In the instance of EN 61000-3-2 and EN 61000-3-3, we MUST look to regulatory authorities to make the decision.
I think the basis of the whole argument is this: For many products covered by these standards, the "essential requirements" as listed by many competent EMC engineers would not include EN 61000-3-2 and EN 61000-3-3. In their eyes it only increases product cost and complexity with minimal product reliability and/or safety benefit. Other competent engineers would disagree. Apparantly, standards writing committees for IEC and CENELEC have stumbled over the same problem. The authors of EN 61326-1 (and apparatantly some other product standards) did not feel that the "essential requirements" for Class A Test and Measurement equipment included EN 61000-3-2 and EN 61000-3-3. The authors of EN 61000-3-2 and EN 61000-3-3 disagreed. According to standards hierarchy, the authors of EN 61000-3-2 and -3-3 win out. That's great, but it doesn't clear up the conflicting standards and we've already seen that it isn't clearly solved by "essential requirements" type thinking. I think that the "essential requirements" type of solution only works when you could ask 100 EMC engineers about a requirement and get the same answer more than, say, 95 times. This standard does not fall into that category (as witnessed by all of the confusion). I would assert that the argument over this standard has precipitated because most EMC engineers DO UNDERSTAND essential requirements. This is what leads them to question the standards. As a design engineer, I do not have the power to go to my power supply manufacturers and demand power factor corrected power supplies. My power supply manufacturers are very cost competetive and will wait for a VERY clear system of regulatory mandates before they take the risk of increasing the cost and complexity of their power supplies. Also in our cost competetive market we cannot always afford a custom power supply. It seems to me that the confusion and fighting over this standard initially slowed down the availability of power factor corrected supplies which put an availability crunch on quite a few designers. That is where a clear regulatory mandate would help. In the end, I don't think that we're waiting for the regulatory agencies to make our decisions for us. I think we're waiting for them to make their own decisions for themselves (with our input). When they are clear in their decisions, it helps to level the competetive playing field among products. When they take on the authority of regulation, they take on the responsibility of being clear in their mandates. (Anybody else who is a parent would understand that one.) I feel better. This will be my last email regarding this thread (promise) (collective applauase from the group) Have a good one :-) Chris > -----Original Message----- > From: Wagner, John P (John) [SMTP:[email protected]] > Sent: Wednesday, October 11, 2000 10:55 AM > To: 'EMC-PSTC - forum'; 'Jim Eichner' > Subject: RE: Standards hierarchy > > > I'd like to throw my two cents worth in here. > > First, compliance with a national/international standard or regulatory > regime does not guarantee adequate product performance or safety. That is > the responsibility of the manufacturer. The standard(s) gives guidance to > achieve that acceptable level of performance and compliance with it > acceptable to a regulatory regime or authority provides a legal basis to > market the product. > > Don't look to regulatory authorities to manage your compliance or > EMC/Safety > design goals. > > John P. Wagner > AVAYA Communication > 11900 N. Pecos St, Room 2F58 > Denver CO 80234 > email: [email protected] > phone: 303 538-4241 > fax: 303 538-5211 > > > ---------- > > From: Jim Eichner[SMTP:[email protected]] > > Reply To: Jim Eichner > > Sent: Tuesday, October 10, 2000 4:45 PM > > To: 'EMC-PSTC - forum' > > Subject: RE: Standards hierarchy > > > > > > To summarize and conclude this thread: > > > > 1. If you ignore all consideration except the rules for CE Marking and > the > > EMC Directive, and if you have a product family standard that does