The discussion on languages and grammar has been very useful.


I would like your opinion and answers on the following standards clause, as found in a concept cited harmonised EMC product family standard:

/If hardware or software are modified subsequent to the completion of the tests described in this standard// //an impact analysis shall be carried out and it shall be decided whether the EMC test shall be repeated as // //a whole, in parts or not at all. Impact analysis and decision shall be added to the EMC test plan for the////apparatus./


I have some questions on this clause:

1. What is this clause doing in a standard describing technical
   requirements for an apparatus?
2. Shouldn't this be part of a basic standard describing the test method?
3. Who should carry out the impact analysis (not the manufacturer of
   course) and decide on what retesting to do?
4. Why this should be made part of the test plan and not in the test
   report?

The principle of EMC- testing equipment, is that a full test is required upon any modification, as a modification makes it a a different equipment, but i also understand that a strict interpretation of this might lead to excessive test costs, and some test reductions are possible based on EMC expertise , experience in testing and knowledge of the equipment. I also consider that the EMC-directive is requiring as assessment and not testing (though testing seems an essential part of assessing and test reports are mentioned explicitly in the EMCD annexes.

But there is much more to say about an impact analysis than a simple clause .....

How would you treat the problem of infinite testing, -to-be-sure-, versus realistic testing, and how would you implement such a "impact analysis" in the different standards, in the light of creating HS with legal effects.


Gert Gremmen




--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant


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