To self-declare or not? That is the question
By Amy Zuckerman -- Purchasing, 11/4/1999
Major corporations are challenging the standards-verification and testing world to prove its value, threatening to move toward "supplier's declaration of conformity" (SDoC) for everything from registration to ISO 9000 quality standards to lab tests for non-consumer products.This major shift would reverse the trend of the last decade toward third-party certification and testing--relying on independent test labs and auditing organizations to provide assurance that a product is safe or produced in a quality fashion. Large companies with the wherewithal will maintain their own accredited laboratories and validate their own management processes. Backup documentation will be broadcast through Web sites and any other means necessary to satisfy government officials and consumers. This trend is a huge threat to the third-party certification firms. At stake are billions of dollars in testing fees.
The main goal behind self-declaration is cost savings. For example: Companies affiliated with the Washington, D.C.-based Information Technology Industry Council (ITI) believe they can provide assurance to consumers and government regulators alike through detailed documentation of their procedures and public display of their test results. The threat of product liability is ever-present to keep them honest, they insist. In fact, some industry leaders argue that the supplier-declaration 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 power-house companies in high technology, telecommunications, aerospace, heavy equipment, and automotive industries.
Already, Siemens and Hewlett-Packard have stated publicly that they would not go the supplier-declaration route for any consumer product where health and safety could be called into question. But there are many products--both in and outside of the consumer arena--they believe do not require the same level of consumer assurance as, say, a pacemaker.
Both companies, along with Motorola, have been at the forefront of a "one standard, one test" movement to cut back on redundant conformity assessment (registration and testing) activities worldwide. Guido Guertler--icsca European Co-Chairman--now says some members are prepared to take action on the lab testing side. And they're going to move ahead even if it means bucking government regulators here and in Europe.
"Third-party, independent testing has a role, but not as extensive a role as the accreditation industry wants," he says. "osha (the United States Occupational Health and Safety Administration) may not like this, but we have moved away from old-fashioned, obligatory third-party registration schemes. This is out."
Guertler is careful to point out that even companies as prominent as Siemens and Hewlett-Packard aren't advocating dropping all third-party testing, and certainly not for parts, components, or whole products that are sold to consumers. "You must make a distinction between different product groups," he 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 switch gears or telecomm 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 versus products used in manufacturing (or to make a process work)."
Testing industry responds
Keith Mowry, Manager of Global Accreditation Services for Underwriter Laboratories, Inc. (UL) --one of the largest electrical testing houses in the United States--offers the following statement in response to the iti/icsca proposed 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 suppliers declaration of conformity."
Peter Unger, president of the American Association of Lab Accreditation (A2LA), says he's "sympathetic to 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 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?" Unger asks.
"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."
The question remains--and will remain until self-declaration is tested--whether governments and consumers will trust industry to watchdog itself. Guertler takes the position that if a company maintains an accredited laboratory, that should be sufficient. "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."
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