The “Good Housekeeping Seal of Approval” was launched in 1909 by Good Housekeeping Magazine. The publication, a first in consumer protection (in the early Spring of social advocacy) guaranteed satisfactory use of products that bore their Seal. The guarantee states that “if any product that bears our Seal or is advertised in this issue (with certain exceptions) proves to be defective within two years from the date it was first sold to a consumer by an authorized retailer, we, Good Housekeeping, will replace the product or refund the purchase price.”
“Certified” goods—kind of. If your GHS (Good Housekeeping Seal) umbrella inverts on a windy day and was proven to be defective, you’ll get a refund. Vacuum cleaner doesn’t suck anymore? Write the magazine, fill out a form, explain the problem, have them do their due diligence and you’ll be whole in no time. A hundred years on one looks back to the last ’09. Kids weren’t concerned—or didn’t know—that celiac’s disease made you steer clear of wheat gluten. I would submit that growing up in rural Maine, having anything on the plate was cause for celebration (and you knew where your potatoes came from). Now, food choices have widened broader than a politician’s smile and “food scares” make the news and the rounds of the virtual water cooler of online news, blogs and social networking sites. Still, one hundred years after Upton Sinclair penned The Jungle, we continue to have serious concerns about food safety. Until we give up eating, I submit that these worries will continue.
Maine early 20 C.;
What is the response to panic over products? Whenever there is some kind of crisis, the first response is to push for “Certification” of some form, whether it be government or industry-mandated. If the government gets involved, the real pushing and shoving begins. And at the end of the day, what sort of comfort level does this bring the consumer? When all is calm or in less-celebrated situations, is the public all that interested? Only when something goes wrong…that’s when the e. coli hits the fan.
The question is where is the balance between adequate protection and smothering regulations? When one interest group pushes for reform, another decries the added cost (calculated in various ways) to the product or process. Another issue is raised when the term “Certification” is inappropriately applied. I can certify that every fact in this missive is true, but on whose authority? Mine? When is self-certification sufficient? Only if someone with a self(ish) interest is paying attention, most likely your competitor (alternatively, take the Wikipedia model of group peer-review).
There is currently a lot of momentum in the Certification world, across many different sectors and product types and, deriving from Newton’s second law, momentum is directly proportional to the force applied to a body. Forces act from various directions: the public, industry, regulatory authorities and the testing industry.
With the ultimate goal to protect the public, an open system of Certification, which involves multiple stakeholders and a process of oversight and exchange, is the most effective sort. The challenge is to build something that is strong but flexible, much like a building built in an earthquake zone, allowing a little wiggle without falling to pieces.
This article discusses some of the trends and forces acting on the Certification process. In our corner of the sandbox—electronics—the growth of Certifications has leapt right along with the growth of standards and technologies. Just flip over your laptop and look at all the cartoons on the label, nearly every one of the logos depicting some type of Certification. We’ll take a stab at discussing the structure of Certification and some of its forms that assure that products stay in compliance.
An Overview of Certification Systems
According to the United Nations Environment Programme, “Certification systems seek to ensure that products meet a set of agreed-upon standards.” Note that the verb in that sentence is “seek”. There is no real guarantee that the standards are being met; we live in an imperfect world after all. The critical element is that there is ultimately traceability (and culpability) in the system, even if a product is less than stellar.
Types of Certification in the Electronics Industry
There are two general categories of Certifications that are used in the electronics industry. These can be broadly broken into Regulatory Certification and Industry Certification.
In the regulatory (i.e., governed) world, Certification is usually reserved for devices that have a high degree of potential risk, should the device fault, fail or be incorrectly produced. Product safety is a commonly-known certification regimen. The other common type of certification is relegated to radio transmitters under the FCC Rules and Regulations.
There are several other types of product approval schemes, some involve simple registration, wherein the evaluation of the product is not lodged, only the potentially culpable party is listed with the regulatory authority. The other regimens are more strict, such as for medical devices, which require a full or detailed submission and authorization prior to marketing. The most stringent type of approval, arguably the most expensive and complex is for pharmaceuticals.
Other types of government device certifications include programs that deal with compromising emanations under the National Security Agency’s TEMPEST program. This type of certification pushes the authority to the testing agency, which is accredited to produce reports that demonstrate that the proper RED/BLACK isolation is maintained.
