RE: product safety audit scenario
Couldn't agree more, Rich, and I try to get that team effort working whether I'm the host or not. Don't forget to tell everyone involved about the resolution to a problem if it does occur. Just a quick walk across the floor to tell the assembler directly, for example. You might be amazed at how much they appreciate it, and how much more it makes them feel involved with the company as a whole. There are even times when you want to involve the inspector. They have a requirement to see all of the equipment over some given time span (a year maybe?). So if their quarterly inspections haven't coincided with the production runs give them a heads up. That adds a lot of trust to the process and they generally reciprocate when things are so black and white during the inspections. Gary From: Rich Nute [mailto:ri...@sdd.hp.com] Sent: Tuesday, February 18, 2003 4:53 PM To: Gary McInturff Cc: john.al...@era.co.uk; emc-p...@majordomo.ieee.org Subject: Re: product safety audit scenario Hi Gary: Your comment triggers another comment: Leadership. Typically, we tend to let the inspector be the leader for the duration of the inspection. The host can be the leader. 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: product safety audit scenario
Peter, Semantically you are absolutely correct. They cannot hold the shipment. Pragmatically, it ends up that way. If I can't apply the logo I can't ship the product, its part-and-parcel with the product for production level equipment. An occasionally Beta unit goes out incomplete, but that is done with the customers understanding that the process is being completed. Gary [Gary McInturff] -Original Message- From: peter merguerian [mailto:pmerguerian2...@yahoo.com] Sent: Tuesday, February 18, 2003 12:42 PM To: Lay Siang Saw; emc-p...@majordomo.ieee.org Subject: Re: product safety audit scenario Alice, An inspector cannot hold your shipment! They can however ask you to remove the agency marking from the products prior to shipment. Some examples of major deviations: 1) change of power supply 2) pcb traces that are different than original design 3) change of fan to one with a lower CFM or LFM 4) change in filter design 5) safety Instructions not shipped with unit 6) grrounding connection not in accordance to report 7) routing of Wiring not in accordance to report 8) change of openings 9) lithium battery reverse charging protection circuitry not in place 10) plastics flammability and/or ignition properties not in accordance to report. These are just a few that I have come across and have considered as major deviations. Regards, Lay Siang Saw l...@celestica.com wrote: Hi all, Can anyone share with me under what conditions an auditor is allowed to stop shipments ? Thanks,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 06:09 PM --- Lay Siang Saw 02/18/2003 10:50 AM To: emc-p...@majordomo.ieee.org cc: Subject: product safety audit scenario Hi all, Thank you very much for your comments.I have received many replies from this forum. May be someone out there can standardize this,applicable to UL,TUV,CSA etc. On the report On the physical part VN ? ... ... . 1. Rating (V) 90-135/180-265V 115/230V NO,as this part has been tested in 90-135/180-265V range 2. Rating (I) ! 12/10A 10A NO,as this rating is within the tested rating 3. Rating (V) 120-127/220-240V 125/230V NO,as this part has been tested in 120-127/220-240V range 4. Rating (V) 120-127/220-240V 120-127V NO,the rating used within the tested range Once again ,thank you all and it would be good if there is standardisation made on this issue. Regards,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 10:51 AM --- Lay Siang Saw 02/17/2003 11:40 AM To: emc-p...@majordomo.ieee.org cc: Subject: product safety audit scenario Hi all,can anyone share with me with your comments Scenario : Component A with rating mentioned in the UL's product report as 90-135/180-265 Vac, however in the phyical unit is written as 115/230 V . Q1 : Is this a non conformity ? Should a VN be raised ?50 % says Yes and other 50% says No Scenario! :In the report, it mentioned the marking on the label as 120! -127V , however in the actual label on the unit it is written as 120-127V/220-240V. Q2. Is this a non conformity ? Should a VN be raised ?100% yes Scenario : In the report, it mentioned component B carries many safety agency certification, however i the actual physical unit, it only containes one or two safety agency logos. Q3. Is this a non conformity ? Should a VN be raised ? 90% says YES and 10% says NO Q4. When an IPI ( Initial product inspection ) is carried out, should the UL's product report been approved by the UL ? Q5. Should the report used during IPI is a detailed report with Sec general and condition of testing been included ? Q6. Can anyone share with me the correct ways the product report/FUS procedure for a product should be written so that we are not caught up with it, particularly on the rating,model and safety agency certification requirement for the product ? I am looking forwards to hearin! g a reply from you. Thanks Regards, alice saw 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 _ Do you Yahoo!? Yahoo! http://rd.yahoo.com/O=1/I=bran r/vday03/text/flow/*http://shopping.yahoo.com/shop?d=browseid=20146735 Shopping - Send
