The numbered Whereas clauses are NOT part of the directive. The actual text of the directive starts after the stipulation
HAVE ADOPTED THIS DIRECTIVE: , just after consideration clause number (75) and just before article 1: The text before this phrase therefore cannot be part of it, including clause 7. . Gert Gremmen Van: John Woodgate [mailto:jmw1...@btinternet.com] Verzonden: vrijdag 4 augustus 2017 13:00 Aan: EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Re: [PSES] RED DoC and LVD You have my sympathy regarding the problems with language, worth 0.001 Euro. Be thankful that neither mediaeval French or Latin expressions are used. Yes, you need 1 firm, so that the bean counters can calculate the average weight per firm, and 0/0 causes their computers to crash. With best wishes DESIGN IT IN! OOO – Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Piotr Galka [mailto:piotr.ga...@micromade.pl] Sent: 04 August 2017 11:43 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RED DoC and LVD John, If I knew that I would start my discussion not from 1.4 and 3.1(a) but from (7), 1.4 and 3.1(a) what gives more relations to consider :) I am reading directives since 2004 when we joined EU. Till now I always assumed that everything before Article 1 is not important. Specially I remember in WEEE I think (may be in RoHS) that some point before Art 1 said that it is very important to not load too much small firms which was in total opposition with the rest of directive. For example we had a control and they found a cap with compressed air. We use about one per year but since then 4 times a year we have to send a report in which from time to time we report 1 such cap. Till now, as I know, we don't need to report these four sheets of paper used for it :) Our products (access control system) are intended to be installed and work for years. So after 2006 when we had to count how many kg of our products we got back as used-on for many years we had 0kg/year. We had to have signed agreement with recycling firm with recycling capabilities enough for recycling what we got back. My understanding was that to recycle 0 kg I need 0 firms. Now (after control) we know that to recycle 0kg you need 1 recycling firm :( Regards Piotr W dniu 2017-08-03 o 20:37, John Woodgate pisze: That’s not quite right. In the same way that English has 3 words for everything, it has a minimum of 3 meanings for any word. Some have hundreds (‘set’ and ‘bar’). ‘Whereas’ can simply mean ‘but’. However, in Directives, it has a legal meaning, which is rather stronger that your translated circumlocution. I suppose a short equivalent would be ‘Taking full account of these relevant issues, …’. In legal terms, such issues could be very significant indeed, such as ‘Whereas such serious crimes should be punished by long-term imprisonment,…’ What this means is that a statement in the ‘Whereas’ is a full part of the Directive, not a sort of ‘note’. With best wishes DESIGN IT IN! OOO – Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Piotr Galka [mailto:piotr.ga...@micromade.pl] Sent: 03 August 2017 16:28 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RED DoC and LVD I think I don't feel 'Whereas' precisely. In Polish directives it was replaced with 7 words: "but also hawing in attention, what follows:" I feel it as "we have it in attention, and only that - no more" so I called it 'wishful thinking'. Piotr Gałka MicroMade Gałka i Drożdż sp.j Gdańsk Polska W dniu 2017-08-03 o 15:35, John Woodgate pisze: With best wishes DESIGN IT IN! OOO – Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Piotr Galka [mailto:piotr.ga...@micromade.pl] Sent: 03 August 2017 14:22 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RED DoC and LVD John, The full text you can find in my first mail - still present at the end: [JMW] Ah, well, I didn’t know to look there. 1,4.Radio equipment falling within the scope of this Directive shall not be subject to Directive 2014/35/EU, except as set out in point (a) of Article 3(1) of this Directive. 3,1. Radio equipment shall be constructed so as to ensure: (a) the protection of health and safety of persons and of domestic animals and the protection of property, including the objectives with respect to safety requirements set out in Directive 2014/35/EU, but with no voltage limit applying; (7) seems more clear but As it is before Article 1 I understand it as a kind of wishful thinking set out before issuing the directive. [JMW] No, the ‘Whereas’ are an important part of the Directive, attempting to explain how it was built up. Now (reading it once more and once more and....) I think that probably "shell be constructed.. with respect to ... requirements .. in LVD" means "do everything like with LVD but don't name it as being subject to LVD". Understanding it that way LVD should not be listed in RED DoC, but what for is such complex construction used (saying "no but yes"). [JMW] That’s right. Yes it is something like Gauka or Gawka with 'w' read as in what, when (if I read it correct - I've never been in any English speaking country :( ). I didn’t write ‘Gawka’, because ‘w’ is pronounced in different ways in different languages. - - - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
