group are one. This obviously has good and bad implications. Brian makes an excellent point that has at times caused my hackles to raise more than once...the independence (or lack thereof) between the compliance department and the engineering department. In the company documents filed by two of these quality agencies, i.e. ISO 900x, A2LA, TUV or COMPASS, there is a clause that specifically mentions the requirement for this independence. Or, is it more of a 'suggestion'? There does not however, seem to be an audit check for departmental independence. I recently have become an ISO auditor, and I am uncertain there is, UNLESS I want to take it upon myself to press the issue. Since I work in the department, I cannot be assigned the task of auditing it, but I could express my concerns with the person assigned the audit of the EMC/Safety/Design engineering department. Hmm... I dont recall where these clauses are, but the purpose behind them is to express the importance of functional isolation between the interests of the two groups. In our case, this causes a disastrous effect on scheduling and allocation of resources because the conflicts are quick to rise and there is a weak attempt to resist. At times, we find ourselves pulled in two directions simultaneously. The 'Janus'..? All the planning, procedures and methods in the world cannot overcome this conflict if no one is willing to meet the challenge and push the issue. (as in our case) My poor boss has been subdued...and our compliance group is eternaly the whipping boy. I see the problem, but I am ineffective at fighting off the 800Lb gorilla's because they do not believe a lab rat...could read, think and speak. Ah, but I can AUDIT, or cause focus by another auditor...that would attract the attention of the QA folks (who seem to be beyond reproach). In the end, the quality of our output is in the hands of the lab rats who, take it upon themselves to ensure the letter of the standards are adhered to despite the conflict associated with the work. That makes it a thankless job, with little if any, appreciation. Ha!! what's that you say...you want a medal? -for driving up COSTS and delaying product release!!! If it were'nt for the beaurocracy...you would not have a job. [Ehler, Kyle] (my words) -Original Message- From: Brian McAuliffe [mailto:bally...@iolfree.ie] Sent: Tuesday, November 20, 2001 4:36 AM To: 'EMC-PSTC Discussion Group' Subject: RE: Quality Assurance and product approvals I think the point raised by Gary re: where the Compliance group fits into the organisation structure is more important than procedures/process, although I disagree with him about where that should be. Let me explain. Having a good working relationship with Engineering is indeed critical, however from my experience I believe it essential for the Compliance group to be organisationally independent of Engineering. If not, then there are always conflicts of interest when allocating the (usually limited) Compliance resources between: Engineering - there are 4 design reviews this week and preparation required for a safety pre-compliance test next week; Operations - the agency auditor is visiting next week and there is some prep needed; Sales/Marketing - the Russian approval is expiring in 2 weeks and you need to re-apply, prepare doc pack, etc. How do you prioritise without getting slack from at least one functional head ?? Obviously if the Compliance group is actually a group and not just 1 or 2 persons, then with a good understanding of the roles amongst the group members the above does not really pose a problem. However I do NOT believe this is the case, particularly in the current climate of lay-offs, with us Compliance folk are becoming less essential. Unless the role of the Compliance group is very narrow and involves only support of one function (which I doubt), I feel that an independent Compliance group is essential. It should be functionally independent to any other group and reporting to the MD, or, reporting to the QA Director/Manager. This will mean you can realistically argue for adequate resouces to do a professional job for all those groups requiring your services. You will have somebody independent at the right level in the organisation supporting the Compliance group - essential when $$$ are involved. Let's face it, no RD Manager is going to approve headcount for a 2nd Compliance Engineer whose primary function is to do audits of the production facility to ensure critical components are controlled as they should, and, to support Sales/Marketing to achieve product approvals
RE: Quality Assurance and product approvals
