Hello all
Good to see that the discussion is rising so many issues and is somehow
sharing light on issues on interpretation. I just finish doing some support
work with industry here in the Philippines (as part of the industry
component on an Asia Trust Fund project).
Philippines is getting ready for an FVO visit, hence everyone is getting to
grips with the details of the EU regulations.
Alma, who initially wrote the mail that generated all this discussion, was
one of the participants on our training sessions, which emphasised the fact
that when the regulations says ³black² then is black, and when it says
³white² then is white... but that in many cases is open to interpretations
and in that case you can argue the point with the inspector.
However, that argument has to be based on valid information that can sustain
your position, and that information can come from various resources beside
bibliography... such as this mailing group... I was very proud when I saw
Alma¹s mail with her concerns... and even more proud when I see the level
and deepness of the answers...
The relation in between regulatory verifications and industry should not be
a ³command and control² one or a ³police and thieves² one, that was part of
the key message during training... should more like ³business partners²,
where compliance is industry responsibility and the competent authority¹s
job is to be and ³official witness² of that compliance...
To pass an inspection you need to know the rules at least as good as the
inspector or better... and that the interpretation discussion is not an
³affront² to the regulator, but rather an opportunity to increase knowledge
in an area that affects both parts. Because at the end of the day, the
competent authority would be evaluated by the EU FVO, in the way they
evaluate industry compliance.
Based on scenario, I just was to thank the highly regarded opinions
expressed in this discussion, because the service they provide as support
and ³eye openers² for people in the industry and CA worldwide... Besides the
work of donor agencies, development groups and industry associations.
I¹m sure the ³decision tree² (a undervalued tool?) and the information
provided by this mails would help Alma to take the right decision and argue
it with a solid position.
Thanks Again
Francisco Blaha
This archive was generated by hypermail 2b29 : Wed Oct 12 2005 - 09:21:17 PDT