See below. Jon D. Curtis, P.E. Director of Engineering email: [email protected] Curtis-Straus LLC phone: (508) 263-1897 409 Massachusetts Avenue fax: (508) 263-4164 Acton, MA 01720 http://world.std.com/~jdc/ USA
On 5 Jun 1996, rbusche wrote: > For some reason, it is still unclear in my mind the role of a competent body > in the big picture. I have thrown out several topics for discussion on this, > yet, the answer still somewhat eludes me. 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? Yes, but... for emissions they must choose an approved standard. This is to prevent interference to a third party (company C) outside the transaction. For immunity, a standard must also be picked. BUT, company A could accept that Company B writes in it's manual that the product's performance is unknown and possibly horrible under ESD, EFT, RFI, etc. (why company A would accept substandard immunity is still an issue) Remember, under the performance criteria of the generic immunity documents, Company B is representing that their product performs as specified in the manual under EMC disturbances. The immunity side of the EMC directive can be looked at as setting up a covenant between the transacting parties. In the absense of further agreements, Company A has reason to believe that Company B's product operates as stated in the manual under a suite of electromagnetic disturbances defined by the standards as applicable to the expected end-use environment. >I > understand that if no standard exists or has been officially published in the > OJ, a competent body might be useful. Right. But there are currently very few areas under the EMC directive that are not covered by the standards route. In fact, since the generic documents for immunity and emissions are published there is always a standards route to compliance. Only where the standards route is particularly onerous and you can convince a competent body to go easier on you, does the TCF route for the EMC directive make any economic sense at all. In my experience, rather than interpreting EMC regulations in a rational manner to minimize the required testing, competent bodies tend to test to everything they can find that might be applicable including draft standards not yet even published! >But in my scenario, I am providing ITE > equipment to a larger system which is arguably in this gray area. If your customer says you need to go the TCF and you can't convince him otherwise, you'll need a TCF to get the sale. Make sure he pays for it! > > 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. The only justification is based on your customer's lack of trust in you or the lab you contract to do the testing. There is no requirement in law for you to get a TCF from a competent body. > > 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. This is a non-issue as relates to competent bodies. The standards route is open for both light and heavy industrial products. I agree that you should be able to pick either or as long as you document your decision in your specifications to the customer. You are responsible for defining the environment in which you intend your product to be used. > > 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. > > Thanks in advance.... > > > Rick Busche > [email protected] >
