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Old 19th March 1999, 09:59 AM
John C

Total Posts: n/a
You now agree that Preventive action “can” include detection. Well in 4.14.3 it says that it “shall”, which is totally different from “can”. If we were allowed to replace “shall” with “can”, wherever it occurs in the Standard, then the document would be worthless. We can’t go around making up our own “interpretations”. Even more important, we can’t go round saying that the standard says things that it clearly does not and calling it ‘interpretation’.
Interpretations are not in the interests of industry. They are the tools of self interest.
They are also a nonsense. They cannot clarify the message, only confuse it. If, as you say, there are several interpretations for this section, then there will soon be hundreds. But I don’t believe there are any. The words are simple. They mean what they say and are available, officially translated, into most people’s native language. Instead of continually going on about the need for interpretation, I would like someone to show me one case from 4.14.3 where there is any ambiguity. I doubt I’ll hear from anyone with an example. It’s only about 60 words. Try it.
I hope I don’t hear from anyone with ideas about how the clauses are met. For example; deciding what is ‘appropriate’, is not interpretation. There are many opinions as to what is appropriate, but only one meaning for the adjective ‘appropriate’.
Our first responsibility is to give engineers and managers good information, from which base they can go ahead and design their process. If we give them bad information and muddy the water for them, then we do them a disservice and take their money for doing so.
If we tell them there are three interpretations of a clause, then we leave them vulnerable to the next chancer who comes along with a fourth one.
If we tell them, there are lots of chancers out there who would like to use various interpretations as leverage for their own ends, and that they should read the standard and stick to what they see, then we have done them a service and not left them in the dark.
I’m on the side of industry. I support free trade.

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