Five things most machine builders do incorrectly

Five things that most machine builders fail to do. With a Sixth Bonus fail­ure!

The Top Five errors I see machine builders make on a depress­ing­ly reg­u­lar basis:

1) Poor or Absent Risk Assessment

Risk assess­ments are fun­da­men­tal to safe machine design and lia­bil­i­ty lim­i­ta­tion, and are required by law in the EU. They are a includ­ed in all of the mod­ern North Amer­i­can machin­ery safe­ty stan­dards as well.

Machine builders fre­quent­ly have trou­ble with the risk assess­ment process, usu­al­ly because they fail to under­stand the process or because they fail to devote enough resources to get­ting it done.

If risk assess­ment is built into your design process, it becomes the norm for how you do busi­ness. Time and resources will auto­mat­i­cal­ly be devot­ed to the process, and since it’s part of how you do things it will become rel­a­tive­ly pain­less. Where peo­ple go wrong is in mak­ing it a ‘big deal’ one-time event. Also get­ting it done ear­ly in the design process and iter­at­ed as the design pro­gress­es means that you have time to react to the find­ings, and you can com­plete any nec­es­sary changes at more cost-effec­tive points in the design and build process. The worst time to do risk assess­ment is at the point where the machine is on the shop floor ready to start pro­duc­tion. Costs for mod­i­fi­ca­tion are then expo­nen­tial­ly high­er than dur­ing design and con­struc­tion.

Poor­ly done, risk assess­ments become a lia­bil­i­ty defense lawyer’s worst night­mare and a plaintiff’s lawyer’s dream. Short­chang­ing the risk assess­ment process ensures that you will lose, either now or lat­er.

Fight this prob­lem by: learn­ing how to con­duct a risk assess­ment, using qual­i­ty risk assess­ment soft­ware tools, and build­ing risk assess­ment into your stan­dard design process/practice in your orga­ni­za­tion.

2) Failure to be Aware of Regulations & Use Design Standards

This one is a mys­tery to me.

Every mar­ket has prod­uct safe­ty leg­is­la­tion, sup­port­ed by reg­u­la­tions. Grant­ed, the scope and qual­i­ty of these reg­u­la­tions varies wide­ly, but if you want to sell a prod­uct in a mar­ket, it doesn’t take a lot of effort to find out what reg­u­la­tions may apply.

Design stan­dards have been in exis­tence for a long time. Most pur­chase orders, at least for cus­tom machin­ery, con­tain lists of stan­dards that the equip­ment is required to meet at Fac­to­ry Accep­tance Test­ing (FAT).

Why machine builders fail to grasp that using these stan­dards can actu­al­ly give them a com­pet­i­tive edge, as well as help­ing them to meet reg­u­la­to­ry require­ments, I don’t know. If you do, please either com­ment on this sto­ry or send me an email. I’d love to hear your thoughts on this!

Fight this prob­lem by: Doing some research. Under­stand the mar­ket envi­ron­ment in which you sell your prod­ucts. If you aren’t sure how to do this, use a con­sul­tant to assist you. Buy the stan­dards, espe­cial­ly if your client calls them out in their spec­i­fi­ca­tions. Read and apply them to your designs.

One great resource for infor­ma­tion on reg­u­la­to­ry envi­ron­ments and stan­dards appli­ca­tions is the IEEE Prod­uct Safe­ty Engi­neer­ing Soci­ety and the EMC-PSTC List­serv that they main­tain.

3) Fixed Guard Design

Fixed guard­ing design is dri­ven by at least two fac­tors, a) pre­vent­ing peo­ple from access­ing haz­ards, and b) allow­ing raw mate­ri­als and prod­ucts into and out of the machin­ery.

Design­ers fre­quent­ly go wrong by select­ing a fixed guard where a mov­able guard is nec­es­sary to per­mit fre­quent access (say more than once per shift). This is some­times done in an effort to avoid hav­ing to add inter­locks to the con­trol sys­tems. Fre­quent­ly the guard will be removed and replaced a cou­ple of times, and then the screws will be left off, and even­tu­al­ly the guard itself will be left off, leav­ing the user with an unguard­ed haz­ard.