not > > call > > out any other standards (for example EN61000-3-2), and if that product > > family standard has been published in the OJ, then it would seem that > you > > are in compliance with the EMC Directive if you apply only that standard > > (since it provides a presumption of conformity). > > > > 2. Doing the above would be a bad idea because... > > > > a) The EC has not got it's act together. With one hand they publish a > > standard in the OJ and with the other hand they say the standard isn't > > sufficient. According to what Gert said, it sounds like the EC will be > > working with CENELEC to correct this situation, so it is short sighted > to > > take the easy road now if you'll just have to take the longer road later > > anyway. > > > > b) There may be real world problems (and in the worst case a product > > safety > > hazard) associated with an EMC phenomenon addressed by other standards > but > > omitted by your product family standard. In such a situation, liability > > may > > be increased by not having applied the other standards, even though > > technically you didn't have to. > > > > c) You are flying in the face of standard practice (pun intended). > > Diligent > > compliance people are doing the "right" thing and applying all the > > standards > > that apply, rather than putting on the blinkers and just using their > > product > > family standard (however technically correct or incorrect that may be). > > > > I'd add a statement to Gert's closing comment that the concept of > > essential > > requirements has not been fully understood yet. I'd echo say the > concept > > of > > product family standards has not been fully understood yet. The Europa > > web > > site list of harmonized standards is full of wording that implies that > > single standards give presumption of conformity with the EMC Directive's > > essential requirements. There is nothing to indicate that in many > (most?) > > situations it will take a group of standards to fully cover all the > > essential requirements. > > > > If anyone from the EC or CENELEC has been following this thread, it > would > > be > > very helpful to get some clarification as to the current and future > "right > > way" to deal with this issue. > > > > Regards, > > > > Jim Eichner > > Sr. Regulatory Compliance Engineer > > Mobile Markets > > Xantrex Technology Inc. > > Email: [email protected] > > Website: www.xantrex.com > > > > Any opinions expressed are those of my invisible friend, who really > exists > > but is not, by himself, sufficient to give presumption of...oh never > mind. > > > > > > > > > > > > -----Original Message----- > > From: CE-test - Gert Gremmen Ing. - CE-mark & more ... > > [mailto:[email protected]] > > Sent: Thursday, October 05, 2000 5:20 AM > > To: Jim Eichner; 'EMC-PSTC - forum' > > Subject: RE: Standards hierarchy > > > > > > Hello Jim, group > > > > You are fully right. A standard not covering a certain EMC subject, or > > whitening it out > > due to whatever reason but physical/technical (such as a filament lamp > not > > being susceptible) > > still owes the presumption of compliance but the presumption will not > > hold > > in court. > > > > After all , presumption is not proof !!!!!! > > > > BTW it happens all the time that we are needing more then one emc > standard > > . > > For ITE we need 4: EN 55022 / EN 55024 / EN 61000-3-2 / EN 61000-3-4. > > > > We automatically add the other 3 as we conclude that the first one did > not > > cover > > certain phenomena. > > > > What's new here is that the EC does not recognize the right of OJEC > > published standards > > to white out certain test requirements because some lobby decided that > it > > was not > > in their interest to cover this. > > > > In fact the EC is targeting the CENELEC for creating insufficient > quality > > standards > > (in this case) and not you as a manufacturer presuming compliance. > > Therefore, you will get away with such a standard - for the time being. > > > > I think the principal of essential requirements has still not been fully > > understood !! > > > > Regards, > > > > Gert