Re: product safety audit scenario
Hi Gary: Your comment triggers another comment: Leadership. Typically, we tend to let the inspector be the leader for the duration of the inspection. The host can be the leader. The host can set the agenda (in advance, although the inspector need not be notified). First, is to decide what products to be inspected. Then, decide whether everything will be inspected, or just some individual items, i.e., what does the inspector want to see (decided before going to the factory floor). On the factory floor, the host can then find each item and show it to the inspector. Point-by-point through the whole FUS document. It works well. Some inspectors may tend to feel as though they are being railroaded, so you need to be sensitive to this. 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: 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: product safety audit scenario
Hello Bill, The following is part of the UL Variation Notice. I understand your comments, however, 'hold shipment' (Item 3) is a term that UL uses. Sylvia Underwriters Laboratories Inc. Information For Manufacturers Variation Notices GENERAL - If the UL Representative finds items (variations) which differ from the UL Procedure, he must complete a Variation Notice (VN). Some of the items may be minor changes needed in the UL Procedure, and these will be handled by UL without any further action on your part. Should these differences be significant, the manufacturer has three choices: 1). Rework the Product - Correct the variations to comply with the UL Procedure. 2). Remove All References to UL - Permanently remove or obliterate all UL Marks on, or associated with the product. These include UL references on the carton, packing materials and similar items accompanying the product. Also included is the UL Recognized Marking for Recognized Components. 3). Hold the Shipment - The manufacturer must agree to keep the products at the factory until a UL office has made a decision as to whether or not the variations (changes) are acceptable. If this situation is urgent, a copy of the Variation Notice should be sent, by fax, to the UL Reviewing Office and to the Applicant. If facsimile facilities are not available, use telex, telephone, or overnight mail. APPEALS PROCEDURE - If the manufacturer disagrees with our Field Representative, he may hold shipment as noted above and appeal to the UL conformity Assessment Services Reviewing Office. COMMUNICATIONS - The UL Representative will note on the Variation Notice which items require a response from the manufacturer. In all cases, information about the variations and the appeal, if any, can be sent to the UL office by the fastest means, including fax, telex, and telephone. If a telex is sent, a verbatim copy of the Variation Notice should be telexed along with the manufacturer's comments. A telephone call should be made while the UL Representative is at the factory. It is the manufacturer's responsibility to notify the Applicant, if other than the manufacturer, that a response to the VN is required. Even if the Conformity Assessment Services Reviewing Office determines the variation(s) to be acceptable, changes cannot be made to the Procedure until UL has received written authorization from the Applicant. From: FastWave [mailto:bi...@fastwave.com] Sent: Tuesday, February 18, 2003 12:12 PM To: Sylvia Toma; Lay Siang Saw; emc-p...@majordomo.ieee.org Subject: RE: product safety audit scenario The Certification laboratories such as UL, CSA, ETL, MET, etc. cannot hold a shipment. However, they can require that you stop shipping products with their certification mark = your choice, remove the certification mark or hold shipment until the lab allows you to use the certification label again). That is one of the basic elements of their Follow Up Service Agreement. Be sure you understand what you are signing when you sign Follow Up Service agreements. In general, they authorize access to manufacturing facilities to inspect anything with their certification mark. NOTE - OSHA has authorized NRTL's to reduce the number of annual Follow Up Service inspections from 4 to 2 for most categories. I would anticipate that this soon will be one of your prime considerations on selecting a Certification Lab = how many FUS inspections they require per year. Bill Bisenius EDD bi...@productsafet.com www.productsafet.com -Original Message- From: Sylvia Toma [mailto:st...@juniper.net] Sent: Tuesday, February 18, 2003 12:39 PM To: Lay Siang Saw; emc-p...@majordomo.ieee.org Subject:RE: product safety audit scenario Hello Alice, One scenario that an auditor can hold shipment is the system under audit employs a different power supply (different manufacturer name and/or model number) than the one stated in the Procedure or Critical Component list of the Test Report. Power supply is a critical component (since it contains hazardous voltages) and one cannot substitute a different power supply into the system without first notifying the agencies. The agencies need to conduct evaluation and testing on the alternate power supply. Sylvia From: Lay Siang Saw [mailto:l...@celestica.com] Sent: Tuesday, February 18, 2003 1:51 AM To: emc-p...@majordomo.ieee.org Subject: product safety audit scenario Hi all, Can anyone share with me under what conditions an auditor is allowed to stop shipments ? Thanks,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 06:09 PM --- Lay Siang Saw 02/18/2003 10:50 AM 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
