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: johnwag...@avaya.com phone: 303 538-4241 fax: 303 538-5211 > ---------- > From: Jim Eichner[SMTP:jim.eich...@xantrex.com] > 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: jim.eich...@xantrex.com > 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:cet...@cetest.nl] > 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: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]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: eric.lif...@ni.com [mailto:eric.lif...@ni.com] > >>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 ..." > >> <cet...@cetest.nl> > >> > >>To: "Maxwell, Chris" <chr...@gnlp.com>, "'Jim Eichner'" > >> <jim.eich...@xantrex.com>, "'EMC-PSTC - forum'" > >> <emc-p...@majordomo.ieee.org> > >>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: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]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: chr...@gnlp.com > >>>> > >>>> > >>>> > >>>> > >>>> > >>>>> -----Original Message----- > >>>>> From: Jim Eichner [SMTP:jim.eich...@xantrex.com] > >>>>> 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: jim.eich...@xantrex.com > >>>>> 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: > >> majord...@ieee.org > >>with the single line: > >> unsubscribe emc-pstc > >> > >>For help, send mail to the list administrators: > >> Jim Bacher: jim_bac...@mail.monarch.com > >> Michael Garretson: pstc_ad...@garretson.org > >> > >>For policy questions, send mail to: > >> Richard Nute: ri...@ieee.org > >> > >> > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com > Michael Garretson: pstc_ad...@garretson.org > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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