A tangent here but an important one given the theme of this thread. Once one
has decided there is a law that pertains to the safety requirements, or at
least an insurance reason for doing these things, or that indeed the federal
regulations for EMI apply, the next step is in deciding whether or not you
are going to comply. This is almost always a sales or marketing issue, and
you can fill in your favorite reasons.
I don't know how many times I have had to address the issue of simply
writing the customer a letter and see if he waives these requirements. Not a
good idea, and it does not relieve the manufacturer of any responsibility
under the FCC or NEC rules. At best it only elicits the customer into
complicity to violate federal regulations. The customer cannot, by agreeing
to accept non-compliant or non-approved equipment, override the federal
requirements.
As Tania, points out there are ways to get some small number of units to
Beta sites, (A Beta Test site can be considered under engineering control as
they are working with the manufacturer to report any bugs etc. - this is an
opinion mind you so check it out with your internal sources and make sure
there is consensus.)However, all of the equipment must eventually be
compliant including the Beta equipment that may have already been shipped,
if you can't do it in the field you are going to have to replace it. This
upgrade part seems to be conveniently overlooked. Before I agree to any
release of this type I require the serial numbers and addresses so that I
can track it later.
A thorough reading of CFR 47 section 2.8 is actually pretty interesting.
The very next question that comes up is then. "What are the chances of
getting caught". I have pretty much given up even addressing this question.
Gary
-----Original Message-----
From: Grant, Tania (Tania) [SMTP:[email protected]]
Sent: Monday, August 16, 1999 11:32 AM
To: [email protected]; '[email protected]'
Subject: RE: Equipment for development
Tim,
I am not aware that the different states have different approaches;
however,
the local authorities, including your customer, might have different
ideas,
especially with respect to safety. That is why I recommend that
you
contact your customer to ask him what their expectations are
specific to
safety.
My expectations for safety, as a minimum, would be a complete design
review
for safety compliance, an individual product safety inspection by
you
product safety engineer of the specific unit that is to be shipped
out, and
a hipot test and ground resistance test at the appropriate voltage
for your
product. Be aware that Underwriters Laboratories has a program
where a UL
inspector/engineer will go out to a site and perform visual
inspection for
basic safety (may require supporting documentation from you!) and
may
require hipot tests at the site, and then affix their own UL mark
(which is
different from the one you can affix to the product). All this is
a lot of
rigmarole that may be definitely worthwhile to minimize any
liability issues
that may arise. You can obtain details from UL.
Our process is to obtain official safety approvals before we ship
any
so-called BETA systems (still under development) to any potential
customers.
For compliance to FCC Part 15 (EMC), the federal regulators are
quite
specific. For Class A product only, you are allowed to ship
systems still
under development, provided "....the customer is advised that this
equipment
has not yet been tested for compliance, but will comply when finally
shipped..." All this is specified in Part 2 of the Rules. What
many
people don't realize is that FCC Rules Part 15 are the technical
part, and
Part 2 the general and administrative part that still apply to all
equipment
covered under the other parts.
I always advise that the letter stating the above be addressed to a
specific
person and reference the specific model and serial number that is
being
shipped. You want to show due diligence in case the authorities
have any
questions.
Tania Grant, [email protected] <[email protected]>
Lucent Technologies, Communications Applications Group
----------
From: [email protected] [SMTP:[email protected]]
Sent: Monday, August 16, 1999 8:12 AM
To: [email protected]
Subject: Equipment for development
Hi Everybody,
I have some equipment that is currently under development for an
American company. While the design of the equipment still has to be
finalised, the customer requires a set of units to run on a
simulator
for test purposes.
Apart from the obvious requirement that these development units must
not cause harm, are there any specific requirements for safety or
EMC
(etc.) that *must* be complied with?
I don't know (at this time of writing) which State the company is
located - is there any serious differences between States that must
be
considered?
Regards
Tim
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