You're correct that no "governmental organization" require approved
components. If they are in safety critical areas they will be
investigated along with the rest of the product to insure that they can
meet the requirements in the safety standards.
Transformers are, or used, to be a good example of the safety evaluation
process. Transformers can be certified on their own (with some
conditions applied to their proper application in the end product.) That
certification really addresses the insulation class, spacing, etc.
However, nobody requires that you use a pre-approved transformer. If you
wish to use it, you will be asked for multiple samples of the
transformer including a non-potted sample - so that the investigating
agency can investigate this component of your system. They will then
proceed along with the rest of the investigation on the end product and
if everything, including the transformer construction meets the
requirements you will be allowed to apply the appropriate safety label
to the end product. As part of your periodic follow up inspections they
will pull the transformer apart to inspect for the proper number of
layers of insulation, that it is the material you said it was, that the
windings are held in place as described in the report etc. If you don't
build the transformer in-house and have don't have ready information
about the material identification then verifying the insulation system
is a daunting task.
Had the transformer carried its own approvals the investigation of the
transformer stops once you have identified the transformer as the
manufacturer and model described in your end product evaluation report.
(This is because the safety agencies are independently investigating the
transformer manufacturer to insure it continues to meet the
requirements).
This whole process is repeated for each private label safety
organization to which you have requested a safety evaluation. UL - TUV -
NOM - GOST etc.
Given the costs and time for investigating components in my end product
and the hassle of confirming the construction through the follow up
inspections I don't find it cost effective to use non-approved
components if I don't have to.
As long as there is an independent safety mark applied to the equipment
and you have time to have all of the components investigated during your
final product safety submittal and still meet my time lines for product
introduction I would consider your equipment for purchase or inclusion
into my equipment. If you are simply telling me that you have checked it
out and it meets your interpretation of the standards, and their exists
standards for your product category, I'll find another vendor.
This seems related to the survey of self testing versus third party
tested to confirm compliance. I didn't see the final results of the
survey but the few responses I saw clearly indicated that all of us were
looking for independent confirmation that equipment met requirements.
Gary McInturff
-----Original Message-----
From: Crabb, John [SMTP:jo...@exchange.scotland.ncr.com]
Sent: Wednesday, September 09, 1998 1:14 AM
To: 'je...@ftc2.aei.com'; emc-p...@ieee.org
Subject: RE: Agency approvals on components in CE mar
I will paraphrase the situation as stated in the "Low Voltage
Directive",
73/23/EEC, as amended by 93/68/EEC (CE Marking Directive) ;
"CE marking attests to the conformity (of the electrical
equipment) to the
provisions of this Directive."
"The Member States shall take all appropriate measures to ensure
that,
in particular, electrical equipment which complies with the
safety
provisions
of harmonized standards shall be regarded by their competent
administrative
authorities as complying with the provisions of Article 2 (the
basic
requirement
that equipment be "safe"), for the purposes of placing on the
market and
free movement".
If you are CE marking on the basis of your own "manufacturers'
declaration
of
conformity", ALL you have have to do is to have prepared a
report showing
conformity to a harmonized standard. Standards do not require
that you use
agency
approved parts - agencies do ! Refer to IEC 950 para 1.5.2
for more
details on
evaluation and testing of components.
John Crabb, Product Safety Engineer, NCR Financial Solutions
Group Ltd,
Dundee, Scotland.
> -----Original Message-----
> From: je...@ftc2.aei.com [SMTP:je...@ftc2.aei.com]
> Sent: 08 September 1998 17:31
> To: emc-p...@ieee.org
> Subject: Agency approvals on components in CE mar
>
>
> It is my understanding that the European Commission has stated
that a
> manufacturer has the freedom to determine the acceptability of
components
> used in CE marked products. (Or words to that effect.) I
would conclude
> that this would remove the need for using European agency
approved
> components in safety critical locations. Any reputable agency
approval,
> or
> appropriate evaluation by the manufacturer, would be
acceptable.
>
> Does anyone know of where I can obtain this statement in
writing? I'd
> like
> to have something to back this up. Also, I welcome comments
on the
> conclusions I have drawn based on this "alleged" EC statement.
>
> Regards,
>
> Jeff Jenkins
> Senior Regulatory Compliance Engineer
> Advanced Energy Industries, Inc.
> Fort Collins, CO USA
>
>
>
>
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