Product safety and conformity representative (PSCR) (10.03.2019)

Product innovation frequently results in increasing product complexity, with simultaneous shorter development cycles. Combined with increasing customer expectations in terms of the function and safety of products, this raises particular challenges for all companies involved.

Companies not only have to deal with new customers and their cultures, but also with changing customer expectations and the country-specific laws and requirements that apply to the products. Furthermore, the sensitivity and connectedness of product users and authorities, and public discussions on the issue of product integrity have increased significantly.

In this context, the question arises as to which organization structures and processes must be established in a company and how a company should react if a product is classified as potentially non-conform or as potentially safety-critical due to discrepancies in one or multiple countries.

The answer to this question is subject to a certain level of complexity that results, among other things, from the number of parties involved (authorities, product users, OEM, suppliers) and their various requirements.

Reasonable safety expectations from customers, consumers, and uninvolved third parties (the “general public”) need to be identified and taken into account. If products prove to be “unsafe” in the market, the company has an obligation to initiate the necessary measures to protect customers, consumers, or the general public.

The resulting duty of care is the basis for appropriate handling of safety and conformity-related issues.

From these insights, companies can develop preventive measures with regard to internal processes, methods and tools, as well as the organization structure.

The fundamental responsibility of senior management cannot be delegated, but duties designed to meet this responsibility can. Responsibility for particular duties can be delegated, provided that the competences (for decision-making and action) are verifiably defined (e.g. in writing), the relevant person is carefully chosen and their qualifications can be confirmed. This kind of delegation should take place explicitly, promptly and effectively.

A company should identify people, qualify them and assign them the required authority to formulate and implement preventive and corrective measures.

We will start from this April the updated two-day training ID 503 Product Safety and Conformity Responsible (PSCR) and one-day training ID 533 Upgrade Training from PSB to Product Safety and Conformity Representative (PSCR) to ensure such competence and qualification of responsible persons.

Mikhail Kalinichenko

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