Hoping this reaches the right eyes. Our comments on the document:
1. In many places, the English is not idiomatic and lays stress
inappropriately, often by incorrect use of the negative or of "does". For
instance "this phenomenon needs not to be considered" means it is compulsory
not to consider it! Sometimes this doesn't matter; sometimes it would have
legal significance. If the English text is to carry legal weight, it should
be edited by a native English speaker to ensure that it does not convey the
wrong meaning; the same applies of course to all the other languages.
2. In annex II section C.1 concerning documentation accompanying a product,
there is the requirement that documents (presumably all of them, including
instruction manuals, declarations of conformity etc. etc.) "have to be
available in one of the official languages of the member state where the
apparatus is to be taken into service ..." I understand the desirability of
this for consumer goods, where it is generally followed today, but for
professional equipment I think it is unnecessarily onerous. A manufacturer
such as Dolby might sell only one or two samples per year of an apparatus
into say Finland or Portugal, and to have to translate and print multipage
documents into those languages would be uneconomic.
3. Article 5 contains a section that states: "Member States shall not impede
for reasons relating to electromagnetic compatibility the placing on the
market and/or the taking into service for its intended use of equipment
conforming to this directive." As you are well aware, states and smaller
administrative areas such as cities are currently impeding installation of
equipment that conforms to the present Emc and low voltage directives,
despite CE marking and accompanying declarations of conformity . I suggest
that this clause should be strengthened to make clear that it applies not
only to national governments but to others as well.
Chris James
Dolby Labs Inc
-----Original Message-----
From: John Juhasz [mailto:[email protected]]
Sent: Thursday, March 30, 2000 3:19 PM
To: '[email protected]'; [email protected]
Subject: RE: EMC Directive revisions
Here we go . . . 'indirect' trade barrier . . . forget Class A.
To whom can we directly raise our concerns (besides product trade
associations)?
John Juhasz
Fiebr Options
Bohemia, NY
-----Original Message-----
From: [email protected] [ mailto:[email protected]
<mailto:[email protected]> ]
Sent: Thursday, March 30, 2000 7:39 AM
To: [email protected]
Subject: RE: EMC Directive revisions
Thanks Brian. I have some very serious concerns about this draft.
Art 3A, 1a: "General" type products appear to have to be able to function in
any EMC environment including industrial. Class A type products just went
out the window since the product must also be able to function in a
residential environment.
Annex II, A1,1: Testing immunity to DC current or voltage on AC
networks????????
Annex II, B.1: Oh great! Now we have to design so emissions are "reduced as
far as possible."
I can just see now that we ship every system is a sealed, welded steel
container.
Annex II B.1.1: and B.2.1: If a standard lists several levels of emissions
and immunity, the product must comply with the most severe limits. They have
to be kidding!
If this is the outcome of SLIM, I would hate to see the outcome of FAT!
Richard Woods
----------
From: Brian Jones [SMTP:[email protected]]
Sent: Thursday, March 30, 2000 4:06 AM
To: EMC-PSTC
Subject: Re: EMC Directive revisions
Ed, Richard, and everyone
Following discussions in the SLIM working group, the Commission has
now
produced a draft of the revised EMC Directive. This is a complete
rewrite,
not an amendment. The major change is removal of the requirement
for fixed
installations to be assessed and CE marked prior to taking into
service, but
the possibility for investigation by enforcement authorities, should
interference be caused, remains. The distinction between "systems"
which
continue to require CE marking, and "fixed installations" is unclear
at
present.
It is expected that the draft will undergo further development and
changes
at SLIM working group meetings during this year before a draft is
published
for comment.
I will be presenting a paper in one of the poster sessions at the
EMC
Symposium in Washington DC, on the latest position.
Best wishes
Brian Jones
EMC Consultant and Competent Body Signatory
-------------------------------------------
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.
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]