Gremmen, (Ing) > > > > ce-test, qualified testing > > > > =============================================== > > Web presence http://www.cetest.nl > > CE-shop http://www.cetest.nl/ce_shop.htm > > /-/ Compliance testing is our core business /-/ > > =============================================== > > > > > > >>-----Original Message----- > > >>From: [email protected] [mailto:[email protected]]On > Behalf > > >>Of Jim Eichner > > >>Sent: Thursday, October 05, 2000 2:39 AM > > >>To: 'EMC-PSTC - forum' > > >>Subject: RE: Standards hierarchy > > >> > > >> > > >> > > >>OK now I'm really confused. It suddenly hit me that I thought > > publication > > >>in the OJ conferred presumption of conformity with the essential > > >>requirements!!! End of sentence, full stop. Silly me, I must > > >>stop standing > > >>so close to the microwave. > > >> > > >>Are we really in a situation where there are standards being published > > in > > >>the OJ that do NOT address all of the essential requirements and are > > >>therefore not sufficient on their own? This seems to be what Gert's > Mr. > > >>DeVre is saying, and if so the system is downright out of control. > > >> > > >>I assert that despite Mr. DeVre's comments, a standard that has been > > >>published in the OJ as applicable under the EMC Directive gives > > >>presumption > > >>of conformity with the essential requirements of that directive, and > is > > >>therefore, by definition, sufficient without the use of further > > standards. > > >> > > >>Am I wrong!? Further comments please! > > >> > > >>Thanks, > > >> > > >>Jim > > >> > > >>Suddenly flipping burgers for $5/hr doesn't sound so bad. > > >> > > >>-----Original Message----- > > >>From: [email protected] [mailto:[email protected]] > > >>Sent: Wednesday, October 04, 2000 11:49 AM > > >>To: CE-test - Gert Gremmen Ing. - CE-mark & more ... > > >>Cc: Maxwell, Chris; 'Jim Eichner'; 'EMC-PSTC - forum' > > >>Subject: RE: Standards hierarchy > > >> > > >> > > >> > > >> > > >>Gert et al, > > >> > > >>[Critical comments re CEN removed in an attempt to maintain a > > professional > > >>attitude.] > > >> > > >>Can't we just recind all of these silly redundant product family > > standards > > >>if > > >>they are truely just informative supplements to the Generics? I'm > > getting > > >>tired > > >>of retesting and then rewriting hundreds of DoCs. > > >> > > >>Regards, > > >>Eric Lifsey > > >>Compliance Manager > > >>(And a miserable author of about 400 DoCs.) > > >>National Instruments > > >> > > >> > > >> > > >> > > >>Please respond to "CE-test - Gert Gremmen Ing. - CE-mark & more ..." > > >> <[email protected]> > > >> > > >>To: "Maxwell, Chris" <[email protected]>, "'Jim Eichner'" > > >> <[email protected]>, "'EMC-PSTC - forum'" > > >> <[email protected]> > > >>cc: (bcc: Eric Lifsey/AUS/NIC) > > >> > > >>Subject: RE: Standards hierarchy > > >> > > >> > > >> > > >> > > >>I remember to have contributed to this discussion before, and I have > > asked > > >>this question at the time to Robert DeVre, who is actually the > > >>EMC-consultant of the European Committee. > > >>His opinion -close to European law- (abbreviated) : > > >> > > >>== > > >>Any product or product family standard that tries to exclude any > > >>category of > > >>tests (f or categories see f.a. the generic) is actually creating a > > >>non-compliance situation for the equipment in question, as it does not > > >>comply to the essential requirements of the EMC-directive. > > >>== > > >> > > >>Do not forget that complying to a standard creates only presumption of > > >>conformity to the essential requirements. The standard writing > > >>committee did > > >>bad service to the market creating a standard trying to create an > escape > > >>route. > > >> > > >>The EC ( by voice of Mr. DeVre) has contacted CENELEC to make > > >>this standard > > >>comply with the Essential requirements of the EMC-directive. > > >> > > >>Please note that there is a report available to all national > > >>committees that > > >>are charged with standards writing, that explains to what requirements > > >>future "harmonized standards" should comply to