RE: product safety audit scenario
Agree, with it all, except I signed the VN - right after it was cleared up with the UL engineer. The inspector was correct that it didn't match the descriptive file, it was also the case that it didn't matter from a hazard perspective, and to avoid the problem in the future we did need to update the file. All of these things were handled in the same telephone conversation and everyone was happy. The inspectors paper work, was complete, UL understood the problem, UL updated the file within in a couple of weeks, and the next the inspector got there the product and the file correctly matched each other. Self audits get a little more difficult when the manufacturer is many hundreds of miles away, but I usually try to make at least an annual trip to audit. If nothing else it makes the CM take note that I am paying attention, and that following drawings and component sourcing is important. An small anecdote- about a custom build transformer from years ago. 1) Do not let helpful employee's hang around during the inspection. During an inspection it was found that the transformer external leads were not surface marked, as the report required. It was our fault for not inspecting diligently. The transformers and the wire were both manufactured by the same vendor and they forgot a step. When the inspector put a production halt on the equipment do the discrepancy our every helpful manufacturing folks took umbrage, saying that's ridiculous that transformer is used in three other products Very helpful, now I had four rather than 1 product on ship hold 2)In an odd but fortuitous coincidence it turns out that the transformer manufacturer was owned by the father of the UL engineer who investigated our project. Whether it should have been that quick or not, the UL engineer, was able to confirm the wire got the ship hold released, and the process from the manufacturer fixed real quick. Another moral to this story, is that you may have to guide the incoming inspection folks on what you as a safety professional need identified on parts if its important. The inspection guys, did a number of things; they checked the part number, they checked the lead lengths, and if I remember correctly they even ran some performance checks. But the marking on the wire wasn't specifically called out - so they didn't check that. 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: product safety audit scenario
Hello Alice, One scenario that an auditor can hold shipment is the system under audit employs a different power supply (different manufacturer name and/or model number) than the one stated in the Procedure or Critical Component list of the Test Report. Power supply is a critical component (since it contains hazardous voltages) and one cannot substitute a different power supply into the system without first notifying the agencies. The agencies need to conduct evaluation and testing on the alternate power supply. Sylvia From: Lay Siang Saw [mailto:l...@celestica.com] Sent: Tuesday, February 18, 2003 1:51 AM To: emc-p...@majordomo.ieee.org Subject: product safety audit scenario Hi all, Can anyone share with me under what conditions an auditor is allowed to stop shipments ? Thanks,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 06:09 PM --- Lay Siang Saw 02/18/2003 10:50 AM 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: product safety audit scenario
Hi Folks I second Rich's comments - the same things have happened to me a few years ago, and did result in a temporary shutdown on one occasion but rapid discussions with the agency engineer gave us a few weeks to fix the problem and so we could restart production virtually straightaway. The secret, however, is (like Gregg said earlier) quite simply do the audit before the agency factory inspector does - and be even more stringent on yourselves than he is likely to be. Then you can get well in-control BEFORE you get the line stoppers - That worked well for me over quite a few years. Nevertheless, if you are new to the game and not sure what to audit for (and don't want to call the agency in!) then try to get a suitably experienced consultant (and there are plenty out there around the world)in to it for you - It could be a lot cheaper than the alternative! Regards John Allen Technical Consultant Safety and Risk Management ERA Technology Ltd Cleeve Rd Leatherhead Surrey KT22 7SA Tel:+44 (0) 1372-367025 (Direct) +44 (0) 1372-367000 (Switchboard) Fax:+44 (0) 1372-367102 (Fax) From: richwo...