So for product safety, we would ID safety items from inputs such as customer drawings,
DFMEA review and perhaps an annual statutory & regulatory review. We would look to review this information during design & development planning to identify applicable safety characteristics, cascade this down to our supply base, ensure they confirm products they supply meet requirements (likely during PPAP process to us), maintain this documented information as evidence of conformity. We would then request annual submissions for flammability for instance as ongoing conformity.
Would this necessarily require the update of all older legacy control plans and
FMEA we have internally to be updated for either special characteristic ID (if missing) and/or continuing conformance (annual activity). Our plan is to implement this on new programs moving forward and any high volume/impact products we currently have, but do not intend to do all 300ish active sets of documents.
Is this the similar path others have taken when dealing with regulatory and statutory items along with annual ongoing compliance submission 8.4.2.2 & 8.4.2.5?
Would you also consider flash on a vehicle exterior molded part as a safety characteristic? Part is chrome plated, so could be sharp metal edge. It could possibly (provided it's out of specification) cause cuts to end users hands during installation perhaps. Would this be severe enough to warrant it being identified as a safety characteristic.
How have others approached the training portion of this clause?
Thanks for your discussion.
Aaron