Morning Brian, et al. I don't have a large heartburn about the exact organizational chart location I have been in them all - well not actually sales I do have some standards* - and I find the debate very valuable! Location doesn't really create or fix all that many problems. You kind of trade one set of problems for the other. The absolute point of criticality is that the corporation has to have understand what it needs to get a product to market. That is established in the products requirement document, others may have different names. The things this group does, including Safety, EMC, and NEBS, among others are quite simply product requirements just like everything else in the document, in our case the ability to pass packets at line rate without packet loss, or maybe implementing spanning tree protocols etc. Take a look back at recent discussions about whether or not a DOC by itself was sufficient to accept product. The answer was generally no. That can affect a bottom line and that always gets attention from the highest levels. Why? Because some of the product features couldn't be independently verified and products aren't being purchased without it. We just stopped purchases of some very expensive pieces of equipment because of some operational bugs AND because of problems with their radiated emissions. That affected that companies bottom line for the quarter and that gets everybody's attention. Once the feature issue is understood then things start falling into place quite nicely. Making that understood is probably one of the more critical items we have to face, and it can be done from any organization. When the various prototype, pilot, or alpha builds are being planned they include the units I need for my job - that will range from three to six depending on the NEBS requirements, and these aren't inexpensive pieces of equipment. Schedules are a sneaking little tool. When being laid out its not a hard sale to point out that not having EUT's and having them on fixed dates starts putting day to day slips into the production release of the product. It also clearly identifies when more bodies are needed to implement the schedule. Something the big guys can evaluate very effectively. You're correct about the design review meetings and I spend a lot of time either in them or responding via e-mail or cell phone to them. Its not perfect but works very well. If I train the engineers well they become somewhat self monitoring and learn to get quick verifications when they have concerns. Spokane is an absolutely wonderful place to live but it means that for those tests I need to witness - EMC and NEBS etc, I spend a great deal of time in rectangular tubes at 30,000 feet trying to get to a rectangular box at the end of the day - traveling is so much fun - but a laptop, a very good electronic Engineering change process, a cell phone, and some first rate engineers and lab rats and it works very well - again independent of what organization I'm in. So get the features defined at step one, that will drive the allocations, tasks and schedules. The work with some great people who understand engineering and the full product development process - yes even sales has its good points, but empire builders are expressly excluded, and then work from anywhere. History has given me a strong preference for being inside the engineering department but your choice is just as. Gary *(It was a joke folks complain to me directly off line). -Original Message- From: Brian McAuliffe [mailto:bally...@iolfree.ie] Sent: Tuesday, November 20, 2001 2:36 AM To: 'EMC-PSTC Discussion Group' Subject: RE: Quality Assurance and product approvals I think the point raised by Gary re: where the Compliance group fits into the organisation structure is more important than procedures/process, although I disagree with him about where that should be. Let me explain. Having a good working relationship with Engineering is indeed critical, however from my experience I believe it essential for the Compliance group to be organisationally independent of Engineering. If not, then there are always conflicts of interest when allocating the (usually limited) Compliance resources between: Engineering - there are 4 design reviews this week and preparation required for a safety pre-compliance test next week; Operations - the agency auditor is visiting next week and there is some prep needed; Sales/Marketing - the Russian approval is expiring in 2 weeks and you need to re-apply, prepare doc pack, etc. How do you prioritise without getting slack from at least one functional head ?? Obviously if the Compliance group is actually a group and not just 1 or 2 persons, then with a good understanding of the roles amongst the group members the above does not really pose a problem. However I do NOT believe this is the case, particularly in the current climate of lay-offs, with us Compliance folk
RE: Quality Assurance and product approvals
I think the point raised by Gary re: where the Compliance group fits into the organisation structure is more important than procedures/process, although I disagree with him about where that should be. Let me explain. Having a good working relationship with Engineering is indeed critical, however from my experience I believe it essential for the Compliance group to be organisationally independent of Engineering. If not, then there are always conflicts of interest when allocating the (usually limited) Compliance resources between: Engineering - there are 4 design reviews this week and preparation required for a safety pre-compliance test next week; Operations - the agency auditor is visiting next week and there is some prep needed; Sales/Marketing - the Russian approval is expiring in 2 weeks and you need to re-apply, prepare doc pack, etc. How do you prioritise without getting slack from at least one functional head ?? Obviously if the Compliance group is actually a group and not just 1 or 2 persons, then with a good understanding of the roles amongst the group members the above does not really pose a