be acceptable to the EC > > and > > >>create (true) presumption of compliance for users actually using them. > > >>This technical report is numbered R210-001 (at least the version I > have > > in > > >>front of me) and is issued by the CENELEC. It's purpose is to advise > > >>standard writing committees in: > > >> > > >>- advice on the application of generic and basic emc standards > > >>- advise on the preparation of product family or dedicated product emc > > >>standards. > > >> > > >>Please note that the compliance for product standards to this > > >>report is part > > >>of the agreement that CENELEC will prepare standards for the EC to > > comply > > >>with EMCD. > > >>(as CENELEC is private and EMCD is law) > > >> > > >>This report has a summary of phenomena that product and product family > > >>standards should > > >>cover: creating limits, or create a decent rationale why not. > > >> > > >>In addition: > > >> > > >> "for assessment of compliance with the EMC -directive, the product > > family > > >>standards take precedence over the generic standards partially or > > totally > > >>according to the EMC domains covered." > > >> > > >>Uncovered or excluded phenomena are thus still susceptible to generic > > >>standard test requirements !!!!!!! > > >> > > >>Regards, > > >> > > >>Gert Gremmen, (Ing) > > >> > > >>ce-test, qualified testing > > >> > > >>=============================================== > > >>Web presence http://www.cetest.nl > > >>CE-shop http://www.cetest.nl/ce_shop.htm > > >>/-/ Compliance testing is our core business /-/ > > >>=============================================== > > >> > > >> > > >>>>-----Original Message----- > > >>>>From: [email protected] [mailto:[email protected]]On > > Behalf > > >>>>Of Maxwell, Chris > > >>>>Sent: Tuesday, October 03, 2000 9:57 PM > > >>>>To: 'Jim Eichner'; 'EMC-PSTC - forum' > > >>>>Subject: RE: Standards hierarchy > > >>>> > > >>>> > > >>>> > > >>>>Jim, > > >>>> > > >>>>Yes, I'm sure that there was a "collective groan" when you mentioned > > EN > > >>>>61000-3-2 and EN 61000-3-3 in your email. I wasn't part of it. > > >>>>I'm glad to > > >>>>see that someone else is still questioning what's going on with this > > >>>>standard. > > >>>> > > >>>>I think that your understanding of "Basic Standards", "Product > Family > > >>>>Standards" and "Generic Standards" is about as good as anybody's. > > >>>> > > >>>>I started a thread similar to this some months ago. I may not > > >>be able to > > >>>>answer your question directly, but I can outline the response > > >>>>that I got so > > >>>>that maybe you can draw some parallels to your own situation. > > >>>>The last time > > >>>>I summarized the responses I got, I received some ridicule. Being > the > > >>>>youngest of 11 children, I've taken my share of that and I've > > >>>>learned not to > > >>>>let it get in my way. So ... > > >>>> > > >>>>My company is in a similar situation with EN 61326-1 versus EN > > >>>>61000-3-2 and > > >>>>61000-3-3. > > >>>> > > >>>>EN 61326-1 is a product family standard covering test and > measurement > > >>>>equipment. EN 61326-1 specifically includes EN 61000-3-2 and > > >>>>EN 61000-3-3 > > >>>>in the requirements for its "Class B" (residential) equipment. > > >>EN 61326-1 > > >>>>specifically excludes EN 61000-3-2 and EN 61000-3-3 from the > > >>requirements > > >>>>for its "Class A" (non-residential) equipment. > > >>>> > > >>>>The last time we discussed this, the responses I got were: > > >>>>(paraphrased to > > >>>>protect the innocent) > > >>>> > > >>>>FROM A PERSON AT A TEST LAB: > > >>>>EN 61000-3-2 and -3-3 are "Product Standards" which apply and > > >>are enforced > > >>>>upon any equipment falling under their scope. They cannot be > > >>>>excluded by a > > >>>>product family standard (such as EN 61326-1) with a narrower scope. > > >>>> > > >>>>FROM ONE OF THE PEOPLE ON THE PANEL THAT WROTE EN 61326-1: > > >>>>EN 61326-1 specifically intended to exempt its Class A equipment > from > > EN > > >>>>61000-3-2 and EN 61000-3-3. > > >>>> > > >>>>FROM AN INNOCENT BYSTANDER: > > >>>>EN 61000-3-2 and EN 61000-3-3 were given