@tycoint.com [mailto:richwo...@tycoint.com] Sent: 18 February 2003 14:16 To: emc-p...@majordomo.ieee.org Subject: RE: product safety audit scenario In the real world, however, such jugements are made by the safety agency factory inspectors. Unfortunately, our factories have received several variance notices in the past, but not a single one has resulted in an immediate line shut-down by the inspector. In some cases, it is obvious that a simple paperwork change is required. In others cases where there is a more serious variance, the manufacturer must resolve the problem within a specified period of time. Usually, in this case, the manufacture works with the agency engineer to provide a resolution and the agency engineer notifies the follow-up services group of the resolution which allows production to continue. If your inspector is shuting down your line, you either have a serious breech of safety or a very strict inspector. If you feel the latter is the case, you need to speak to the inspector's managment. I have had to do that on one ocassion when the inspector was being concerned about items that I felt were beyound his concern. Richard Woods Sensormatic Electronics Tyco International From: Gregg Kervill [mailto:gr...@test4safety.com] Sent: Tuesday, February 18, 2003 7:20 AM To: 'Lay Siang Saw'; emc-p...@majordomo.ieee.org Subject: RE: product safety audit scenario When the product differs from your product description - (most) auditors are expressly forbidden to make engineering judgments - therefore is it says Painted Steel in the narrative description and its actually Anodized Aluminum then he will have no option but to stop shipment. Best regards Gregg From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Lay Siang Saw Sent: Tuesday, February 18, 2003 4:51 AM To: emc-p...@majordomo.ieee.org Subject: product safety audit scenario Hi all, Can anyone share with me under what conditions an auditor is allowed to stop shipments ? Thanks,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 06:09 PM --- Lay Siang Saw 02/18/2003 10:50 AM To:emc-p...@majordomo.ieee.org cc: Subject:product safety audit scenario Hi all, Thank you very much for your comments.I have received many replies from this forum. May be someone out there can standardize this,applicable to UL,TUV,CSA etc. On the reportOn the physical part VN ? . 1. Rating (V) 90-135/180-265V115/230V NO,as this part has been tested in 90-135/180-265V range 2. Rating (I) 12/10A 10A NO,as this rating is within the tested rating 3. Rating (V) 120-127/220-240V 125/230V NO,as this part has been tested in 120-127/220-240V range 4. Rating (V) 120-127/220-240V 120-127V NO,the rating used within the tested range Once again ,thank you all and it would be good if there is standardisation made on this issue. Regards,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 10:51 AM --- Lay Siang Saw 02/17/2003 11:40 AM To:emc-p...@majordomo.ieee.org cc: Subject:product safety audit scenario Hi all,can anyone share with me with your comments Scenario : Component A with rating mentioned in the UL's product report as 90-135/180-265 Vac, however in the phyical unit is written as 115/230 V . Q1 : Is this a non conformity ? Should a VN be raised ?50 % says Yes and other 50% says No Scenario :In the report, it mentioned the marking on the label as 120
RE: product safety audit scenario
In the real world, however, such jugements are made by the safety agency factory inspectors. Unfortunately, our factories have received several variance notices in the past, but not a single one has resulted in an immediate line shut-down by the inspector. In some cases, it is obvious that a simple paperwork change is required. In others cases where there is a more serious variance, the manufacturer must resolve the problem within a specified period of time. Usually, in this case, the manufacture works with the agency engineer to provide a resolution and the agency engineer notifies the follow-up services group of the resolution which allows production to continue. If your inspector is shuting down your line, you either have a serious breech of safety or a very strict inspector. If you feel the latter is the case, you need to speak to the inspector's managment. I have had to do that on one ocassion when the inspector was being concerned about items that I felt were beyound his concern. Richard Woods Sensormatic Electronics Tyco International From: Gregg Kervill [mailto:gr...@test4safety.com] Sent: Tuesday, February 18, 2003 7:20 AM To: 'Lay Siang Saw'; emc-p...@majordomo.ieee.org Subject: RE: product safety audit scenario When the product differs from your product description - (most) auditors are expressly forbidden to make engineering judgments - therefore is it says Painted Steel in the narrative description and its actually Anodized Aluminum then he will have no option but to stop shipment. Best regards Gregg From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Lay Siang Saw Sent: Tuesday, February 18, 2003 4:51 AM To: emc-p...