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Conflict Minerals – Have You Failed to Prepare and Are Now Preparing to Fail?

By Nigel Burtt

Use of Conflict MineralsAs we have pointed out previously in this blog, the requirements of Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act  mean that companies in the USA affected by the Securities & Exchange Commission (SEC) reporting rules for conflict minerals reporting need to have systems in place to gather the necessary data for this entire calendar year for the first submissions to the SEC which are required by May 2014.

The nature of this legislation is that, like the EU’s RoHS Directive and REACH Regulation, its data collection requirements are driven down the global supply chain, putting a significant burden on SME suppliers with customers in larger organisations upstream of them. Those companies who are unable to provide their customers with the reporting data they need are likely to find that orders are moved elsewhere to other companies who can.

Continue reading Conflict Minerals — Have You Failed to Prepare and Are Now Preparing to Fail?

Engineering Our Future Links to original Articles Blog

icm_current_coverFor our readers, who do not subscribe to InCompliance Magazine, the following are links to an article written by Gregg Kervill, Senior Engineer, IEEE with his take on the future of engineering.
The article was published in three separate issues with the last section appearing in the May 2013 issue.

Engineering Our Future: A View of Changes Facing Engineers -Part 1
Engineering Our Future: A View of Changes Facing Engineers – Part 2
Engineering Our Future: A View of Changes Facing Engineers – Part 3

We would love to have your comments. It is an important subject of concern to all of us and future generations.

Compliance and ‘Blame Mitigation’

Finger PointingWe need only turn on the TV to confirm the statement that “We are a litigious nation”; but what does that really mean?

During the Toyota “sticky throttle” debacle how many people, when stopped for speeding, blamed their accelerator pedal for sticking?

Are we regressing to the school-boy mentality of Blame Mitigation? You remember, back at school, when the school bully pointed to the weakest member of the class and pleaded: “It’s not my fault – he MADE me do it!”

Continue reading Compliance and ‘Blame Mitigation’

The Irrational Guide to Regulatory Compliance in the EU, the US and the World

by
Gregg Kervill

Should-it-come-off-like-thisSynopsis: The following spoof article by Gregg Kervill, has been compiled to expose that ever present belief (in the words of Isaac Asimov) that “my ignorance is just as good as your knowledge”.
It is published, and we trust will be received, in the spirit in which it is written – to use humor, that we may better retain what we are about to learn.

Continue reading The Irrational Guide to Regulatory Compliance in the EU, the US and the World

A Plastic Box may not be your friend

It’s funny how the same issues come round regularly. The first time I saw these was in the mid 90′s when I was shown a family of power supplies that had been built into the sort of plastic boxes you can get from Radio Shack.

Now, there is nothing wrong with plastic boxes from Radio Shack – until you try to use them in an application for which they never intended – for example Building Power Supplies.

The client needed a number of “Cheap” power supplies to power instrumentation that connected to a computer – and these power supplies were certainly cheap. . . . .

These PSU’s also needed to comply with EU Safety Directives (it was before the days of REACH and RoHS, which now apply to most products.).

Plastic was to be the material of choice for the boxes (..”because it is an insulator”…).

A simple “E-I” core transformer took the incoming 230V AC to about 15 Volts AC at about 100 mA and provided Basic Insulation across the bobbin between Primary and Secondary and between Primary to the transformer core.

Capture Capture2The designer had applied “good engineering practice” and added an internal 20 mm glass fuse rated 1 Amp (T) 250V.

All fastenings for these items were steel with ‘nylock’ nuts.

 

Let’s forget about applying any specific standard to this design and let’s just list a few of the obvious potential hazards. You should need only the descriptions given to identify the potential hazards and their solutions.

Electric Shock – (a) from the screws fixing the transformer core and (b) screw holding the fuse holder; (c) from a failure of Basic Insulation between Primary and Secondary winding to dc output

Fire – (d) the plastic had a UL94-HB rating ( which limited its use to a decorative enclosure);
(e) the fuse rating would not protect the transformer from fire; (f) a glass fuse will have a typical maximum “breaking” current of only about 30 Amps. This means that a Live Neutral fault could create a fault current in excess of 2,000 Amps – causing the fuse to explode and create a plasma that would sustain the fault current – perhaps for several seconds.

Mechanical – (g) the box cracked during the steel ball test and allowed a test finger to contact live parts; (h) the box failed a drop test – the transformer fastenings pulled through the box and rattled about inside the box smashing everything inside; (i) the external (slotted screw) fastenings could be turned by the user and internal insulation barriers could be bridged.

QUESTION – with only the information given above:  Which hazards cannot be solved if the box is an electrical insulator? –   If you select a better grade of plastic for the box, how would you solve the remaining non-compliances?

 

CLICK HERE TO SEE OUR suggestions.

 

 

News Release: March 2013 – Tightening Europe’s Point of Entry

european_flag-200At the moment Enforcement rules across the EU are inconsistent and fragmented. This means that there are specific ‘soft’ points were non-complaint and unsafe products can enter the EU without detection, this is bad, but, because of the Single Market principle those non-compliant (and unsafe) goods then have free access to every Member State.

The result is bad for consumers (who expect that all products of the EU Market are safe); and for businesses (that expect fair trading conditions).

Continue reading News Release: March 2013 — Tightening Europe’s Point of Entry

Quality Management Systems, Audits, and Technical Files

Maintain Technical Files Simply and without Tears

Moment in TimePROBLEM STATEMENT:
Directives and Regulations change from time-to-time (announcements are made monthly in the OJ) and may introduce new requirements or actions in addition to those summarized by your product’s Technical File. (Example; the REACH Recast.)

Additionally, Standards also change, adding new requirements or changing Pass-Fail criteria.

These two factors mean that all Technical Files are TIME DEPENDANT and MUST change to reflect changes within EU Directives, Regulations and Harmonized Standards.

Continue reading Quality Management Systems, Audits, and Technical Files

“The Chicken” or “The Egg”?

5737-Who-Came-First3

Which came first the design requirement or the production drawings?”

It’s easy to see that the design requirement came first, now ask the question “Which came first the regulatory requirements or the product design?”

Here it is not so easy to give a clear answer because the final product will be influenced by both the design requirements and the regulatory requirements.

Continue reading “The Chicken” or “The Egg”?

EMC You’ve Come A Long Way Baby

EMC has not only come a long way, but has progressed from a black art to a science.emc3A

In the 1960′s/70’s very few designers concerned themselves with EMC performance. The only exceptions for commercial products were if interference prevented the product working properly, interfered with radio or TV or where a failure could mean loss of life or serious injury.

Whereas the requirements and specification for military, flight and satellite products included requirements for EMC testing and compliance, at that time they were not as comprehensive as the today’s requirements for a domestic washing machine imported into the EU.
Continue reading EMC You’ve Come A Long Way Baby

A New Year And New Environmental Regulation

Well, the end of a Mayan calendar cycle on the 2012 Winter Solstice apparently didn’t signal some cataclysmic event with global impact, but even so, as one cycle ends, a new one begins.

There are a number of important changes for manufacturers and distributors of electrical and electronic equipment, that apply immediately in 2013 if their products destined for the EU marketplace are already subject to the requirements of the recast RoHS Directive, which was due to be enforced in all Member States’ law-books on 2nd January (for example here is the UK implementing regulation.)

Continue reading A New Year And New Environmental Regulation

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