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"Jesus Gonzalez"
<jgconsultants@charter.net> 10/24/2006 11:17 AM |
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This message has been replied to and forwarded.
Hi Joe,
Per our conversation last week, please see the letter attached. I
tried to detail what I see as the issue with the current
"Association" - "Member" model that some companies are using
to market their product without officially registering with either the state or
local authorities... I hope the details I provided are clear enough; however,
if you have any question feel free to contact me.
I am looking forward to hear the results of your investigation.
Sincerely,
Jesus Gonzalez
JG Business Consultants LLC
October 24,
2006
Jesus Gonzalez
JG Business Consultants LLC
Mr. Joe Bigelow
Department of Community Affairs
Building Codes and Standards
Dear, Mr. Bigelow,
I am writing to your office as
a follow up to the conversation we had on the telephone last Wednesday, October
17, 2006. Per your request, I detailing for you the subject of my enquire so
that you can present it to the Florida State Commision.
Here is some background info:
Under the Florida Product
Approval System implemented on October 1, 2003, every manufacturer of a product
that affects the structural integrity of buildings needs to receive a product
approval for its product, and to implement a quality assurance program to
guarantee that the product is being built as approved. The manufacturer then
can either get a local product approval or register with the State of
For companies looking to
register its product for a state wide product approval, the State of
A Quality Assurance Program is
based on international standards established under ISO 9000. So, every
manufacturer that implements a quality assurance program needs to meet these
requirements, at least at the basic level.
The requirements are:
- Identification of the organization building the approved product
-
Control of raw
material
-
Control of the
manufacturing process
-
Control of the product
being built (engineering design) to meet the approved requirements
-
Control of the
finished product
-
Control of packaging
and product conservation
Support:
-
Revision procedure for
the quality assurance program
-
Documentation of the
quality assurance records and documents and record keeping procedures
-
Procedures to
guarantee continuous improvement (- Corrective Actions, - Preventive Actions)
-
Procedure to control
changes of design
-
Procedure to control
Non Conforming Products
-
Procedures related to
the customer (Response to the Field Complaints, Customer Services and attention
to its requirements)
Issues:
Legal Issues (Violation of
the Quality Assurance Requirements and overall product approval system
1) Some companies have created
trade associations and have registered their approved product with the State of
To my understanding this
practice is illegal because the members do not have any accountabilities to the
approved products they build. Under the FL product approval system , a company
that holds a product approval can only built its products under its direct
supervision; so, by allowing other companies to build the same product using
the association product approval, and
outside the association direct supervision, the association could be
considered to be aiding and abiding another company to do an illegal practice,
and it is ultimatelly liable for the product built by its members.
2) A quality assurance program
requires each company to be accountable to its customers and to the government
regulations for the product they built. This requirement is also violated under
the current association – member model for the State of
Financial Issues:
Right now these same
associations, as well as its members, are required to register with
Request Actions:
I would like the commission to
do an investigation on these issues and to level the play field for all the
manufacturers by either mandating the registration of all the manufacturers
using a Florida Approved product or by striking down that requirement, which
would create an exodus of companies from under the
Please keep me informed on the
development of your investigation, and if you need any further information or
supporting evidences for your investigation, feel free to contact me.
Respectfully,
Jesus Gonzalez
JG Business Consultants LLC
Under