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.
>>>
>>>
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