The oth­er com­mon fault with fixed guards relates to the sec­ond fac­tor I men­tioned — get­ting raw mate­ri­als and prod­ucts in an out of the machine. There are lim­its on the size of open­ings that can be left in guards, depen­dent on the dis­tance from the open­ing to the haz­ards behind the guard and the size of the open­ing itself. Often the only fac­tor con­sid­ered is the size of the item that needs to enter or exit the machin­ery.

Both of these faults often occur because the guard­ing is not designed, but is allowed to hap­pen dur­ing machine build. The size and shape of the guards is then often dri­ven by con­ve­nience in fab­ri­ca­tion rather than by thought­ful design and appli­ca­tion of the min­i­mum code require­ments.

Fight this prob­lem by: Design­ing the guards on your prod­uct rather than allow­ing them to hap­pen, based on the out­come of the risk assess­ment and the lim­its defined in the stan­dards. Tables for guard open­ings and safe­ty dis­tances are avail­able in North Amer­i­can, EU and Inter­na­tion­al stan­dards.

4) Movable Guard Interlocking

Mov­able guards them­selves are usu­al­ly rea­son­ably well done. Note that I am not talk­ing about self adjust­ing guards like those found on a table saw for instance. I am talk­ing about guard doors, gates, and cov­ers.

The prob­lem usu­al­ly comes with the design of the inter­lock that is required to go with the mov­able guard. The first part of the prob­lem goes back to my #1 mis­take: Risk Assess­ment. No risk assess­ment means that you can­not rea­son­ably hope to get the reli­a­bil­i­ty require­ments right for the inter­lock­ing sys­tem. Next, there are small but sig­nif­i­cant dif­fer­ences in how the Cana­di­an, US, EU and Inter­na­tion­al stan­dards han­dle con­trol reli­a­bil­i­ty, and the biggest dif­fer­ences occur in the high­er reli­a­bil­i­ty clas­si­fi­ca­tions.

In the USA, the stan­dards speak of con­trol reli­able cir­cuits (see ANSI RIA R15.06–1999, 4.5.5). This require­ment is writ­ten in such a way that a sin­gle inter­lock­ing device, installed with dual chan­nel elec­tri­cal cir­cuits and suit­ably select­ed com­po­nents will meet the require­ments. No sin­gle ELECTRICAL com­po­nent fail­ure will lead to the loss of the safe­ty func­tion, but a sin­gle mechan­i­cal fault could.

In Cana­da, the machin­ery and robot­ics stan­dards speak of con­trol reli­able sys­tems (see CSA Z432, 8.2.5), not cir­cuits as in the US stan­dards. This require­ment is writ­ten in such a way that TWO electro­mechan­i­cal inter­lock­ing devices are required, one in each elec­tri­cal chan­nel of the inter­lock­ing sys­tem. This per­mits the sys­tem to detect mechan­i­cal fail­ures such as bro­ken or miss­ing keys, and if dif­fer­ent types of inter­lock­ing devices are cho­sen, may also per­mit detec­tion of efforts to bypass the inter­lock. Most sin­gle mechan­i­cal faults and elec­tri­cal faults will be detect­ed.

In the EU and Inter­na­tion­al­ly, con­trol reli­a­bil­i­ty is much more high­ly devel­oped. Here, the appli­ca­tion of ISO 13849, IEC 62061 or IEC 61508 have tak­en con­trol reli­a­bil­i­ty to high­er lev­els than any­thing seen to date in North Amer­i­ca. Under these stan­dards, the required Per­for­mance Lev­el (PLr) or Safe­ty Integri­ty Lev­el (SIL) must be known. This is based on the out­come of, you guessed it, the Risk Assess­ment. No risk assess­ment, or a poor risk assess­ment, dooms the design­er to like­ly fail­ure. Sig­nif­i­cant skill is required to han­dle the analy­sis and design of safe­ty relat­ed parts of con­trol sys­tems under these stan­dards.