problem. However I do NOT believe this is the case, particularly in the current climate of lay-offs, with us Compliance folk are becoming less essential. Unless the role of the Compliance group is very narrow and involves only support of one function (which I doubt), I feel that an independent Compliance group is essential. It should be functionally independent to any other group and reporting to the MD, or, reporting to the QA Director/Manager. This will mean you can realistically argue for adequate resouces to do a professional job for all those groups requiring your services. You will have somebody independent at the right level in the organisation supporting the Compliance group - essential when $$$ are involved. Let's face it, no RD Manager is going to approve headcount for a 2nd Compliance Engineer whose primary function is to do audits of the production facility to ensure critical components are controlled as they should, and, to support Sales/Marketing to achieve product approvals worldwide. (To bring this back to procedures/process) There also needs to be a 'document' which highlights: 1. What services the Compliance group offer; 2. The inputs (from other groups) required, and the outputs to be expected from each service; 3. Turnaround time (this will never be 100% accurate) With a document such as this published it raises awareness among each of the functions that the Compliance group do have organisation-wide responsibilites and are not at the beck and call of just one group. It forces them to plan for compliance also. It gives the Compliance group more credibility and visibility, and maybe people will start to appreciate the . Brian -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Gary McInturff Sent: 19 November 2001 16:35 To: 'Tania Grant'; am...@westin-emission.no; 'EMC-PSTC Discussion Group' Subject: RE: Quality Assurance and product approvals Bottom line is that each program generates a set of milestones that identify a function, set of equipment required, and timeframe for getting them done, and there are a set of generic test suites, but generally the whole process is documented at very non-descript level. The rest of this is rational for the way it happens. Over the course of my career ( companies of 40 - to 1,000 employees) this function has 1) grown in scope, first just safety, then safety and EMC, then safety, EMC and DVT, currently its safety, EMC, DVT, and NEBS. 2) It has been shuffled from place to place. Engineering, QA, manufacturing, to marketing. I have always been able to direct it back to what I believe is the correct department - Engineering. Principally for, conservation of resources - I already have some lab rats ( I say this with humor they have saved me much time and grief over the years) , and equipment, I may have to expand the equipment set marginally but I don't have to duplicate it. Probably just as important, is that inside of engineering I have the most timely input into the design changes or recommendations up front. Being located with the design engineers gives us both immediate and personal contact. They can stop into my office, and do quite regularly, to ask questions or seek advice, and I can do the same. As for formality of process it has always been more a series of milestones rather than explicitly documented processes for the vary reason Tania states - things change and they can change rapidly. I do have a series of boilerplate tests such as temperature, etc but occasionally those tests end up confirming - not predicting - what the safety agencies find. I try to find the very earliest point at which I can submit product to the safety agencies and the product is not always 100% functional from a design perspective, but 100% representative
Re: Quality Assurance and product approvals
Hi Tania, I just finished writing a procedure on agency certifications for a client (prompted by their ISO 9000 audit). It became partly glossary partly encyclopedia so sales, marketing, etc could find definitions and explanations of what the agencies are and why we need the certifications. It identifies the different levels types of certifications why they are needed by various parties. It outlines who does what, as far as design (initial ongoing), purchasing (ongoing - no stealth changes of critical parts), parts/materials inventory (traceability), etc. It defines who gets notified of new certifications what records are kept for how long. I agree with you completely that it would be never-ending to try to write a procedure to allow the untrained to do it all, so it does not explain how to conduct a project at any agency except in the most basic terms (tell the agency what you want to certify, get their cost estimate, write PO, provide samples documentation, assist as needed). Much can be gained by having such a document, which will seem basic for any competent compliance engineer. It will so nice to refer people to the procedure for the routine questions, instead of doing Agency 101 for the umpteenth time. Mike Harris/Teccom -Original Message- From: Tania Grant taniagr...@msn.com To: am...@westin-emission.no am...@westin-emission.no; 'EMC-PSTC Discussion Group' emc-p...