@majordomo.ieee.org Subject: product safety audit scenario Hi all, Can anyone share with me under what conditions an auditor is allowed to stop shipments ? Thanks,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 06:09 PM --- Lay Siang Saw 02/18/2003 10:50 AM To:emc-p...@majordomo.ieee.org cc: Subject:product safety audit scenario Hi all, Thank you very much for your comments.I have received many replies from this forum. May be someone out there can standardize this,applicable to UL,TUV,CSA etc. On the reportOn the physical part VN ? . 1. Rating (V) 90-135/180-265V115/230V NO,as this part has been tested in 90-135/180-265V range 2. Rating (I) 12/10A 10A NO,as this rating is within the tested rating 3. Rating (V) 120-127/220-240V 125/230V NO,as this part has been tested in 120-127/220-240V range 4. Rating (V) 120-127/220-240V 120-127V NO,the rating used within the tested range Once again ,thank you all and it would be good if there is standardisation made on this issue. Regards,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 10:51 AM --- Lay Siang Saw 02/17/2003 11:40 AM To:emc-p...@majordomo.ieee.org cc: Subject:product safety audit scenario Hi all,can anyone share with me with your comments Scenario : Component A with rating mentioned in the UL's product report as 90-135/180-265 Vac, however in the phyical unit is written as 115/230 V . Q1 : Is this a non conformity ? Should a VN be raised ?50 % says Yes and other 50% says No Scenario :In the report, it mentioned the marking on the label as 120-127V , however in the actual label on the unit it is written as 120-127V/220-240V. Q2. Is this a non conformity ? Should a VN be raised ?100% yes Scenario : In the report, it mentioned component B carries many safety agency certification, however i the actual physical unit, it only containes one or two safety agency logos. Q3. Is this a non conformity ? Should a VN be raised ? 90% says YES and 10% says NO Q4. When an IPI ( Initial product inspection ) is carried out, should the UL's product report been approved by the UL ? Q5. Should the report used during IPI is a detailed report with Sec general and condition of testing been included ? Q6. Can anyone share with me the correct ways the product report/FUS procedure for a product should be written so that we are not caught up with it, particularly on the rating,model and safety agency certification requirement for the product ? I am looking forwards to hearing a reply from you. Thanks Regards, alice saw 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
RE: product safety audit scenario
When the product differs from your product description - (most) auditors are expressly forbidden to make engineering judgments - therefore is it says Painted Steel in the narrative description and its actually Anodized Aluminum then he will have no option but to stop shipment. Best regards Gregg From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Lay Siang Saw Sent: Tuesday, February 18, 2003 4:51 AM To: emc-p...@majordomo.ieee.org Subject: product safety audit scenario Hi all, Can anyone share with me under what conditions an auditor is allowed to stop shipments ? Thanks,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 06:09 PM --- Lay Siang Saw 02/18/2003 10:50 AM To:emc-p...@majordomo.ieee.org cc: Subject:product safety audit scenario Hi all, Thank you very much for your comments.I have received many replies from this forum. May be someone out there can standardize this,applicable to UL,TUV,CSA etc. On the reportOn the physical part VN ? . 1. Rating (V) 90-135/180-265V115/230V NO,as this part has been tested in 90-135/180-265V range 2. Rating (I) 12/10A 10A NO,as this rating is within the tested rating 3. Rating (V) 120-127/220-240V 125/230V NO,as this part has been tested in 120-127/220-240V range 4. Rating (V) 120-127/220-240V 120-127V NO,the rating used within the tested range Once again ,thank you all and it would be good if there is standardisation made on this issue. Regards,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 10:51 AM --- Lay Siang Saw 02/17/2003 11:40 AM To:emc-p...@majordomo.ieee.org cc: Subject:product safety audit scenario Hi all,can anyone share with me with your comments Scenario : Component A with rating mentioned in the UL's product report as 90-135/180-265 Vac, however in the phyical unit is written as 115/230 V . Q1 : Is this a non conformity ? Should a VN be raised ?50 % says Yes and other 50% says No Scenario :In the report, it mentioned the marking on the label as 120-127V , however in the actual label on the unit it is written as 120-127V/220-240V. Q2. Is this a non conformity ? Should a VN be raised ?100% yes Scenario : In the report, it mentioned component B carries many safety agency certification, however i the actual physical unit, it only containes one or two safety agency logos. Q3. Is this a non conformity ? Should a VN be raised ? 90% says YES and 10% says NO Q4. When an IPI ( Initial product inspection ) is carried out, should the UL's product report been approved by the UL ? Q5. Should the report used during IPI is a detailed report with Sec general and condition of testing been included ? Q6. Can anyone share with me the correct ways the product report/FUS procedure for a product should be written so that we are not caught up with it, particularly on the rating,model and safety agency certification requirement for the product ? I am looking forwards to hearing a reply from you. Thanks Regards, alice saw 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 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