Product Family Standard > > >>>>status by a > > >>>>stroke of an editors pen without true CENELEC approval. They > > >>>>were intended > > >>>>to be basic standards. Chaos has ensued. > > >>>> > > >>>>At this point, I was still confused, so I emailed CENELEC using the > > >>>>www.cenelec.be website. > > >>>> > > >>>>FROM CENELEC: > > >>>>Check with ANSI (The American National Standards Institute). > > >>>> > > >>>>So, I followed my instructions: > > >>>> > > >>>>FROM ANSI: > > >>>>(No comment) > > >>>> > > >>>>Well there you have it. (SARCASM ALERT !!!!) I don't understand > why > > >>>>anyone would be confused about this standard. > > >>>> > > >>>>What has this pointed me toward? For one thing, it has led me to > > >>>>appreciate > > >>>>this email group. If it wasn't for the group, I would have > > >>>>simply followed > > >>>>EN 61326-1 and never considered EN 61000-3-2 and 3-3. I may not > > >>>>agree with > > >>>>it, but the only safe path is to design and test our products for > the > > >>>>harmonics and flicker standards. This is what I'm preparing to do. > > >>>> > > >>>>However, I really would like to see some direction from CENELEC to > > clear > > >>>>this up. I think that it would be easy enough. All CENELEC > > >>would need to > > >>>>do is make a short press release and hand it to "Compliance > > >>Engineering", > > >>>>"Conformity", "Item" ... (I apologize to publications I haven't > > listed). > > >>>>I'm sure they would be glad to print it. > > >>>> > > >>>>By the way, I have kept all of the reponses to my original > > >>query. I would > > >>>>be glad to forward them to you if you wish. > > >>>> > > >>>>The opinions expressed in this email are mine and mine alone. I > > >>>>don't think > > >>>>like my employer. If I did, they wouldn't have any use for me. > > >>>> > > >>>>Chris Maxwell, Design Engineer > > >>>>GN Nettest Optical Division > > >>>>6 Rhoads Drive, Building 4 > > >>>>Utica, NY 13502 > > >>>>PH: 315-797-4449 > > >>>>FAX: 315-797-8024 > > >>>>EMAIL: [email protected] > > >>>> > > >>>> > > >>>> > > >>>> > > >>>> > > >>>>> -----Original Message----- > > >>>>> From: Jim Eichner [SMTP:[email protected]] > > >>>>> Sent: Monday, October 02, 2000 8:00 PM > > >>>>> To: 'EMC-PSTC - forum' > > >>>>> Subject: Standards hierarchy > > >>>>> > > >>>>> > > >>>>> As relates to the EMC Directive, I am trying to straighten out > > >>>>my thoughts > > >>>>> re the different classes of standards. I'll say what I thought > > >>>>was right > > >>>>> and then ask my questions and ask for comments: > > >>>>> > > >>>>> What I thought until now: > > >>>>> > > >>>>> 1. Basic - underlying standards that have no force themselves but > > are > > >>>>> there > > >>>>> to provide test methods and limits or performance criteria for > other > > >>>>> standards to call out, so that a large number of other standards > > don't > > >>>>> have > > >>>>> to repeat and maintain this common material. > > >>>>> > > >>>>> 2. Generic - standards used in the absence of 3 or 4, that define > > the > > >>>>> required tests and set limits, and may make use of Basic standards > > for > > >>>>> methodology. > > >>>>> > > >>>>> 3. Product Family - standards that have a scope that covers a > > >>family of > > >>>>> related equipment, and are mandatory and sufficient only in the > > >>>>absence of > > >>>>> 4 > > >>>>> below; they define the required tests and set limits, and may > > >>>>make use of > > >>>>> Basic standards for methodology. > > >>>>> > > >>>>> 4. Product Specific - standards that cover a narrowly > > >>defined, specific > > >>>>> type > > >>>>> of equipment, and are therefore mandatory if your product falls > > >>>>within the > > >>>>> scope; they define the required tests and set limits, and may > > >>>>make use of > > >>>>> Basic standards for methodology. > > >>>>> > > >>>>> Hierarchy: I thought the situation was that > > >>>>> a) you use a Specific standard if there is one, then if not > > >>you go for a > > >>>>> Family standard, and finally, failing that, you go for the Generic > > >>>>> standards > > >>>>> b) if you have a Specific a standard applicable