The sampling and surveillance procedure are most stringent

To                                                                                                                                                        Date : 16-10-24

The Director General

Bureau of Indian Standard

9, Bahadur Shah Zafar Marg, New Delhi-110002

Sub.: Product wise guidance on factory and market surveillance under scheme – I

Ref.: CMD-1/2:12:7 dated 10th April 2023

Sir,

On the above subject and reference to your circular as mentioned above we Haryana Plywood Mfr. Association beg to submit that:-

1. Plywood, Block Board, Marine Plywood, Shuttering Plywood and Flush Door fall under sl. no. 5, 17, 19, 20 and 49 of the above circular and each of the above products has been put for sampling 2 nos. from factory every year and 4 nos. from market every year.
2. If failure of sample is more than 50% in last 2 years then license is liable to be cancelled. These provisions are effective from 10th April 2023 but cancellation of license has been made applicable from 10th April 2021, that is retrospectively.
3. It is general principal of natural justice that no punishment can be awarded retrospectively. But the licenses, at regional level and zonal level, are cancelled two years preceding the date of notification of the above circular.
4. There are many cases where more than 50% failures are reported but corrective measures have already been taken and verified by the Bureau and special visit fees of Rs. 7000/-, lab testing charges of the independent test house have been paid by the license holder and the license has been regularized from ‘Stop Marking’ to operative. By application of the above circular retrospectively the whole exercise of corrective measures, special inspection, independent lab testing shall become in fructuous.
5. This is an anomaly and it is requested to review the applicability date of the cancellation provision.
6. It is also requested that plywood, doors and block board has been put under QCO w.e.f. 11th Feb. 2025. The sampling and surveillance procedure are most stringent. Very few units will survive these measures. It is therefore requested that no. of samples be reduced by 50% for initial 2 years of the QCO until the produces get settled and familiar with QCO compliance.

Yours faithfully

For Haryana Plywood Manufacturers Associations

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