product safety audit scenario
Hi all, Can anyone share with me under what conditions an auditor is allowed to stop shipments ? Thanks,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 06:09 PM --- Lay Siang Saw 02/18/2003 10:50 AM To:emc-p...@majordomo.ieee.org cc: Subject:product safety audit scenario Hi all, Thank you very much for your comments.I have received many replies from this forum. May be someone out there can standardize this,applicable to UL,TUV,CSA etc. On the reportOn the physical part VN ? ... ... . 1. Rating (V) 90-135/180-265V115/230V NO,as this part has been tested in 90-135/180-265V range 2. Rating (I) 12/10A 10A NO,as this rating is within the tested rating 3. Rating (V) 120-127/220-240V 125/230V NO,as this part has been tested in 120-127/220-240V range 4. Rating (V) 120-127/220-240V 120-127V NO,the rating used within the tested range Once again ,thank you all and it would be good if there is standardisation made on this issue. Regards,alice -- Forwarded by Lay Siang Saw/MY/Asia/Celestica on 02/18/2003 10:51 AM --- Lay Siang Saw 02/17/2003 11:40 AM To:emc-p...@majordomo.ieee.org cc: Subject:product safety audit scenario Hi all,can anyone share with me with your comments Scenario : Component A with rating mentioned in the UL's product report as 90-135/180-265 Vac, however in the phyical unit is written as 115/230 V . Q1 : Is this a non conformity ? Should a VN be raised ?50 % says Yes and other 50% says No Scenario :In the report, it mentioned the marking on the label as 120-127V , however in the actual label on the unit it is written as 120-127V/220-240V. Q2. Is this a non conformity ? Should a VN be raised ?100% yes Scenario : In the report, it mentioned component B carries many safety agency certification, however i the actual physical unit, it only containes one or two safety agency logos. Q3. Is this a non conformity ? Should a VN be raised ? 90% says YES and 10% says NO Q4. When an IPI ( Initial product inspection ) is carried out, should the UL's product report been approved by the UL ? Q5. Should the report used during IPI is a detailed report with Sec general and condition of testing been included ? Q6. Can anyone share with me the correct ways the product report/FUS procedure for a product should be written so that we are not caught up with it, particularly on the rating,model and safety agency certification requirement for the product ? I am looking forwards to hearing a reply from you. Thanks Regards, alice saw 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: product safety audit scenario
Hi Alice: Scenario : Component A with rating mentioned in the UL's product report as 90-135/180-265 Vac, however in the phyical unit is written as 115/230 V . Q1 : Is this a non conformity ? Should a VN be raised ? Yes, this is a non-conformity. In this case, the report should be revised to match the marking on the component. Whether or not a VN is issued depends on the zeal of the individual inspector. If a VN is issued, then you have a formal duty to request a revision to the report. If a VN is issued, it should not include a production hold. If it does, then you should refuse to sign the VN. Instead, telephone or FAX your UL engineer and request a waiver until the report is revised. Scenario : In the report, it mentioned component B carries many safety agency certification, however i the actual physical unit, it only containes one or two safety agency logos. Q3. Is this a non conformity ? Should a VN be raised ? Maybe this is a non-conformity, and maybe it is not. Clearly, one mark is not many, as many implies more than one. If the report uses the word many, then the report is wrong. This is because the report should either specify the cert marks required for this application, or it should not mention the cert marks. In any case, the report should not force the inspector to decide how many marks comprises many marks. If a VN is issued, then you have a formal duty to request a revision to the report. If a VN is issued, it should not include a production hold. If it does, then you should refuse to sign the VN. Instead, telephone or FAX your UL engineer and request a waiver until the report is revised. Q4. When an IPI ( Initial product inspection ) is carried out, should the UL's product report been approved by the UL ? Absolutely. A UL inspection, whether an IPI or a quarterly inspection, is basically a process of comparing the product to the description in the UL report describing the product. Otherwise, there is no inspection as there is no report to compare the product with. An IPI cannot be made to a non-UL product report. If a discrepancy is found, the inspector is not technically qualified to decide whether or the report is wrong or the