to your equipment, > > the > > >>>>> Family and Generic standards have no force, and the Specific > > standard > > >>>>> gives > > >>>>> you full presumption of conformity even if it leaves out or > > >>contradicts > > >>>>> requirements in the broader standards > > >>>>> c) if you have a Family standard applicable to your equipment, > > >>>>the Generic > > >>>>> standards have no force and the Family standard gives you > > presumption > > >>>>> without using the Generics. > > >>>>> > > >>>>> Any comments on the accuracy of items 1-4 and a)-c)? > > >>>>> > > >>>>> My specific question relates, of course, to harmonic currents > > >>>>(collective > > >>>>> groan). The product specific standard in question is > > EN50091-2:1996, > > >>>>> which > > >>>>> covers EMC requirements for UPS. The scope section states that > the > > >>>>> standard > > >>>>> "will take precedence over all aspects of the Generic Standards > and > > no > > >>>>> additional testing is necessary". The omission of a > > >>statement that the > > >>>>> standard takes precedence over a Product Family standard started > me > > >>>>> thinking > > >>>>> that my assumption b) above is wrong in saying that Product Family > > >>>>> standards > > >>>>> have no force. > > >>>>> > > >>>>> If this is a Product Specific standard, and assumption b) above is > > >>>>> correct, > > >>>>> I am under no obligation to look at EN61000-3-2 which is a > > >>>>Product Family > > >>>>> standard. I suspect my assumptions are wrong, and EN50091-2 takes > > >>>>> precedence over the Generics but not any Product Family > > >>>>standards that may > > >>>>> apply and therefore I need to meet EN61000-3-2. > > >>>>> > > >>>>> My confusion is escalated by the outdated info in EN50091-2, > > >>which has a > > >>>>> section on harmonics wherein it says "If the application is within > > the > > >>>>> scope > > >>>>> of EN60555-2, the limits and test methodology shall apply" > followed > > by > > >>>>> "Note: This subclause is under consideration pending revision of > > >>>>> EN60555-2:1987". The combined effect of those two quotes > > >>seems to be to > > >>>>> allow me to ignore EN60555-2:1987 (which is obsolete anyway). > > >>>>> > > >>>>> The comments of the group are greatly appreciated, as always. > > >>>>> > > >>>>> Thanks, > > >>>>> > > >>>>> > > >>>>> Jim Eichner > > >>>>> Sr. Regulatory Compliance Engineer > > >>>>> Mobile Markets > > >>>>> Xantrex Technology Inc. > > >>>>> Email: [email protected] > > >>>>> Website: www.xantrex.com > > >>>>> Any opinions expressed are those of my invisible friend, who > really > > >>>>> exists. > > >>>>> Honest. > > >>>>> > > >>>>> > > >> > > >> > > >> > > >> > > >> > > >> > > >> > > >> > > >>------------------------------------------- > > >>This message is from the IEEE EMC Society Product Safety > > >>Technical Committee emc-pstc discussion list. > > >> > > >>To cancel your subscription, send mail to: > > >> [email protected] > > >>with the single line: > > >> unsubscribe emc-pstc > > >> > > >>For help, send mail to the list administrators: > > >> Jim Bacher: [email protected] > > >> Michael Garretson: [email protected] > > >> > > >>For policy questions, send mail to: > > >> Richard Nute: [email protected] > > >> > > >> > > > > ------------------------------------------- > > This message is from the IEEE EMC Society Product Safety > > Technical Committee emc-pstc discussion list. > > > > To cancel your subscription, send mail to: > > [email protected] > > with the single line: > > unsubscribe emc-pstc > > > > For help, send mail to the list administrators: > > Jim Bacher: [email protected] > > Michael Garretson: [email protected] > > > > For policy questions, send mail to: > > Richard Nute: [email protected] > > > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > [email protected] > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: [email protected] > Michael Garretson: [email protected] > > For policy questions, send mail to: > Richard Nute: [email protected] > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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