On the industrial side, a further division might be made between “private label” programs and “industry” programs. Private label programs (like the Good Housekeeping Seal) are usually mandated to either provide a marketing advantage or to screen certain producers of products that are designed to operate on specific platforms or operating systems.
Such examples are the Good Housekeeping Seal and certain types of Logo programs that certify that bits of software code are compliant with test cases (and won’t crash your smartphone).
The second type of industrial program includes industry consortium or programs that are built around consensus standards. These programs usually consist of a group of companies that operate in the same technology space and share a common resource for certifying products. An example of this is the WiFi Alliance, wherein a group of industry leaders in the wireless space developed test protocols and a program to certify devices to be in compliance with the common wireless networking that the industry adopted.
Structure of Certification Processes
If Conformity Assessment is the trunk of the product assuredness tree, Certification is a specialized branch on that tree. The roots of the tree grow in the soil of the nourished by certain demand-drivers, these being regulations or product acceptance requirements. Continuing the tree analogy (perhaps to absurdity), products form like fruit in various outlying branches and Adam and Eve pluck juicy products…well this is where the analogy breaks down because we all know what happened to A&E, snake or no.
Under a conformity assessment process, one introduces the concept of the third party. Third party evaluation is performed by an organization or entity that has no interest (theoretically) in the outcome of the evaluation. The other two parties are the manufacturer or seller (first party) and the consumer or buyer (second party). The Third party simply issues an evaluation against the common criteria that were agreed to (or specified) by the “demand drivers”. Supposedly, the third party is completely agnostic as to the outcome of the evaluation and is really only interested if process has been served and criteria applied correctly. Of course, this doesn’t happen in the real world as there are human interests at play, including greed, mischief (often a cousin of greed), ennui, laziness (and even sometimes fervor!). A whole slew of other factors are at-work, such as market access, technical barriers to trade and the effect on sales and marketing on the process. While intriguing, we are really not concerned with those (tangible and real issues) here, but are primarily interested in surveying some of the Certification programs that occupy parts of our visible spectrum.
Accreditation and Oversight
Accreditors are really the fourth party in the process. They are outside the transaction and the evaluation of the product and are quite removed from the consumer or user. In fact, the general public is usually unaware of the accreditation process until something goes awry and the finger-pointing starts.
Accreditation may be thick or thin, depending on the program and the oversight may have links up the chain to the ultimate authority—someone in the government. That means that, in a robust certification system, there are multiple links in the process that are in place to assure that the process is fair, evenly-administered, impartial and, above-all, serves the interest of the public.
A Survey of Certifications
Regulatory Certification Processes
The Federal Communications Commission mandates that intentional radiators (transmitters) are certified. The process is designed around the central mandate of the FCC, that is, to protect the users of the radio frequency spectrum. Manufacturers of devices that send signals into the aether must demonstrate that the signals stay in the right part of the spectrum and that they do not send too much energy at their assigned space. The rules limit frequency use and transmitted power. A device is tested, a report is prepared and the application submitted to the FCC or, in ~90% of the cases, a Telecommunications Certification Body. The application is reviewed for adherence to the Rules and, if found in compliance, a Grant is issued. This Grant states the Rule Part(s), the frequency or frequency range(s), the output power and any special conditions that may restrict its use. The results of the Certification are then published to the FCC web site, where much of the test data and application (less some confidential information) are available for viewing. This process is quite open and has, in the opinion of the author, been a significant contributor to the advancing of the state-of-the art of radio transmitter design and development. This Certification process does not address whether the device does what it is supposed to do. Rather, it is simply a process that seeks to minimize interference with other users of the spectrum (particularly those holding licenses to transmit—broadcasters, land mobile and cellular networks). A critical part of this Certification process is post-market surveillance or auditing, which is performed on a sample of the devices certified.
The Food and Drug Administration regulates, among other things, Medical Devices. From bandages to in vitro diagnostic devices, the mandate of the FDA is to protect the public from harmful products and, for medical devices and pharmaceuticals, that the products are efficacious, that is, they do what they are supposed to do. The process consists of assembling a document package that describes the device, its use and function and is known as premarket notification (not strictly “Certification”). For electronic devices, the device must conform to a set of emissions and immunity requirements based on IEC 60601-1, which sets a minimum standard for electromagnetic compatibility. The package is submitted (known as a 510(k) submission) for certain types of devices deemed critical by the FDA. Devices are classified according to the risk factors associated with the use into Class I, II or III. Class I devices are nearly all exempt from this process and certain Class II (special control) devices as well. Class III devices are high-risk devices (pacemakers, for example) that are all subject to the pre-market notification process. The complete package is reviewed by the FDA or an approved reviewer and if the submission passes the FDA’s litmus test, a letter is sent to the applicant that is the approval to market the device.