Fight this prob­lem by: Get­ting the train­ing you need to prop­er­ly apply these stan­dards and then using them in your designs.

5) Safety Distances

Safe­ty dis­tances crop up any­where you don’t have a phys­i­cal bar­ri­er keep­ing the user away from the haz­ard. Whether its an open­ing in a fixed guard, a mov­able guard like a guard door or gate, or a pres­ence-sens­ing safe­guard­ing device like a light cur­tain, safe­ty dis­tances have to be con­sid­ered in the machine design. The eas­i­er it is for the user to come in con­tact with the haz­ard, the more safe­ty dis­tance mat­ters.

Stop­ping per­for­mance of the machin­ery must be test­ed to val­i­date the safe­ty dis­tances used. Fail­ure to get the safe­ty dis­tance right means that your guards will give your users a false sense of secu­ri­ty, and will expose them to injury. This will also expose your com­pa­ny to sig­nif­i­cant lia­bil­i­ty when some­one gets hurt, because they will. Its only a mat­ter of time.

Fight this prob­lem by: Test­ing safe­guard­ing devices.

6) Validation

OK, so this list should real­ly be SIX things. Just con­sid­er this to be a bonus for read­ing this far!

Designs, and par­tic­u­lar­ly safe­ty crit­i­cal designs, must be test­ed. Let me say it again:

Safe­ty Crit­i­cal Designs MUST Be Test­ed.

What­ev­er the­o­ry you are work­ing under, whether it’s North Amer­i­can, Euro­pean, Inter­na­tion­al or some­thing else, you can­not afford miss­ing the val­i­da­tion step. With­out val­i­da­tion you have no evi­dence that your sys­tem worked at all, let alone if it worked cor­rect­ly.

Fight this prob­lem by: TESTING YOUR DESIGNS.

A wise man once said: “If you think safe­ty is expen­sive, try hav­ing an acci­dent.” The gen­tle­man was involved in inves­ti­gat­ing the crash of a Siko­rsky S-92 heli­copter off the coast of New­found­land. 17 peo­ple died as a result of the fail­ure of two tita­ni­um studs that held an oil fil­ter onto the main gear­box, and the fact that the heli­copter failed the ‘1/2-hour gear­box run-dry test’ that is required for all new heli­copter designs. This was a clear case of fail­ure in the risk assess­ment process com­pli­cat­ed by fail­ure in the test process.

ESA Manufacturer’s Registration Deadline postponed

This entry is part 1 of 1 in the series Ontario ESA Man­u­fac­tur­ers Reg­istry

If you’ve been fol­low­ing the dis­cus­sions on the EMC/PSTC list serv­er and else­where about the ESA Manufacturer’s reg­istry in Ontario, you may not be aware that ESA has dropped the August 30 dead­line for reg­is­tra­tion. It seems that the Ontario Gov­ern­ment and ESA are review­ing the dead­line fol­low­ing a cab­i­net shake-up at Queen’s Park. There is no word on when or if the dead­line will be rein­stat­ed. Need to know

If you’ve been fol­low­ing the dis­cus­sions on the EMC/PSTC list serv­er and else­where about the ESA Manufacturer’s reg­istry in Ontario, you may not be aware that ESA has dropped the August 30 dead­line for reg­is­tra­tion. It seems that the Ontario Gov­ern­ment and ESA are review­ing the dead­line fol­low­ing a cab­i­net shake-up at Queen’s Park. There is no word on when or if the dead­line will be rein­stat­ed. Need to know more? Come to the PSES Sym­po­sium and be there for ESA’s pre­sen­ta­tion on the Reg­istry!

