TALKING POINT on IBI
The new GPSR – Risk Analysis, Risk Mitigation and Document RetentionOn December 13, the new General Product Safety Regulation (GPSR) applies and repeals the old one. This is the right time for the (top) management to check whether the internal risk analysis processes for product safety are in place and are actually being implemented.
So, who is responsible for the technical product safety in your company?
One matter is if those persons are properly trained but another if they have the time to run in-depth analysis.It is also important that their analysis is not dismissed by a superior as that of a doubter.
Let us take folding side terrasses as an example – state-of-the-art on many powerboats and yachts today. The assessment of some risks is covered by applying the RCD and its harmonised standards, but not all risks.
Is the operating mechanism safe, taking into account the normal and foreseeable use of the product? How to prevent person from being injured and what about protection of “vulnerable persons” such as children?
Let’s assume the boat is anchored at a bay during calm conditions with lowered side terrasses. Now the weather is getting worse and the crew wants to turn back to the harbour. However, the electrical actuator to lift the terrace up is not working. Is there an alternative way to lift up the terrace in such an emerging situation?
These exemplary scenarios show that a risk analysis is very important. Naturally, appropriate measures must be taken based on the results of the analysis. Otherwise, the risk mitigation is inadequate.
Anyone who has ever been involved in a legal claim arising from a loss knows how much time, energy and money is involved in such a claim – usually much more than if the claim had been avoided through appropriate risk analysis and preventive measures beforehand.
Last but not least, good document retention is the key to protecting your company. In the more than 20 years that I have been involved in technical safety and assessment, I have seen many cases where the technical documentation can no longer be found even after a few years. The reason for this is often a change of employees, company takeovers or simply a lack of systematics.
Even if the day-to-day business challenges you with financial figures, sales, design matters etc., one should never neglect the risk assessment for product safety.