@majordomo.ieee.org Date: Monday, November 19, 2001 1:18 AM Subject: Re: Quality Assurance and product approvals Amund, Since I transferred, over more than 20 years ago, from Quality Assurance to Regulatory compliance/product safety, I will share with you my opinions and my experience. However, I would also be interested in hearing about the experience of others. In my opinion, QA and regulatory compliance are different enough functions that require different experiences and disciplines that would not necessarily make it effective for a QA organization to either write or enforce procedures on the regulatory compliance functions. That does not mean that regulatory compliance shouldn't have a more formal process and a procedure to go with it. For myself, I know that having a QA background made me a more effective regulatory guru at the company. But I don't see how the two can be meshed under the same umbrella without diluting one or the other. Both require focus but it would be a rare Janus that could manage this effectively. However, the regulatory processes could, and should, be integrated into the whole engineering design process;-- and so should the QA process. Thus, the two can and should help each other, but I just don't see that a QA oversight by itself would make the regulatory process better or more effective. Now, I have a problem with your statement ...have your companies made procedures which in details describes the product approval process from beginning to end ? You are quite right that any procedure should describe a process in detail from beginning to end. This lends itself quite well to any and all test procedures, assembly of various parts, and other such functions where the same process is repeated over and over again. However, with the regulatory approval process, each product is different enough, that a procedure, especially one that is detailed, would not work. And the approval process is not always from the beginning to end but very often just a test or two have to be repeated, but not all, and sometimes you just notify the authorities about this and that, and sometimes you don't, but only document it or write up a justification why a particular test is not required. So how do you write a procedure around this? If I had to religiously do all this, I would be writing a procedure practically every time I was submitting a new or providing changes to a product. And I sure as heck would have been very upset if someone else (say from QA) were writing these procedures for me, especially since they wouldn't know what was required, or how to achieve this. A procedure describes how something is done. If I don't know how to do it, I shouldn't be working in that position. If the QA person is writing such a procedure (and assuming they are effective at it, which is problematic) then they should be working in that position and not me. Thus, I am not in favor of procedures. However, I am very much in favor of regulatory compliance plans that should be written for each new product, or a major regulatory up-date to a product. This compliance plan is really a communication device that informs Marketing, Engineering, QA, etc., the regulatory strategy: what the requirements are for this particular product, for which countries, to which standards, where the various tests will be performed, the approximate time assuming only one sample
RE: Quality Assurance and product approvals
Bottom line is that each program generates a set of milestones that identify a function, set of equipment required, and timeframe for getting them done, and there are a set of generic test suites, but generally the whole process is documented at very non-descript level. The rest of this is rational for the way it happens. Over the course of my career ( companies of 40 - to 1,000 employees) this function has 1) grown in scope, first just safety, then safety and EMC, then safety, EMC and DVT, currently its safety, EMC, DVT, and NEBS. 2) It has been shuffled from place to place. Engineering, QA, manufacturing, to marketing. I have always been able to direct it back to what I believe is the correct department - Engineering. Principally for, conservation of resources - I already have some lab rats ( I say this with humor they have saved me much time and grief over the years) , and equipment, I may have to expand the equipment set marginally but I don't have to duplicate it. Probably just as important, is that inside of engineering I have the most timely input into the design changes or recommendations up front. Being located with the design engineers gives us both immediate and personal contact. They can stop into my office, and do quite regularly, to ask questions or seek advice, and I can do the same. As for formality of process it has always been more a series of milestones rather than explicitly documented processes for the vary reason Tania states - things change and they can change rapidly. I do have a series of boilerplate tests such as temperature, etc but occasionally those tests end up confirming - not predicting - what the safety agencies find. I try to find the very earliest point at which I can submit product to the safety agencies and the product is not always 100% functional from a design perspective, but 100% representative of the tests and construction that the safety agencies focusing on. Occasionally, that means a phone call or letter telling them that there are changes before they issue the certificates and possible some