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European Conformity Assessment (ECA) (Project INCOLAB G7RT-CT-2002-05106). Cor van der Ploeg CvanderPloeg@NMi.nl NMi Van Swinden Laboratorium The Netherlands Notified Bodies for LVD and their problems (NL example) Prague 4 December 2003. 15. Institutional Triangle. Manufacturers. Q.
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European Conformity Assessment (ECA) (Project INCOLAB G7RT-CT-2002-05106) Cor van der Ploeg CvanderPloeg@NMi.nl NMi Van Swinden Laboratorium The Netherlands Notified Bodies for LVD and their problems (NL example) Prague 4 December 2003 15
Institutional Triangle Manufacturers Q Government Institutions INCOLAB Prague 4 December 2003
NB’s and CA • The primary task of a NB is to provide services for CA on the conditions set out in the Directives, this is a service to the manufacturers in an area of public interest Public role • NB’s are free to offer their CA services to any economic operator in or outside the Community and may carry out these activities also in other Member States or third countries EU Competition • Manufacturers are free to choose any NB that has been designated to carry out CA according to the applicable Directive Self Declaration Cost effectiveness INCOLAB Prague 4 December 2003
Conformity assessment procedures B Type examination A Internal control of production G Unit Verification H Full quality assurance ISO 9001 C Conformity to type D Production quality assurance ISO 9002 E Production quality assurance ISO 9002 F Product verification INCOLAB Prague 4 December 2003
The CA Modules INCOLAB Prague 4 December 2003
ECA Flow LVD INCOLAB Prague 4 December 2003
So the problem for LVD NB’s • They have to perform a public task • Relatively low level of market surveillance • CA is only Module A, so the choice is fully to the manufacturer, so self-declaration. • Manufacturer seeks for cost-effective solutions, • In LVD no formal need to go to a NB • The “challenge” art 8 is very exceptional • The only real driver is avoiding liability problems by manufacturers • So very limited business for NB’s and no base for big long term investments INCOLAB Prague 4 December 2003
The Dutch situation (1) • Only 3 NB’s for LVD • KEMA Arnhem • Long history of safety testing, focused on household appliances, continues activities as good as possible • TNO E.P.S. • Former NMi, • Former lab of a electronic instruments manufacturer • Combines services with EMC etc. testing • Mainly relying on consultancy • Low level of investments • Gastec Apeldoorn • Combined services with testing of gas-appliances • LVD Expert just left the institute INCOLAB Prague 4 December 2003
The Dutch situation (2) • Recently a new big player in The Netherlands: • European headquarters of Underwriters Laboratories (UL) in Venendaal • Mainly focus is USA requirements for insurance (very strong impact of legal liability in the USA) • Provides its services for European manufacturers exporting to the USA • Uses its existing NB’s in the UK and Denmark to offer also LVD services INCOLAB Prague 4 December 2003
Main topics to discuss, NB’s LVD • Essential impact of liability • Accreditation (by a EA body) is prove of reliability • Drive to lower costs by Manufacturers • Low key role of Market Surveillance for enforcement • Most labs have historic position, new labs in insurance related business • Limited economic base for big investments • Main business is consultancy INCOLAB Prague 4 December 2003
Institutional Triangle Manufacturers Q Government Institutions INCOLAB Prague 4 December 2003