ESA Manufacturer Registration in Ontario, Canada

Do you make elec­tri­cal prod­ucts sold in Ontario, Cana­da? Are you aware of the need to reg­is­ter your com­pa­ny with the Elec­tri­cal Safe­ty Author­i­ty (ESA) in order to sell your prod­ucts legal­ly? If not, spend some time and catch up on the new ESA Manufacturer’s Reg­istry!

Electrical Safety Authority LogoThis sto­ry updat­ed 4-Feb-2014 and 11-Jun-18.

Update on this story


Since this sto­ry was orig­i­nal­ly writ­ten in March of 2009, all men­tion of the Manufacturer’s Reg­istry has dis­ap­peared from the ESA web­site. When I have tried to con­tact peo­ple involved in the orig­i­nal roll­out of the Reg­istry, they do not respond. I have asked for the oppor­tu­ni­ty to inter­view one per­son in par­tic­u­lar and had yet to receive any kind of reply.

It would seem that this pro­gram has been allowed to qui­et­ly die, how­ev­er, the leg­is­la­tion that per­mit­ted it to be cre­at­ed in the first place remains unchanged. Depend­ing on the mood of those in charge, it could the­o­ret­i­cal­ly be brought back to life again.

Since Feb­ru­ary 17th, 2009, there has been an inter­est­ing dis­cus­sion thread on the PSES’s EMC-PSTC list on the new Manufacturer’s Reg­istry in the Province of Ontario, Cana­da. Since there was so much inter­est, I decid­ed to try to sum­ma­rize things here.


Ontario is the sec­ond old­est and the most pop­u­lous Province in Cana­da, with 14,193,384 peo­ple as of 1-Jul-2017. Cana­da has 10 Provinces and three Ter­ri­to­ries. Ontario, along with Québec, form Canada’s man­u­fac­tur­ing heart­land. Due to Ontario’s pop­u­la­tion and con­tri­bu­tion to Canada’s GDP, the Province is often a leader in new leg­is­la­tion.

The ESA, or the Elec­tri­cal Safe­ty Author­i­ty as they are more prop­er­ly known, is the Author­i­ty Hav­ing Juris­dic­tion (AHJ) in the Province of Ontario, Cana­da. This means that they are autho­rized by the Gov­ern­ment of Ontario to reg­u­late elec­tri­cal safe­ty in the Province. ESA was for­mer­ly the inspec­tion arm of Ontario Hydro, a crown cor­po­ra­tion dis­solved in 1998. ESA pro­vides build­ing and equip­ment elec­tri­cal inspec­tion ser­vices to the pub­lic and indus­try in the Province and pub­lish­es the Ontario Elec­tri­cal Code. The Code is adapt­ed direct­ly from CSA’s Cana­di­an Elec­tri­cal Code — Part 1 (CSA C22.1), with Provin­cial devi­a­tions.

On 1-Aug-07, the Min­istry of Small Busi­ness and Con­sumer Ser­vices filed Ontario Reg­u­la­tion 438/07, Prod­uct Safe­ty. This new reg­u­la­tion enables the Elec­tri­cal Safe­ty Author­i­ty to reg­u­late the safe­ty of elec­tri­cal prod­ucts and equip­ment sold and used in Ontario.

The reg­u­la­tion was phased in to ensure that ESA and stake­hold­ers had enough time to devel­op tech­ni­cal guid­ance to sup­port the reg­u­la­tion.

  • On 1-Oct-07 the sec­tions of the reg­u­la­tion that gov­ern approval of elec­tri­cal prod­ucts (cur­rent­ly con­tained in the Ontario Elec­tri­cal Safe­ty Code) and that allow notice be giv­en to the pub­lic of unsafe elec­tri­cal prod­ucts came into effect.
  • On 1-Jan-08 oth­er sec­tions relat­ing to ESA’s inves­tiga­tive and order-mak­ing pow­ers came into effect.
  • On 1-Jul-08 sec­tions of the reg­u­la­tion requir­ing organ­i­sa­tions to report seri­ous elec­tri­cal inci­dents or defects came into effect.
  • On 1-Apr-09 the Reg­istry will open, and man­u­fac­tur­ers can begin to reg­is­ter with ESA. For man­u­fac­tur­ers cur­rent­ly sell­ing prod­ucts in Ontario, reg­is­tra­tions must be com­plet­ed by 30-Aug-09. If your com­pa­ny wants to begin sell­ing prod­ucts in Ontario, the com­pa­ny must reg­is­ter before prod­ucts can be sold. This require­ment has been post­poned. For more infor­ma­tion, see this arti­cle.

