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Continuing
Compliance Management
Since
the arrival of the European Unions R&TTE Directive, and the subsequent
easing of telecommunications regulations, the Maintenance of Compliance
has now become a leading issue for Telecommunications Manufacturers.
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R&TTE
Surveillance Authorities have been successful in removing non-compliant
Radio and Telecommunications Terminal Equipment from the entire European
Union Market
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Several
of our clients have been audited for compliance of their Regulatory
Compliance Folder
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It
is therefore possible that any manufacturer of Radio and/or
Telecommunications Terminal Equipment could be audited by any of the 18+
different European Union Surveillance Authorities
To
alleviate the potential problems of a non compliant Surveillance Audit by any of
the 18+ Surveillance Authorities, Patton & Associates are now offering Continuing
Compliance Management services
Background
The
R&TTE Directive mandates that equipment shall continue to comply with the
Essential Requirements against which compliance was originally declared.
Surveillance
Authorities in each Member State of the European Union police the market place
pro-actively to ensure that equipment placed on the market meets these Essential
Requirements; they will also react to complaints made by customers and network
operators concerning equipment which is suspected of non compliance.
Further,
the network operators are bound by national laws and by the terms of their
operating licenses to ensure that equipment which operates over their
network-cabling infrastructure shall not cause harm or interference. All network
operators are obliged to disconnect harmful equipment from their network and to
inform Surveillance Authorities of any the suspected equipment.
Surveillance
Authorities can and have demanded that non-compliant equipment be removed from
the market place throughout the entire European Union. Additional penalties for
non-compliance can be draconian, restrictive and prohibitively expensive for a
manufacturer wanting to market R&TTE equipment in the European Union.
Patton
& Associates know of a number of manufacturers who have been called to
account for non-compliance and have been required to withdraw equipment from the
market place, ship all non compliant product out of the European Union and back
to its point of manufacture.
Regardless
of whether equipment is defined as terminal equipment or as part of the network
infrastructure, it is likely that at some time in the future it will be audited
by one of the Surveillance Authorities to ensure compliance with the
regulations.
Continuing
Compliance Management Services
Patton
& Associates Continuing Compliance Management
Services include, but are
not limited to, the following:
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Review the Manufacturers existing Compliance
Folder [1]
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Review Manufacturing ECO's and check if these
raise Continuing Compliance issues
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Review Manufacturing Quality System
documentation and procedures
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Management of all Continuing Compliance queries
and correspondence with European Union Surveillance Authorities
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Management of all claims, investigations
and litigation associated with audit of Compliance Folders and compliance
documentation by the European Union Surveillance Authorities
[1]
The
first "port of call" by a surveillance authority will be scrutiny of
the Compliance Folder. It is imperative that the Compliance Folder, and hence
product compliance, is kept up to date
A
copy of The R&TTE directive may
be downloaded at: http://www.patton-assoc.com/
History
of Legislation. The
legislation that has affected R&TTE emerged from different sciences and
disciplines. The EC-wide Low Voltage Directive 73/23/EEC (1973) covered safety
of all ITE. This Directive was eventually designated by all Member States to
cover nationally approved TTE as well as EC-wide approved apparatus. Similarly,
the EMC Directive 89/336/EEC replaced national legislation to cover all ITE and
TTE. The TTE Directive 91/263/EEC (later to become 98/13/EC) used to cover
approval of technically harmonized TTE before the advent of the R&TTE
Directive.
The
full title of the R&TTE Directive is:
Directive 1995/5/EC of the
European Parliament and Council of 9th March 1999 on Radio Equipment and
Telecommunications Terminal Equipment and the mutual recognition of their
conformity.
Author
biography –
John Roche is Managing Director of Patton & Associates (UK) – the European
office of Patton & Associates Inc. of Prescott Arizona. Patton &
Associates provide Telecommunications Consulting, Design and Type Approval
services for Europe, North America and The Pacific Rim.
John
Roche can be reached at: roche@patton-assoc.com
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