The big problem as you've stated is that you can't modify Listed/Certified
equipment and retain the safety marks. As you are aware it ain't Listed or
Certified if they haven't examined it, even if it is obviously (once they do
look at it) compliant to the standards. 
The gotcha paragraphs the flammability requirement and paragraph 5.4.6
        -overloading of SELV connectors and printed wiring board
receptacles, or both, that area accessible to the operator. <<snip>> plus
the flammability requirements.
Basically, what these guys are going to look at is that an operator can plug
this card into any computer without degrading the safety of the computer,
either by making the printed circuit out material that doesn't meet the
flammability requirements and allows flame to spread in an other wise "fire
safe" environment, or that plugging in the wrong peripheral to your port the
operator manages to draw current beyond that which is allowable. Both of
these things are checked on any of the PC cards that are submitted with the
computer. So these are really new or additional requirements they are just
making sure that these cards are at least as good as what the original
computer manufacturer is required to have.
The investigation itself is pretty straightforward. Examine the card for
suitable flammability and measure the max. Current and voltage out of this
thing. Many times this test is waived because their is no power delivered
out of the card. If there is and its fused, or has 10K ohm serial resistance
(UL1950 only not EN60950) the test is also waived. The description of a PC
card I have is three items long. The PCB and it refers back to section
general, the Laser transceiver, and the metal faceplate.
Because the card only has a light output there was no power testing.
This card can now be used in any equipment without violating any of the
safety marks for that equipment.
UL calls these Unlisted components, and TUV certifies it as a component,
without any further clarification, but requires the Buarat (sp?) mark rather
than the TUV mark.
        I have seen many cards that have no safety approvals I just don't
use them
        Hope this helps.
        Gmac


        -----Original Message-----
        From:   [email protected] [SMTP:[email protected]]
        Sent:   Tuesday, December 22, 1998 12:06 PM
        To:     [email protected]
        Subject:        Product Alteration

                        On a similar note to the current thread regarding
changes in
        company names, I am reminded that I have a related question. My
company
        plans to buy 
                        "off the shelf"  PCs, add logic cards, fans and
perhaps even
        an additional power supply. What are the implications? Obviously
this
        negates the original safety license and I would assume that the mark
would
        have to be removed. Again I understand that the circuitry added must
remain
        compliant with the respective EMI/EMC standards. But my question is
this:

        1.      What process is required to use a "approved" PC as a
superset to my
        product.  Can I submit a make from to a given safety agency,
submitting the
        original device with my modifications. Who then is the manufacturer?

        Thanks in advance.


        Best wishes to everyone at this Christmas season!

        Rick

        [email protected]

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