In reply to Pete Perkins, The issue Pete raises regarding the legal liability for any individual signing a Declaration of Conformity for Europe is often not considered with the respect it sometimes deserves.
A similar situation applies in Australia relating to the use of the C-tick and A-tick marks. There is a legal liability and penalty for both the organisation responsible and the individual who signs a Declaration of Conformity falsely etc. Best regards, Kevin > Sender: [email protected] > Received: from ruebert.ieee.org (ruebert.ieee.org [199.172.136.3]) > by dub-img-11.compuserve.com (8.8.6/8.8.6/2.18) with ESMTP id PAA17841; > Tue, 2 Mar 1999 15:25:55 -0500 (EST) > Received: by ruebert.ieee.org (8.8.8/8.8.8) > id PAA21646; Tue, 2 Mar 1999 15:25:00 -0500 (EST) > Date: Tue, 2 Mar 1999 15:20:55 -0500 > From: "Peter E. Perkins" <[email protected]> > Subject: CE marking - self-certification > To: PSNetwork <[email protected]> > Message-ID: <[email protected]> > MIME-Version: 1.0 > Content-Type: text/plain; charset=ISO-8859-1 > Content-Disposition: inline > Content-Transfer-Encoding: 8bit > X-MIME-Autoconverted: from quoted-printable to 8bit by ruebert.ieee.org id PAA21632 > Sender: [email protected] > Precedence: bulk > Reply-To: "Peter E. Perkins" <[email protected]> > X-Resent-To: Multiple Recipients <[email protected]> > X-Listname: emc-pstc > X-Info: Help requests to [email protected] > X-Info: [Un]Subscribe requests to [email protected] > X-Moderator-Address: [email protected] > > > PSNet > > This ongoing discussion of self certification brings to the surface > several issues... > > In applying the CE marking to equipment, the manufacturer must sign > the Manufacturer's Declaration of Conformity. In doing so, it must include > a list of the Directives and Standards that the manufacturer claims to > meet. > > The manufacturer is allowed to do all the work to ascertain > compliance without the use of any outside help. In fact, that is commonly > encouraged by the EU. > > In looking at the practicallity of this, hardly any small companies > have the resources of an in-house, full EMC lab to determine the > acceptability of their product to meet these requirements. So, this is > often hired out. > > On the mechanical and electrical safety side, most engineering > departments feel that they can properly assess their equipement against the > requirements. This is usually the point of discussion of > self-certification. > > Just one reminder, however, that the person who signs the MDoC for > the company bears personal criminal liability in EU law if they sign > falsely. So, the signer should ask carefully if the evaluators of the > equipment not only understood the technical requirements, but do they > understand the usual European interpretation of these requirements. > > If there is any doubt in having this Euro understanding, the use of > a Notified Body on the first few projects will go a long way in assuring > that the Euro interpretation is understood and used in the product > evaluation. > > So it costs a lot of money, you say... What's it worth to insure > that you don't get harassed about your meeting the requiements by some NCB > who is following up on a complaint... or worse, find yourself not being > able to defend compliance to the requirments because you didn't understand > the usual Euro interpretation of the requirements... > > This little homily can, again, be classified as a word to the wise > or deficient... pick your poison... > > > - - - - - > > Peter E Perkins > Principal Product Safety Consultant > Tigard, ORe 97281-3427 > > +1/503/452-1201 phone/fax > > [email protected] email > > visit our website: > > http://ourworld.compuserve.com/homepages/peperkins > > - - - - - > > --------- > This message is coming from the emc-pstc discussion list. > To cancel your subscription, send mail to [email protected] > with the single line: "unsubscribe emc-pstc" (without the > quotes). For help, send mail to [email protected], > [email protected], [email protected], or > [email protected] (the list administrators). > > Best regards, Kevin Richardson Stanimore Pty Limited "Specialists in Technology Requirements and Compliance" Ph: 02-43-29-4070 Fax: 02-43-28-5639 Int'l: +61-2-43-2x-xxxx Email: [email protected] (Internet) or [email protected] (Internet) or 100356,374 (Compuserve) --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], [email protected], or [email protected] (the list administrators).
