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Continuing Compliance Management

Since the arrival of the European Unions R&TTE Directive, and the subsequent easing of telecommunications regulations, the Maintenance of Compliance has now become a leading issue for Telecommunications Manufacturers.

  • R&TTE Surveillance Authorities have been successful in removing non-compliant Radio and Telecommunications Terminal Equipment from the entire European Union Market

  • Several of our clients have been audited for compliance of their Regulatory Compliance Folder

  • It is therefore possible that any manufacturer of Radio and/or Telecommunications Terminal Equipment could be audited by any of the 18+ different European Union Surveillance Authorities 

To alleviate the potential problems of a non compliant Surveillance Audit by any of the 18+ Surveillance Authorities, Patton & Associates are now offering Continuing Compliance Management services

Background

The R&TTE Directive mandates that equipment shall continue to comply with the Essential Requirements against which compliance was originally declared. 

Surveillance Authorities in each Member State of the European Union police the market place pro-actively to ensure that equipment placed on the market meets these Essential Requirements; they will also react to complaints made by customers and network operators concerning equipment which is suspected of non compliance.

Further, the network operators are bound by national laws and by the terms of their operating licenses to ensure that equipment which operates over their network-cabling infrastructure shall not cause harm or interference. All network operators are obliged to disconnect harmful equipment from their network and to inform Surveillance Authorities of any the suspected equipment.

Surveillance Authorities can and have demanded that non-compliant equipment be removed from the market place throughout the entire European Union. Additional penalties for non-compliance can be draconian, restrictive and prohibitively expensive for a manufacturer wanting to market R&TTE equipment in the European Union.

Patton & Associates know of a number of manufacturers who have been called to account for non-compliance and have been required to withdraw equipment from the market place, ship all non compliant product out of the European Union and back to its point of manufacture.

Regardless of whether equipment is defined as terminal equipment or as part of the network infrastructure, it is likely that at some time in the future it will be audited by one of the Surveillance Authorities to ensure compliance with the regulations.

Continuing Compliance Management Services

Patton & Associates Continuing Compliance Management Services include, but are not limited to,  the following:

  • Review the Manufacturers existing Compliance Folder [1]

  • Review Manufacturing ECO's and check if these raise Continuing Compliance issues

  • Review Manufacturing Quality System documentation and procedures

  • Management of all Continuing Compliance queries and correspondence with European Union Surveillance Authorities 

  • Management of  all claims, investigations and litigation associated with audit of Compliance Folders and compliance documentation by the European Union Surveillance Authorities


[1] The first "port of call" by a surveillance authority will be scrutiny of the Compliance Folder. It is imperative that the Compliance Folder, and hence product compliance, is kept up to date


A copy of The R&TTE directive may be downloaded at: http://www.patton-assoc.com/

History of Legislation. The legislation that has affected R&TTE emerged from different sciences and disciplines. The EC-wide Low Voltage Directive 73/23/EEC (1973) covered safety of all ITE. This Directive was eventually designated by all Member States to cover nationally approved TTE as well as EC-wide approved apparatus. Similarly, the EMC Directive 89/336/EEC replaced national legislation to cover all ITE and TTE. The TTE Directive 91/263/EEC (later to become 98/13/EC) used to cover approval of technically harmonized TTE before the advent of the R&TTE Directive.

The full title of the R&TTE Directive is: Directive 1995/5/EC of the European Parliament and Council of 9th March 1999 on Radio Equipment and Telecommunications Terminal Equipment and the mutual recognition of their conformity.


Author biography John Roche is Managing Director of Patton & Associates (UK) the European office of Patton & Associates Inc. of Prescott Arizona. Patton & Associates provide Telecommunications Consulting, Design and Type Approval services for Europe, North America and The Pacific Rim.

John Roche can be reached at: roche@patton-assoc.com

Telecommunications Regulatory Compliance
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Last updated: February 25, 2010
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