Join Date: Jul 2002
Thanked 4 Times in 4 Posts
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Paulo, that''s quite a lengthy post and I sure don''t have the time to dig into it chapter & verse...but I would like to offer one general observation. I think you place a huge amount of trust in the CE process, from when the draft rules were first created to how they are implemented today at a manufacturer''s plant, and as a result your points are building - at least to some extent - a house of cards.
These rules were heavily influenced by the manufacturers themselves, who participated extensively in the committee process, and were shaped for commercial concerns, and cedrtainly not solely safety-related concerns. Moreover, from personal experience I can assure you that a Notified Body, which is the entity that confirms ongoing compliance with the CE & RCD standards, is hardly the impartial body you describe. They are paid by the manufacturer, they have a commercial interest in continuing that relationship, and it''s much fairer to view this on-site inspection as an infrequent, imperfect, unfolding ''process'' than as some kind of absolute, non-stop compliance check. In fact, I''ll bet - admittedly a guess on my part - that a given Notified Body visits a given factory (e.g. consider a Bavaria, Beneteau or Jenneau plant) for perhaps two or three days in a two year period. One consequence of this is that these on-site compliance visits inevitably become paper & process checks and not nearly so much a real-world ''survey'' or inspection of the boats as built as the average consumer might imagine.
The RCD is a rating system which had as its original purposes the standardizing of build & trade practices within the EU and as a trade barrier to competition from outside the EU. That doesn''t make it worthless but it makes it far from an absolute guarantee of anything. IMO you are really inflating its significance.