Industry Certification Processes
Product Safety Certification
While threads of government regulation reach into the Product Safety Certification process, in the United States the requirements for the safety of electrical devices is primarily driven by risk mitigation—that is—driven by the fear of guys in dark suits. Not Tony Soprano types, but the ones whose heels click down polished halls on K Street and other corridors of litigation. Major retailers usually require that electrical products sold through the distribution be certified or “listed” by a safety agency. In addition, the Occupational Health and Safety Agency has requirements for workplace safety that can be met by listing a device. The process involves submission of a product to a Nationally Recognized Test Laboratory for test and evaluation against a harmonized safety standard. Many of these are based on IEC standards and are incorporated under Underwriters Laboratories (UL) standards. Depending on the type of standard, the UL standard may also be approved by ANSI, making it a national standard. The products, once determined to be in compliance, is labeled and shipped.
It is noteworthy that Europe has an overarching requirement that states that devices be safe, but the process is through a self-declaration or Supplier’s Declaration of Conformity (DOC). Recent request by EU organizations are aimed at allowing the incorporation of sDOC into OSHA rules. The battle is on between the US-based product certifiers and the (maybe) more liberally-oriented sons and daughters of the namesake of the Jupiter’s sixth moon.
As with radio certification, a critical part of this Certification process is post-market surveillance; however, this is accomplished by factory visits to the manufacturers.
Private Label Certifications are usually reserved by large manufacturers to assure that suppliers and vendors meet certain requirements for use on their platforms or systems. For example, Microsoft has a so-called Windows® logo program that is used to evaluate third-party applications against the operation of the Windows® OS. The process involves a test and submission via an approved vendor. If the code passes the test case, then the device is eligible for the logo. This process is designed to make sure that code is compatible with the central OS and peripheral communications structures.
The other class of device certification is usually standards-based programs that are technology-specific, as opposed to the regulatory and consumer-protection based systems. These certifications, sometimes referred to as qualifications, have been developed over time by industry consortia who have a vested interest in the proliferation of the technology. The programs usually follow the same general model with a governing body that oversees approved testing laboratories. IEEE standards are a common basis for the requirements and many of the organizations that developed the standards form the core group of program supports. As these Certification involve interoperability across platforms, “plug-fests” (or, in the case of wireless devices “un-plug fests”) are often arranged that group developers together to test en mass many products together.
The following is a summary list of some of the more well-known groups that have developed product certification or qualification programs. (It is noted that there are numerous other types of organizations that have developed and field acceptance programs. The interesting aspect is the proliferation of and specialization of these groups as technology advances.)
- Bluetooth Special Interest Group
- Universal Serial Bus Implementers Forum, Inc.
- Zigbee Alliance
- WiFi Alliance
- WiMax Forum
- OmniAir Consortium
- Green Electronics Council (Electronic Product Environmental Assessment Tool (EPEAT))
- Cellular Telecommunications Industry Association
- Ethernet Alliance
(Several of these groups held forth at a recent conference at IEEE Headquarters in bucolic Piscataway New Jersey, hosted by the IEEE Standards and Technology Organization and organized by the IEEE Conformity Assessment Program.)
The growth in the electronics sector over the last 30 years has been paralleled by the growth of Certification programs developed to verify conformance with requirements. These programs are either based on consumer protection or on furthering the development of a particular technology. From the perspective of the general public, the comfort offered by having a certified device ultimately lies in the veracity and, in many cases, enforcement of the certification requirements, from product approval throughout the service life of the device. Enforcement, I daresay, is a tar baby that we’ll leave on the side of the road for the time being.
For the conformity assessment service market, the expansion of this industry has led to the development of diversified services to serve this expanding market (and opportunities to participate). The goal of the Certification programs, ultimately, is to assure that products are developed, and stay, in compliance.
Mike Violette is President of Washington Laboratories and Director of AmericanTCB. He has been mucking around in the compliance industry for the better part of three decades and writes and comments on technology, culture, travel and other amusements. He can be reached at firstname.lastname@example.org.