Introduction – Important stuff

1.1        Copyright – share

This material is subject to worldwide copyright with a permission to share.

Phoenix Technical Group grants limited permission to share this information with your friends and colleagues subject to the following conditions, you must forward the document in its full entirety AND the information is not to be republished under any other name AND the information is neither to be sold nor used for profit.

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This material is an excerpt from Gregg Kervill’s fourth book “The Encyclopædia of Electrical Product Safety” which will be on sale April 1^st.

1.2        Why Lifetime Access?

Having a loyal customer base is one of Phoenix’s essential pillars for success.  Because we value return customers so highly, we make sure that all our products are as up-to-date as possible. The EU is constantly making changes, so we don’t give our products an expiration date.  Unless the regulatory change is so drastic as to warrant what is essentially a new product (this would be very rare), our registered paying customers will have Lifetime-Access to updates free-of-charge.

1.3 Why the Phoenix Solution?

In engineering, as in management and other disciplines, we’ve got to do more than just getting it right.  In the words of my old physics teacher “You’ve got to know the why.” Without understanding we will never know how to repeat our successes, to eliminate our failures or what to do when a new situation arise.

2         Engineers – Globalization and the Right Attitude

“Where interaction created separate societies, each will develop its own culture, and individuals will be governed by different sets of rules and share a different perspective. Without continuous interaction ….. each will fail to communicate with, and understand the other” (from “Symbolic Interactionism” by Joel M. Charon – Prentice Hall)

Joel’s statement accurately defines the difficulty faced by engineers in a world market –it is our responsibility, as product safety professionals, to bridge that fissure of different cultures. We must protect non-engineers, the illiterate and the young from products that could kill them.

To do this we must imagine ourselves as the operator who will misuse, mishandle and fail to see any hazard that occurs. In addition to managing this contradiction we must (simultaneously) use our engineering knowledge to devise means of protecting future users from any of the potential hazards and components failures we can identify.

2.1        Being Positive can be Bad

It is our nature to be positive.  This is brought about by our upbringing, our education, and our culture, and it is the wrong attitude for any compliance engineer.

When reviewing a product we must attempt to prove that it can create a hazard.

We must attempt to make the product fail; we must use our knowledge and experience to identify failure modes that will result in hazards – damage, injury and even death.

This is how Product Safety professionals must think – and it is not only hard to think this way but it takes time and discipline to ‘unlearn’ what we have been taught in our early years.

It is only by identifying and eliminating ALL potential hazards that we can have any confidence that a product is compliant with the relevant safety requirements.

2.2        Life or Death

Before we start any review, remember that if we make a mistake someone may die. It is this personal responsibility that makes Product Safety Engineering unique – few other careers place such a huge responsibility on any individual.

Have you ever considered how high Product Safety Engineers rank on the list of potential killers!

Whereas a surgeon can kill only one person at a time – a Product Safety professional has the ability to kill hundreds of people in one go!

For example – the Titanic had several design and construction defects.  These included poor steering, defective steel, and watertight bulkheads that were not fully sealed.  When it struck an iceberg, in the Atlantic Ocean, more than 1,500 people died in freezing water.

Product Safety is a job that results in Life or Death. That is why PSE’s must have strong characters. We must be prepared to be the only member of a group to say “This is not right – It is not acceptable.”

Even today, few product safety professionals can rely on someone checking their work and finding an error they may have missed.

2.3        Use and Service

It is not sufficient for us to consider component failures and the hazards they create – we must also think about the User and the Service Engineer. These individuals can also introduce hazards of their own.

We can, generally expect that a User will be unaware of hazards. This means that we must expect the operator to touch any exposed hazardous part. This condition is especially valid for household and domestic goods and some Information Technology (IT) products. (For example – the cooling slots of most monitors now pass the “chain-test” from IEC 60065. This is an acknowledgement that the PC now has a place alongside the family TV and Audio system and should consider the same physical abuse.)

Therefore, it is the duty of the product safety engineer to consider the User might do something that (to an engineer) might seem unreasonable or just even just plain stupid; and to protect those Users from “reasonable abuse and foreseeable misuse”.

3         The Golden Rules

We now live in the world of instant gratification, and not surprisingly we are always asked for short-cuts or how to simplify the compliance process – unfortunately there are no short-cuts or panaceas that replace understanding, knowledge and experience. There are, however a few fundamental rules – break any one of these are you will rue the day.

1. Throughout the Review and Test try to make the product FAIL!
   It is fundamentally impossible to prove that a product will not cause a hazard; the best we can achieve is to fail to make it fail in a way that does not create a hazard.
2. Sit and look at the product (without any interruptions) for at least an hour.
   Use your engineering knowledge to ‘invent’ ways for a hazard to ‘escape’ from the product and contact the operator. Detail how may protection systems must fail before the hazard escapes. (Example a failure of Basic Insulation, a plastic wall must catch fire.)
3. Next, repeat the process, this time ‘invent ways for the operator to contact hazardous parts, or one of the consequential ‘hazards’ that you invented during step 2. As you perform this in-depth analysis, detail how many protection systems are in place and how they must fail for the hazard to become a threat. (Example hazard is contained by an enclosure. For a hazard to escape part of the enclosure must break or bend to allow finger contact.)
4. Now take the checklist you have created for the appropriate standard(s). (Remember that using checklists does not reduce our liability, nor our responsibility to understand the relevant standard, and knowledge of hazards. At best it will demonstrate that you took ‘due diligence‘ – in the worst case it will demonstrate your negligence.)
5. If in doubt, always err on the side of caution – when standards are revised the changes usually result in a more demanding interpretation.
6. During the review and testing you must identify every “Marginal Pass”. This is because every marginal PASS has the capability of becoming a “Marginal Failure”. (Example some critical parameters are specified as MINIMUM or MAXIMUM. If the design uses these as “nominal” dimensions you can guarantee that 50% of all products fail to meet the Minimum safety requirement.)
7. Never allow yourself to be pressured into allowing (or approving) a non-compliant product – even if it is a ‘sample’ that the customer “must have”. (Samples and refurbished items must meet the latest standards of safety.)
8. Proceed methodically and record each step. This will allow others to follow our path – and is essential when future modifications are required.
9. Always obtain a copy of safety certificates for each Safety Critical Item.
   NEVER ASSUME – ALWAYS DEMAND PROOF – NEVER ACCEPT VERBAL ASSURANCES.
10. Finally, NEVER give in to pressure. Yes this has been stated before. To give in to pressure is the most dangerous situation for any compliance engineer. Your job is to protect the customer/user. If you give in to pressure – you will put them at risk and lose your professional credibility. When it is known that you gave in to pressure no-one will ever trust you again.

This material is an excerpt from Gregg Kervill’s fourth book “The Encyclopædia of Electrical Product Safety” which will be on sale April 1st.