lfresea...@aol.com wrote:
> 
> Brian,
> 
> I'm not sure that I agree with you on your TCF statement. Our TCF's reference
> Harmonized documents, when these change I'm expecting that we will have to
> update our TCF for what ever changes are introduced.
> 
> You don't agree?
> 
> Derek.


Derek

With the TCF route to compliance you demonstrate in the evidence 
contained within the file that the apparatus meets the protection 
requirements of the Directive.  

This means demonstrating that the product does not emit at a level which 
would cause disturbance to other apparatus or services in its 
environment, and that it is sufficiently immune to disturbances which 
exist in that environment.  

This may mean that the TCF covers more immunity phenomena than might be 
covered in a harmonised standard, or as in the example given in my 
earlier posting, less.  The requirements applied may also be different.  
It depends on the apparatus and the environment.  Unless the apparatus or 
the environment change, the TCF remains valid.

The use of harmonised standards in part, or any other standards, does not 
change these concepts.  Of course if you meet a relevant harmonised 
standard in full, then the TCF does not need to cover that aspect.

The Commission Guidelines, in Section 8.2 state "... the technical report 
or certificate [issued by the Competent Body] should be limited to a 
report or certificate that the procedures carried out for the conformity 
assessment of those parts not covered by applied harmonised standards 
have been correctly performed ..."

Those EMC aspects covered by harmonised standards, and not the TCF, would 
indeed need to be reconsidered if one of those standards is changed, 
because that part of the EMC compliance has been demonstrated via the 
standards route. 

I hope that this helps.

Best wishes

Brian Jones
EMC Consultant and Competent Body signatory


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