What is the Reg­istry?

Recent Changes in the Ontario Elec­tric­i­ty Act have increased the require­ments for report­ing of “seri­ous inci­dents” with elec­tri­cal ori­gins. These require­ments are found in Ontario Reg­u­la­tion 438 on Prod­uct Safe­ty. In the past, sig­nif­i­cant num­bers of injuries caused by either unap­proved equip­ment, or fraud­u­lent­ly marked equip­ment have occurred. When ESA has inves­ti­gat­ed the equip­ment, they run into prob­lems with find­ing the orig­i­na­tor of the gear, and there­fore the per­son or com­pa­ny who bears respon­si­bil­i­ty for the prob­lem. The new addi­tions to the reg­u­la­tion address this by requir­ing report­ing of severe injuries caused by elec­tri­cal equip­ment. In order to improve trace­abil­i­ty of elec­tri­cal prod­ucts sold in Ontario, ESA intro­duced the Manufacturer’s Reg­istry and made it manda­to­ry under their author­i­ty as the AHJ in Ontario. See the Ontario Reg­u­la­tion. Reg­is­tra­tion begins 1-Apr-09. Reg­is­tra­tion must be com­plet­ed by 30-Aug-09. The manda­to­ry Reg­is­tra­tion dead­line has been indef­i­nite­ly post­poned. A fee of CA$350 must be paid in the first year, with a reduced fee in each fol­low­ing year.

Man­u­fac­tur­ers of elec­tri­cal equip­ment for sale in Ontario are required to reg­is­ter with ESA, regard­less of whether they are locat­ed in Ontario or else­where. Fail­ure to reg­is­ter will mean that cer­ti­fied or labelled elec­tri­cal prod­ucts will be deemed to be unap­proved and non-com­pli­ant with the Ontario Elec­tri­cal Code. Under Reg­u­la­tion 438, it is ille­gal to sell, dis­play or use unap­proved elec­tri­cal prod­ucts [Sec­tion 5]. Under the Indus­tri­al Estab­lish­ments reg­u­la­tions (part of the Ontario Occu­pa­tion­al Health and Safe­ty Act), it is ille­gal to use unap­proved elec­tri­cal prod­ucts in the work­place [Sec­tion 40]. Sim­i­lar require­ments are also found in the Con­struc­tion Reg­u­la­tions (Ontario Reg­u­la­tion 213, Sec­tion 185).

More infor­ma­tion on the Reg­istry can be found on the ESA web­site in the Prod­uct Safe­ty area. There are some FAQ’s avail­able from this page as well. They include:

*If the links fail to work, please see the down­load links at the end of this arti­cle.

The reg­is­tra­tion is per man­u­fac­tur­er and NOT per prod­uct, so once you have reg­is­tered your com­pa­ny you do not need to re-reg­is­ter for every prod­uct.

Rec­og­nized elec­tri­cal safe­ty marks

ESA pro­vides a list of all of the Cer­ti­fi­ca­tion and Inspec­tion marks that are rec­og­nized in the province. As long as your prod­uct or the prod­ucts you are sell­ing bear one of these marks, the prod­uct can be dis­played, sold or used in the Province, pre­sum­ing the man­u­fac­tur­er is reg­is­tered.

View the list of Rec­og­nized Marks and Field Eval­u­a­tion Labels.

What is a ‘seri­ous inci­dent’?

