RIck, You ask (your points preceeded with a '>'): > For some reason, it is still unclear in my mind the role of a competent body in the big > picture. Please bear with me as I ask this question one last time.
> If company A in Europe buys a product from company B in the US, and the product > is delivered with a CE Mark on the device(s). (Of course with the DoC > accompanying the mark). Shouldn't company A be allowed to determine if the > equipment suits them for their application AND shouldn't company A be able to > accept whatever equipment they want WITHOUT a competent body involved? I > understand that if no standard exists or has been officially published in the OJ, a > competent body might be useful. But in my scenario, I am providing ITE equipment > to a larger system which is arguably in this gray area. As one who has proceeded through the competent body avenue recently, your points touched on some close issues with me. Here's my slant on this. The products that my employer provides to our European customers are basically ITE with some telco I/O thrown in. These are open systems with MANY possible configuration scenarios. By working with a competent body, we were able to test a determined single representative "worst case" configuration. Testing was performed here in the USA with the competent body playing the part of a review authority. This scenario worked well for us. This approach was also instrumental in obtaining the NEMKO safety approval without having to retest at a NEMKO approved EMC lab. However, compliance to the EMC Directive must be attested via a CE marking and the MDofC. Suitable emissions and immunity standards, specific or generic, must be selected for this purpose as your product(s) relate to them. In an open "free market", company A should be allowed to determine if the equipment from company B suits them for their application. Your question suggesting that "company A be able to accept whatever equipment they want WITHOUT a competent body involved" is possible. Simply put, if the products being supplied are not contained in the above stated categories and are not radio devices, then they fall to the self-declaration route. > Even here I have some concerns. The final application is a flight simulator with > hydraulic motion platforms, displays, and computer systems. It is not obvious to me > that this is justification for hiring a competent body to evaluate EMC performance. It is my opinion that, aside from the condition of Article 10-2, competent body selection is purely optional and voluntary to anyone or any organization wishing to do so. > The issue of "light" industrial Vs "heavy" industrial in my mind is one of > ruggedization for the effects of EMC. Given that EN55022 defines the environment > for a Class A emission device, the generic immunity standard EN50082-X should > be a customers decision. You are correct in that the "light" vs"heavy" industrial environments is only a matter of EMC ruggedness. This is reflected in Article 4(b) of the EMC Directive. In fact, determining which environment should depend soley on the characteristics of a product's final intended operating environment. I feel this is not so much regulatory, but one of dependability and reliability. > Please excuse me if this is a dumb question, but if someone can shed a bit more > light I promise to shut up on this issue. I firmly believe that the only dumb question is the one not asked. By not asking, it only keeps one and possibly others in the dark. And, dark is one thing we don't need more of. I hope that my opinions expressed here have shed some, or any, light for you. Please bear in mind that these opinions are my own. Best regards, Ron Pickard [email protected]
