Safety Assessment Part 2: The Golden Rules for Self-Certification and ΠMarking

Product safety testing and reviews are essential steps in getting a product on the market and saving you from costly litigation.

But why are there so many issues, problems, and techniques involved with basic product safety testing?  The task is a minefield that requires detailed, specialist and encyclopedic knowledge.  There are two reasons for this:

1. It will be the last chance to ensure that a well-engineered product meets the world-wide safety requirements necessary.
2. It is probable that no one will check to make sure the task was done correctly.  This becomes critically important because your work may not be checked unless an incident or complaint occurs, when it will be checked thoroughly and professionally.

At Phoenix Technical Group we believe that it is essential that our clients understand how the Œ  Marking process is operated within the EU and the implications on overseas designers.  Only with this knowledge can our clients fully understand the importance of implementing the Œ Marking process and the full implication to their business if things go wrong. This way we understand that our work may be scrutinized, and can be sure that the reports and other documents convey the necessary “due diligence.”

Remember this: if we get any part of our work wrong then people may die.  That is what our duty of “due diligence” is all about.

There are no shortcuts to proper product safety testing, but our own Gregg Kervill has come up with some “Golden Rules.”  These rules can help any company throughout the design and compliance verification of your product.  Just remember, there is no replacement for knowledge and experience:

1. When we Review or Test, we are trying to make the product FAIL!  We are not trying to prove that it will pass.  See our blog on “The Right Mind-Set.”
2. Always have a copy of the relevant standard with you.
3. Never review a product, or use a Product Safety Review Checklist, unless we have total understanding competence and ability.  You will be placing yourself at considerable risk, both physically and financially, if you make a mistake.
4. If in doubt, always err on the side of caution.  When standards are revised, the changes are usually to make them clearer or make the conditions more severe.
5. If a test is “marginal” but the interpretation of the standard allows you to accept the design, consider the implications if the marginal PASS becomes a marginal FAIL.  Not accepting a marginal pass will save your company money.
6. Remember that critical parameters are specified as MINIMUM or MAXIMUM.  If we use these as nominal design parameters, we will automatically guarantee that 50% of all our products will be non-compliant and potentially illegal.
7. Never be pressured into allowing a dubious product to be supplied to a customer.  Remember, samples and refurbished items must meet the latest standards of safety.
8. Always correct any non-compliance.  To place the Œ Mark on a product knowing it to be non-compliant is a criminal offense.  You may be prosecuted, fined, and imprisoned.
9. Always proceed methodically and record each step.  This will allow others to follow your path.  This will be essential when someone needs to answer a detailed question about the product or to re-specify a critical component.
10. Always get a copy of a safety certificate for each Safety Critical Item before you are committed to use that component.
11. NEVER ASSUME
12. ALWAYS DEMAND PROOF
13. NEVER ACCEPT VERBAL ASSURANCES
14. If a product causes an injury, what will be your defense?  The time to consider this question is before going to market and when you carry out the review process.