product is wrong. The VN formally initiates the process to correct one or the other. Q5. Should the report used during IPI is a detailed report with Sec general and condition of testing been included ? At each inspection, whether IPI or quarterly, the inspector is entitled to inspect to both Sec General and to the Sec with the specific product. For an IPI, I would especially expect an inspection to Sec General. This is because this is UL's first visit to your facility, and they will want to examine all aspects. Q6. Can anyone share with me the correct ways the product report/FUS procedure for a product should be written so that we are not caught up with it, particularly on the rating,model and safety agency certification requirement for the product ? When the UL report arrives, you should conduct your own inspection. Go to the production-line, and compare the product to the report. Identify all discrepancies, and make the appropriate corrections to either the product or the report. Then, using a marked-up copy of the report, send the report to UL along with your request to make the indicated changes. If you keep a calendar of UL inspections, you can generally predict the next inspection within a week. A week or so before each UL inspection, you should perform your own inspections, and make appropriate corrections to either the report or the product. On your UL inspection calendar, keep a chart of VN issues per inspection date. Set a goal of 0 VNs. If you do pre-inspections, you can drive the VNs to 0. By doing your own pre-inspections, you will get a feel for problems in the written report. Then you can write reports that will not result in VNs. Speaking from experience, this process works! An inspection is a simple process of comparing the product to the report. Anyone can do this. A VN can be issued for any discrepancy. Do not sign a VN that does not identify a report statement for which the VN is being issued. (Sometimes, this will reveal secret, unpublished requirements!) 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: 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
Re: product safety audit scenario
Scenario : Component A with rating mentioned in the UL's product report as 90-135/180-265 Vac, however in the phyical unit is written as 115/230 V . Q1 : Is this a non conformity ? Should a VN be raised ? Theoretically, it's a non-conformity, however if the component is being used within its ratings, the most appropriate action would be to request a change to the FUS procedure to indicate the actual ratings. My guess is the inspector would write a VN, but not hold up shipment. Scenario :In the report, it mentioned the marking on the label as 120-127V , however in the actual label on the unit it is written as 120-127V/220-240V. Q2. Is this a non conformity ? Should a VN be raised ? Is this the overall product rating? If the product is Listed with a voltage rating of 120-127, you cannot put a voltage rating outside of that range on the label unless or until the unit has been evaluated by UL at the new voltage rating. If the product was tested at the higher voltage rating as well as the lower one, then you need to have the FUS procedure revised to indicate the appropriate rating on the label. Otherwise, it's a non-conformity and you may be required to hold shipment or remove the labels. Scenario : In the report, it mentioned component B carries many safety agency certification, however i the actual physical unit, it only containes one or two safety agency logos. Q3. Is this a non conformity ? Should a VN be raised ? Is it necessary for the component to carry many safety certifications? If not, then the Procedure should only indicate the one type of certification that matters. If the one or two safety agency logos are sufficient, it is redundant to mention others and will likely result in questions or confusion during the inspection. If, on the other hand, the other certifications were mentioned because they are relevant to the requirements of the standard, then they must be there. Q4. When an IPI ( Initial product inspection ) is carried out, should the UL's product report been approved by the UL ? The IPI is usually carried out using a temporary or draft Follow Up Service Procedure that has gone through a final review at UL. The only thing that might remain to be done is to have the report typed in final form and uploaded into their systems. However, for a number of reasons, there may be minor typos or inconsistencies in the report. You need to immediately report any problems or mistakes you identify to the UL engineer who issued the Procedure. If the mistakes are UL's fault (in other words, the information in the report is different than the info you provided them ), then UL should not charge you to fix the report. Q5. Should the report used during IPI is a detailed report with Sec gene ral and condition of testing been included ? Yes. Q6. Can anyone share with me the correct ways the product report/FUS procedure for a product should be written so that we are not caught up with it, particularly on the rating,model and safety