Reg­u­la­tion 438 defines a seri­ous inci­dent in Sec­tion 1:

seri­ous elec­tri­cal inci­dent or acci­dent” means an elec­tri­cal inci­dent or acci­dent that,

(a) results in death or seri­ous injury to a per­son,

(b) has the poten­tial to cause death or a risk of seri­ous injury to a per­son, or

© caus­es or has the poten­tial to cause sub­stan­tial prop­er­ty dam­age.

Report­ing Require­ments

Once your com­pa­ny has reg­is­tered with ESA, any seri­ous inci­dents occur­ring any­where you mar­ket your prod­ucts becomes reportable, but only for prod­ucts sold in Ontario.

Quot­ing from Reg­u­la­tion 438:

8. (1)  A man­u­fac­tur­er, whole­saler, importer, prod­uct dis­trib­u­tor or retail­er that becomes aware of a seri­ous elec­tri­cal inci­dent or acci­dent or a defect in the design, con­struc­tion or func­tion­ing of an elec­tri­cal prod­uct or device that affects or is like­ly to affect the safe­ty of any per­son or cause dam­age to prop­er­ty, shall report to the Author­i­ty as soon as prac­ti­ca­ble after becom­ing aware of the seri­ous elec­tri­cal inci­dent or acci­dent or defect.

(2)  A cer­ti­fi­ca­tion body or field eval­u­a­tion agency that becomes aware of a seri­ous elec­tri­cal inci­dent or acci­dent or a defect in the design, con­struc­tion or func­tion­ing of an elec­tri­cal prod­uct or device that was the sub­ject of a report giv­en by the cer­ti­fi­ca­tion body or field eval­u­a­tion agency that affects or is like­ly to affect the safe­ty of any per­son or cause dam­age to prop­er­ty shall report to the Author­i­ty as soon as prac­ti­ca­ble after becom­ing aware of the seri­ous elec­tri­cal inci­dent or acci­dent or defect.

There is more to Sec­tion 8 of the reg­u­la­tion than quot­ed. Addi­tion­al sub­sec­tions include infor­ma­tion on what needs to be in the report and who needs to be involved in the inves­ti­ga­tion. If you need to make a report, check the rest of Sec­tion 8 first.

For exam­ple, say that your com­pa­ny man­u­fac­tures a wid­get, Mod­el 1523. Mod­el 1523 is sold in the USA, Ontario Cana­da, Mex­i­co and India. The com­pa­ny also man­u­fac­tures a dif­fer­ent wid­get, Mod­el 2000, sold in the USA and Mex­i­co.

At some point, reports of elec­tri­cal shock and fires caused by Mod­el 2000 start to come into your Prod­uct Safe­ty depart­ment. Do you need to report this to ESA? NO — Mod­el 2000 is not sold in Ontario, so severe inci­dents caused by that mod­el do not require report­ing to ESA.

Mod­el 1523 has a clean record, so no report­ing is required there. After man­u­fac­tur­ing Mod­el 1523 for a few years, a key com­po­nent is changed for a cost reduced ver­sion from a dif­fer­ent sup­pli­er. Six months after the change, reports come in from Mex­i­co and India that users have been killed by elec­tric shock received from units of Mod­el 1523. After inves­ti­gat­ing the reports, your Prod­uct Safe­ty depart­ment deter­mines that the faulty units used the new com­po­nent. Do you need to report this to ESA? YES — because Mod­el 1523 is sold in Ontario.

Here’s anoth­er exam­ple. Your com­pa­ny imports elec­tri­cal prod­ucts from a num­ber of coun­tries and sells them whole­sale to large retail­ers, some of whom have stores in Ontario. Do you need to reg­is­ter? NO — But you can­not legal­ly sell prod­ucts from man­u­fac­tur­ers who are not reg­is­tered in Ontario.

What if the prod­ucts are import­ed into Ontario but are not sold to users in the Province, and are only ware­housed and whole­saled to retail­ers or oth­er dis­trib­u­tors out­side of Ontario? Do you need to reg­is­ter? NO — But you must com­ply with the require­ments in the oth­er juris­dic­tions where the prod­uct is sold. Check with the AHJ in each Province or Ter­ri­to­ry where your prod­ucts are sold to deter­mine the require­ments.