re-test but it helps move this part of the design process of the critical path. The same goes for EMC, although that can be a bit trickier and almost always means that I repeat many EMC tests, but the final ones are more validation than praying for a pass as the early units are, and we are pretty comfortable that the project will conclude on time rather than going back for adjustments - which might trigger conversations with more than one outside agency. Marketing puts out a products requirement document and engineering responds with and Engineering requirements. If they have missed agency marks etc, we will feed that back to them in this document. Once everyone agrees what has to be done, the design schedule is fleshed out, and there are a fixed set of prototypes, beta, and production units that are identified and build exclusively for my area or responsibilities, along with a pretty fixed amount of time to complete each of these tasks. - 6 to 8 weeks or whatever. Exactly, what is being done inside each of these tasks left undefined, just as the basic design function is undefined, once the system architecture is defined. I am responsible for project updates and status reports but they are also on a high, rather than detailed, level. Process, problems, design changes needed etc. Gary [Gary McInturff] -Original Message- From: Tania Grant [mailto:taniagr...@msn.com] Sent: Sunday, November 18, 2001 10:32 PM To: am...@westin-emission.no; 'EMC-PSTC Discussion Group' Subject: Re: Quality Assurance and product approvals Amund, Since I transferred, over more than 20 years ago, from Quality Assurance to Regulatory compliance/product safety, I will share with you my opinions and my experience. However, I would also be interested in hearing about the experience of others. In my opinion, QA and regulatory compliance are different enough functions that require different experiences and disciplines that would not necessarily make it effective for a QA organization to either write or enforce procedures on the regulatory compliance functions. That does not mean that regulatory compliance shouldn't have a more formal process and a procedure to go with it. For myself, I know that having a QA background made me a more effective regulatory guru at the company. But I don't see how the two can be meshed under the same umbrella without diluting one or the other. Both require focus but it would be a rare Janus that could manage this effectively. However, the regulatory processes could, and should, be integrated into the whole engineering design process;-- and so should the QA process. Thus, the two can and should help each other, but I just don't see that a QA oversight by itself would make the regulatory process better or more effective. Now, I have a problem with your statement ...have your companies made
RE: Quality Assurance and product approvals
Here, here ! Best regards, Daniel E. Teninty, P.E. Managing Partner DTEC Associates LLC http://www.dtec-associates.com Streamlining the Compliance Process 5406 S. Glendora Drive Spokane, WA 99223 (509) 443-0215 (509) 443-0181 fax -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Tania Grant Sent: Sunday, November 18, 2001 10:32 PM To: am...@westin-emission.no; 'EMC-PSTC Discussion Group' Subject: Re: Quality Assurance and product approvals Amund, Since I transferred, over more than 20 years ago, from Quality Assurance to Regulatory compliance/product safety, I will share with you my opinions and my experience. However, I would also be interested in hearing about the experience of others. In my opinion, QA and regulatory compliance are different enough functions that require different experiences and disciplines that would not necessarily make it effective for a QA organization to either write or enforce procedures on the regulatory compliance functions. That does not mean that regulatory compliance shouldn't have a more formal process and a procedure to go with it. For myself, I know that having a QA background made me a more effective regulatory guru at the company. But I don't see how the two can be meshed under the same umbrella without diluting one or the other. Both require focus but it would be a rare Janus that could manage this effectively. However, the regulatory processes could, and should, be integrated into the whole engineering design process;-- and so should the QA process. Thus, the two can and should help each other, but I just don't see that a QA oversight by itself would make the regulatory process better or more effective. Now, I have a problem with your statement ...have your companies made procedures which in details describes the product approval process from beginning to end ? You are quite right that any procedure should describe a process in detail from beginning to end. This lends itself quite well to any and all test procedures, assembly of various parts, and other such functions where the same process is repeated over and over again. However, with the regulatory approval process, each product is different enough, that a procedure, especially one that is detailed, would not work. And the approval process is not always from the beginning to end but very often just a test or two have to be repeated, but not all, and sometimes you just notify the authorities about this and that, and sometimes you don't, but only