---------- Forwarded Message ----------

From:   Chris Dupres, 100014,3703
TO:     Mark Hone, INTERNET:[email protected]
DATE:   11/06/98 23:22

RE:     Copy of: Re: CE technical file format

Hi Mark and the group.

The term 'Technical File' has been mentioned a few times.  It's worth
mentioning that under the UK EMC Regulations  SI 1992/2372 the term
'Technical Construction File' is a formal term used to describe one of the
legal routes to meeting the compliance criteria.  The other two are the
'Standards Route' and the 'EC Type Examination Route'.

The form of the 'Technical Construction File' is described in this Law (for
that is what it is) in Part V, clauses 41-58, so there can't be much doubt
about what that is as clause 43 is quite specific.  TCF's are required to
be verified by a 'Competent Body' appointed by HM government, and who will
happily relieve you of a substantial quantity of Beer tokens for the
privilege.   However the semantically quite different collection of
technical data and declarations which go to support a self assesment and
declaration of conformity under the Standards Route is normally called a
'Technical File', and contains all the information that would be required
to provide evidence of your compliance to a reasonably well qualified
competent engineer.   This may include, but not necessarily, emission and
immunity test results, photographs of the equipment and test layout (if
carried out), circuit diagrams, assembly drawings, installation
instructions etc. etc.  Competent Body qualification is not required of a
TF, you go to jail on your own behalf if you deliberately seek to confuse.

ThisTechnical File has to convince the Regulating Authority, in the UK the
Trading Standards, and they are not at all stupid!  Interestingly, there is
no legal requirement in the UK regs to carry out tests, though how you
convince people of your compliance with the standards without test results
is an interesting diversion.  Of course if you make a 100W resitive heater
for fish tanks or whatever, the EMC risk would be quite low...  and a
simple declaration would no doubt suffice.  (For these purposes I assume NO
triac controls).

So, don't mix your TCF's with your TF's.   

A tuppence worth, perhaps.

Chris Duprés
Surrey, UK.

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