2019

Industry Leaders Seek Self-Declaration
in Lab Testing

by Amy Zuckerman

Some industry leaders are pushing supplier's declaration of conformity (SDOC) with a recent call for industry self-declaration in the realm of lab testing, as well as for management system standards.

If a number of major high-tech and telecommunications corporations have their way, there will be a return to In-House/On-Site testing and certification--what industry calls SDOC. Companies with the wherewithal will maintain their own management processes, broadcasting backup documentation through Web sites and by any means necessary to satisfy government officials and consumers.

This move would reverse the trend of the last decade toward third-party certification and testing, which means relying on independent test labs and auditing organizations to provide assurance that a product is safe--or even produced in a quality fashion.

The main aim behind this trend is industry cost savings. Major companies affiliated with the Washington, DC-based Information Technology Industry Council (ITI) believe they can provide assurance to both consumers and government regulators through detailed documentation of their procedures and public display of their test results. They insist there is always the threat of product liability to keep them honest.

Some industry leaders, in fact, argue that the SDOC approach is imperative to maintaining a competitive stance in today's global economy.

Besides ITI, members of the Industry Cooperation for Standards and Conformity Assessment (ICSCA) are also supporting this trend. ICSCA includes a number of powerhouse companies in the high-tech, telecom, aerospace, heavy equipment and automotive industries.

Health and safety exception

Companies such as Siemens and Hewlett-Packard have stated publicly that they would not go the SDOC route for any consumer product where health and safety could be called into question. But there are many products--both inside and outside the consumer arena--they believe do not require the same level of consumer assurance as, say, a pacemaker.

Both companies have been particularly supportive of the notion of "one standard, one test" as part of a world industry effort to cut back on redundant testing practices. In recent years, these companies along with Motorola have been at the forefront of a movement to cut back on redundant conformity assessment (registration and testing) activities worldwide.

To date, there has been a lot of talk from ICSCA and its members of going the SDOC route. Last spring, this group resolved to move toward SDOC to the ISO 9000 international quality assurance standard by the year 2005 if registrars don't provide proof of value.

However, Guido Guertler, the ICSCA European co-chairman, now says some members are prepared to take action on the lab testing side. And they're prepared to move ahead, even if it means bucking government regulators here and in Europe.

"I feel the third-party, independent testing house has a role, but not as extensive a role as the accreditation industry wants," Guertler says. "OSHA (the United States Occupational Health and Safety Administration) may not like this, but we have to move away from old-fashioned, obligatory third-party registration schemes. This is out."

Guertler, head of standards for Siemens, is considering proposing to ICSCA members a pilot program for supplier's declaration that would include testing for safety and other functions. Hewlett-Packard, which he says has already taken the SDOC approach for its printers and for basic electrical safety, could serve as a model for other companies.

The next step, according to Guertler, would be to develop a format for supplier's declaration based on the Hewlett-Packard model. Then a number of ICSCA companies adopting this format would move from third-party testing to the SDOC route.

Not for consumer products

Guertler is careful to point out that even companies as prominent as Siemens and Hewlett-Packard aren't advocating dropping all third-party testing, let alone for parts, components or whole products that are sold to consumers. Third-party testing will be retained when necessary to assure consumer confidence.

"You must make a distinction between different product groups," Guertler explains. "If you talk about pacemakers, then every manufacturer is advised to have them third-party tested, even if that's not mandatory and you're just looking for market support.

"But if you look at high-voltage switchgears or telecom public switches, then third-party testing doesn't make sense. These products don't harm anyone. We have to make a distinction between products used by consumers vs. products used in manufacturing or to make a process work."

Guertler also imagines scenarios that would make it unnecessary to continue independent party testing for machinery that's used by educated, skilled people. He says third-party accreditation shouldn't be mandatory unless products fall into a category where the government has an obligation to protect its citizens.

"About 90% of industry involves good companies, and maybe only 5% or 7% of companies are trying to misuse any market rules for individual advantage," adds Guertler. "Market surveillance is necessary to sort out these. Supplier's declaration is supported by ICSCA because product liability is something the manufacturer always faces. The legal aspects are there anyway."

Guertler also points out that in many countries, independent test lab results may not stand up in court in the event of a product liability suit. The courts will examine the lab results, but not necessarily consider these results sufficient evidence to acquit.

Reaction of Underwriters Laboratories

Although no figures are available, the supplier's declaration trend could mean substantial lost business for independent test houses--whether they provide registration services (auditing for management processes) or actual laboratory testing for health, safety and environmental factors.

The multibillion-dollar conformity assessment (certification and test) industry is already mobilizing behind the scenes to address this latest industry threat. Reactions are being prepared.

Keith Mowry, manager of global accreditation services for Underwriters Laboratories Inc. (UL), one of the largest electrical testing houses in the United States, offers the following statement in response to the proposed ITI/ICSCA action in the accreditation arena:

The two basic objectives for any conformity
assessment activity, including suppliers declaration of conformity, are 1) measurable value for the supplier in terms of cost/benefit, and 2) confidence for the acceptance interest regarding demonstrated compliance with relevant requirements.

Acceptance interests are those who take an interest in conformity and whose confidence in that conformity provides some tangible benefit to the supplier or producer. When public safety is involved, confidence demands are and should be very high since risk to life and property are at stake.

The most effective conformity assessment in a given situation is that which satisfies confidence demands in the most cost-effective manner. UL fully supports this principle of effective conformity assessment. UL also notes the dynamics of confidence demands from numerous acceptance interests and the perception of value among numerous suppliers may make sweeping generalizations about conformity assessment in a given situation less than meaningful.

UL is committed to public safety and other societal benefits by meeting the confidence demands of acceptance interests and the demands for value from suppliers through a variety of conformity assessment services, which include third-party services, as well as services to support supplies declaration of conformity.

A2LA suggests combination approach

Peter Unger, president of the American Association of Lab Accreditation (A2LA) made the following comment on ICSCA's proposed movement to SDOC:

I'm sympathetic to the manufacturers' concerns and I appreciate where they're coming from, but we often need information [about a product's safety or environmental impact] to satisfy foreign customers. How do you draw the line between an IBM and a schlock shop? And even the best of manufacturers make mistakes.

How do we educate the marketplace [about a product]? Third parties only enter the picture when imperfect information about a product is available. For example, does a pacemaker work?

There should be an appropriate combination of third-, second- and first-party certification. SDOC should be valid in a buyer/seller transaction, and mostly, it is. But I also wonder if these same manufacturers would allow their suppliers to self-declare to their requirements. What's good for the goose is good for the gander.

A spokesman for the U.S. Registrar Accreditation Board and Bob Levine, president of the Independent Association of Accredited Registrars (IAAR), declined comment because most U.S. registrars do not provide both registration and lab testing services.

Small and mid-size companies will have to make an assessment of whether they can provide an assurance of consumer confidence before adopting a supplier's declaration approach.

Question of trust

The question remains--and will remain until tested out in reality--whether governments and consumers will trust industry to sufficiently serve as its own watchdog. Guertler takes the position that it should be sufficient for a company to maintain an accredited laboratory. "I think that test results from a manufacturer-accredited lab are the same as test results from third-party labs."

And, yes, he says it will be up to manufacturers to prove themselves. According to Guertler, "Supplier's declaration gives much more information than any product mark or test house mark can provide the customer. To give confidence to the market--which is the world's population--is no problem for good companies. This is the way to go."


AMY ZUCKERMAN is principal of A-Z International Associates in Amherst, MA, a consultant on the value-added ISO 9000 process and author of the book International Standards Desk Reference: Your Passport to World Markets.


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