document it or write up a justification why a particular test is not required. So how do you write a procedure around this? If I had to religiously do all this, I would be writing a procedure practically every time I was submitting a new or providing changes to a product. And I sure as heck would have been very upset if someone else (say from QA) were writing these procedures for me, especially since they wouldn't know what was required, or how to achieve this. A procedure describes how something is done. If I don't know how to do it, I shouldn't be working in that position. If the QA person is writing such a procedure (and assuming they are effective at it, which is problematic) then they should be working in that position and not me. Thus, I am not in favor of procedures. However, I am very much in favor of regulatory compliance plans that should be written for each new product, or a major regulatory up-date to a product. This compliance plan is really a communication device that informs Marketing, Engineering, QA, etc., the regulatory strategy: what the requirements are for this particular product, for which countries, to which standards, where the various tests will be performed, the approximate time assuming only one sample is available, and so forth. I am in favor, when a later update is made to the same product, to add an addendum to the same plan rather than generate a brand new plan. This way you can only add the delta tests that have to be done rather than start from scratch. And you have a history of the compliant process in one convenient location. Note that a compliance plan describes what is to be done and sometimes why, if that is crucial, but it does not really go into the details of the how. I don't want to start writing how I thermocouple the various components to get the product ready for safety heating tests! That, I consider, is part of training;-- and I have trained many to do this, all without benefit of writing any procedures. However, I do insist (and I believe that all companies also do this) that there is a Hi-pot test procedure available (and I usually review it), and that designated personnel are properly trained on how to run these tests, whether this function is under the QA or manufacturing test umbrella. Thus, I consider that the regulatory functions (safety, EMC, telco, Bellcore, etc
Re: Quality Assurance and product approvals
. However, no way are they detailed at that point or describe how the job is to be done. For that, we need trained and experienced people. taniagr...@msn.com - Original Message - From: am...@westin-emission.no Sent: Sunday, November 18, 2001 1:49 PM To: 'EMC-PSTC Discussion Group' Subject: Quality Assurance and product approvals Hi all, What is your experience with Quality Assurance and product approvals ? I mean, have your companies made procedures which in details describes the product approval process from beginning to end ? I have participated on many test projects during my time in a test lab. When I today evaluate that type of experience, I think a lot of the manufactures were not prepared at all and a lot of the sources-to-trouble could have been avoided if they had some kind of check list during the product development and preparation before test. Even good EMC and Safety folks need a kind of procedure to follow. TDo you have the same feeling / experience ? Any comments from test labs on this topic ? Best regards Amund Westin, Oslo/Norway PS: Do they only make QA-procedures to keep track on customers satisfaction and so on, and then forget the product approval process? --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Quality Assurance and product approvals
Hi all, What is your experience with Quality Assurance and product approvals ? I mean, have your companies made procedures which in details describes the product approval process from beginning to end ? I have participated on many test projects during my time in a test lab. When I today evaluate that type of experience, I think a lot of the manufactures were not prepared at all and a lot of the sources-to-trouble could have been avoided if they had some kind of check list during the product development and preparation before test. Even good EMC and Safety folks need a kind of procedure to follow. TDo you have the same feeling / experience ? Any comments from test labs on this topic ? Best regards Amund Westin, Oslo/Norway PS: Do they only make QA-procedures to keep track on customers satisfaction and so on, and then forget the product approval process? --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Product Approvals
Given that here in the US the OSHA NRTL program is limited to product safety in the workplace, can someone on this list answer the following: * Is there some other US government regulated program for these types of products outside the workplace? * If a manufacturer of an electrical/electronic product wanted to market the product on a global basis what market compliance would provide the broadest product safety coverage? * Please respond privately to the e-mail address below. Thanks in advance for any replies! Ron Schaible Ronald D. Schaible, CIH, CSP, PE Voice: +1 717 892 3038 Principal Consultant Fax:+1 717 892 3098 SCHAIBLE ASSOCIATESE-Mail: schai...@voicenet.com 1008 Country Place Drive, Lancaster, PA 17601-7109