What if I become aware of seri­ous inci­dents that are occur­ring with prod­ucts I sell in Ontario? You MUST report them to ESA, whether you make the prod­uct, import, dis­trib­ute or retail it.

What Prod­ucts are Cov­ered by the Reg­u­la­tions?

  • Con­sumer elec­tri­cal prod­ucts;
  • Com­mer­cial elec­tri­cal prod­ucts;
  • Elec­tri­cal Med­ical Devices;
  • Indus­tri­al elec­tri­cal prod­ucts;
  • Wiring devices and prod­ucts;
  • Bat­tery-oper­at­ed devices used in Haz­ardous Loca­tions;
  • Bat­tery charg­ers used with bat­tery oper­at­ed prod­ucts;
  • Hard­wired and plug-in life safe­ty prod­ucts like Smoke Detec­tors and CO Detec­tors;
  • Cer­ti­fied com­po­nents used in any of the above.

Will this become a Cana­di­an Nation­al Sys­tem?

This is not yet known. There are dis­cus­sions going on with the oth­er Provinces and Ter­ri­to­ries, how­ev­er, these are very pre­lim­i­nary stages. ESA has stat­ed that they are sup­port­ive of a Nation­al Pro­gram should it be devel­oped, but at this time these require­ments exist only in Ontario.

Tax Grab?

Some peo­ple have expressed the opin­ion that this is sim­ply a way to mask a new tax, since reg­is­tra­tion fees are payable on an annu­al basis. In fact, a means is required to fund the reg­istry, and the fees col­lect­ed are to be used for that pur­pose. See the Fund­ing Mod­el Report. Since ESA’s man­date is to pro­tect the peo­ple of Ontario from elec­tri­cal haz­ards, and since there are increas­ing num­bers of seri­ous inci­dents occur­ring where the prod­ucts turn out to be unap­proved or fraud­u­lent­ly marked, this is a rea­son­able way for the Author­i­ty to gain con­trol over the prod­ucts enter­ing the mar­ket­place, and to hold every­one in the sup­ply chain respon­si­ble for ensur­ing that only approved prod­ucts are sold in the Province.

Since there is no new mark­ing require­ment, and since rep­utable man­u­fac­tur­ers are already cer­ti­fy­ing or label­ing their prod­ucts for sale, and fur­ther­more since the reg­is­tra­tion fee is quite small for any orga­ni­za­tion sell­ing any quan­ti­ty of prod­uct in the Province, this is not an oner­ous require­ment. You are still free to have any SCC accred­it­ed body whose mark is recog­nised in Ontario do the cer­ti­fi­ca­tion work.

Will it work?

Will the Reg­istry actu­al­ly reduce the inci­dence of fraud­u­lent­ly marked or unmarked prod­ucts on store shelves, there­by improv­ing elec­tri­cal safe­ty in the Province? This is the big unknown. Cana­di­ans are known for cre­at­ing reg­istries in response to a per­ceived need to con­trol some­thing. Notable fail­ures include the Nation­al Do Not Call reg­istry was sup­posed to allow Cana­di­ans to reg­is­ter their phone num­bers with the gov­ern­ment, who was then requir­ing Cana­di­an based tele­mar­keters to scrub those num­bers from their call­ing data­bas­es. Unfor­tu­nate­ly, this only pro­vid­ed num­bers to off-shore tele­mar­keters who are using the DNC Reg­istry lists as a way to get num­bers to call.

It’s unfair to group this reg­istry with the pre­vi­ous exam­ple for a num­ber of rea­sons. The imple­men­ta­tion of this reg­istry is dif­fer­ent from the pre­vi­ous exam­ple in intent and exe­cu­tion. Com­pli­ance is mon­i­tored by the entire sup­ply chain. It prob­a­bly stands a pret­ty good chance of work­ing. Time will tell!