Greetings, RE: Applicability of Section 8 to internal R&D and self directed & funded Product Development? We are in the throws of a recertification audit and the topic of 'Product Development' came up. The auditor observed that we do not have the necessary (per section 8) evidence related to product development. We do have a robust process for the products that we delivery to our customers that are engineered to their specific requirements (Application Engineering). The auditor has no negative comment about that (yet...). Am I off my rocker to contend that Section 8 is N/A to self funded R&D and Product Development for the following - 1. The effort(s) is/are entirely self directed and funded 2. Section 184.108.40.206 states - "..shall conduct a review before committing to supply products and services to a customer.." 2.1 - If we are at a low TRL, there is no commitment to provide; and therefore everything after this is N/A I do understand that at some point it all applies, maybe when we contract a third party test facility for testing (as is customary in this industry). Can i play in my sandbox until then?