agency certification requirement for the product ? One of the most common causes of variation notices is overly detailed information in the FUS procedure. Remember that the UL field inspector does not have engineering decision making authority, and was not involved in the original engineering investigation. Field Inspectors are trained to assume that anything called out in the FUS report is necessary to the safety of the product. If there is a question about the FUS procedure during the IPI that the inspector is not qualified to resolve, then the decision has to go back to UL engineering, which can cost you time and money. You should be concerned with any information in the FUS procedure that is not directly tied to the critical safety elements of the product design. For example, calling out transformer core dimensions to the hundredths of an inch is probably unnecessary, but some engineers may still do it out of habit. The fact that a component has 5 different certification marks on it may or may not be relevant. But if it's not relevant and it appears in the procedure, ask UL to take it out. I recommend you go through the Procedure with a fine-tooth comb and ask UL to make changes to it if there are any items that you think are not safety critical, or not consistent with the actual construction of the production unit. Hope this helps. Greg Galluccio www.productapprovals.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
RE: product safety audit scenario
Alice, I have found that inspectors have allowed a manufacturer to claim more stringent or limited ratings than what is in the UL report. In some products that are rated at 120v from line-to-neutral, but are truly 3-phase products, it has been customary that you can denote the operating voltage as 120/208 vac, 3-phase, 4W+G. However, you need to check and make sure the voltage and number of phases are correctly detailed in the report. If a product has been evaluated by a safety agency, I do not see why you would not want to include the mark. However, there are cases on UL products that the mark is not required. One example is that the device is too small to bare the mark. You need to check the marking requirements for that product. When UL performs an IPI, the inspector needs to bring the report with them. This should be complete and include all section, except for the test record. I have often found this process strange as we do an inspection on the product to the report prior to manufacturing to ensure that our report and product structures are in agreement. When the UL inspector brings the report, it is very difficult to perform this check. You can request a preliminary copy of the report from your UL engineer. While it is unofficial, it will help in the process. As for reports, I am not sure if there is a generally accepted method for constructing them within the various agencies. Every time I get a report from a different engineer regardless of agency, they have differences. Good luck. Bryan Cole Director of Engineering Product Safety Officer Emerson Network Power - Control Concepts Binghamton, New York 13902 Phone: 607.724.1352 extension 238 Fax: 607.724.0153 E-mail: bryan.c...@control-concepts.com www.Liebert.com www.Control-Concepts.com www.Edcosurge.com -Original Message- From: Lay Siang Saw [ mailto:l...@celestica.com] Sent: Sunday, February 16, 2003 10:41 PM To: emc-p...@majordomo.ieee.org Subject: product safety audit scenario Hi all,can anyone share with me with your comments Scenario : Component A with rating mentioned in the UL's product report as 90-135/180-265 Vac, however in the phyical unit is written as 115/230 V . Q1 : Is this a non conformity ? Should a VN be raised ? Scenario :In the report, it mentioned the marking on the label as 120-127V , however in the actual label on the unit it is written as 120-127V/220-240V. Q2. Is this a non conformity ? Should a VN be raised ? Scenario : In the report, it mentioned component B carries many safety agency certification, however i the actual physical unit, it only containes one or two safety agency logos. Q3. Is this a non conformity ? Should a VN be raised ? Q4. When an IPI ( Initial product inspection ) is carried out, should the UL's product report been approved by the UL ? Q5. Should the report used during IPI is a detailed report with Sec general and condition of testing been included ? Q6. Can anyone share with me the correct ways the product report/FUS procedure for a product should be written so that we are not caught up with it, particularly on the rating,model and safety agency certification requirement for the product ? I am looking forwards to hearing a reply from you. Thanks Regards, alice saw --- 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 The information in this electronic message may be privileged and confidential and is intended for the use of the individual(s) named above. If you are not the intended recipient, you are on notice that any unauthorized disclosure, copying, distribution, or taking of any action in reliance on the contents of these electronically transmitted materials is prohibited.
