Nick, Well said, but:
AS the PLC in question might be a component, it cannot be covered using a DofC. Period. A DofI might just as well do the job, and the fact that it has not been defined in the EMC-directive, does not imply that incorporating one is illegal. Furthermore: common sense in fact is the basis of the ce marking system. Lawyers have made the system into a system of laws, but at the top EC-level, common sense is represented by the EC system of due diligence and essential requirements instead of strict prescripted standards and limits. Many European courts cannot handle this properly, and your court example is probably right. You should call for a higher justice (who helps me out with the language) to get your case defended right. Until then ........ you are on your own >;<) 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 Nick Williams >>Sent: Tuesday, March 28, 2000 8:21 AM >>To: Dan Kinney (A) >>Cc: [email protected]; [email protected] >>Subject: RE: EMC - Declaration of Incorporation? >> >> >> >>As an engineer, I have a lot of sympathy with the position taken by >>Mike that the DofI would be a useful document for compliance with the >>EMC Directive (and other directives too). However, the DofI is only >>an available option for compliance with the Machinery Directive. >> >>It's important to remember that we're talking politics and the law >>here, not engineering common sense. There are three routes to >>compliance permitted by the EMC Directive and all require a DofC. >>There is no provision for a DofI under the EMC directive so you can't >>use it as a means of complying with the directive. Period. That's a >>shame, but until there's a change in the law, that's the way it is. >> >>It's all very well applying common sense to areas of the directives >>which are not clear (and god knows there are plenty of those!). >>However, the requirement for a DofC under the EMC Directive is not >>one of them. If you ever found yourself in court trying to defend the >>action you've taken to comply with the directive, imagine trying to >>persuade the court that your judgement was superior to that of all >>the lawyers who wrote the directive, and all those who are now lined >>up waiting to demonstrate how much smarter they are than you. >> >>Sorry if this sounds a bit terse: it isn't meant to be, but it's late >>and I'm afraid I don't feel able to say it in a nicer way without >>undesirable verbosity. >> >>Regards >> >>Nick. >> >> >> >> >>At 10:39 -0500 27/3/2000, Dan Kinney (A) wrote: >>>Mike, >>>Wow - that helps a lot. Thanks for the information. >>>Dan >>> >>>Sincerely, >>>Daniel C. Kinney >>>Lead Qualification Engineer >>> >>>Horner APG, LLC >>>Advanced Products Group >>>640 N. Sherman Drive >>>Indianapolis, IN 46201 >>>Phone: (317) 916-4274 ext. 462 >>>FAX: (317) 916-4287 >>>Email: [email protected] >>>Website: http://www.heapg.com >>> >>> >>>> -----Original Message----- >>>> From: Michael Mertinooke [SMTP:[email protected]] >>>> Sent: Monday, March 27, 2000 10:28 AM >>>> To: 'Dan Kinney (A)' >>>> Subject: RE: EMC - Declaration of Incorporation? >>>> >>>> Dan; >>>> Until 6 minths ago I was working for one of your competitors. >>>> All PLCs were shipped with Declarations of Conformity. The >>>> Declaration of Incorporation actually would be more appropriate, >>>> but we found our customers screaming for a DofC. So fine. We >>>> hired a Notified Body, set up TCFs, and went with DOCs. >>>> >>>> Also please note that the DOI is only mentioned in the >>>> Machinery Directive. This has often been interpreted to mean >>>> that it is only appropriate for mechanical parts. I'm not sure >>>> I agree with that. I think that the rules are not clear for >>>> something like a PLC, which has its own enclosure (and therefore >>>> is a "device") but which does not perform a complete standalone >>>> action (and therefore is a "component"). In this case none of the >>>> rules fit exactly - so I am in favor of using whatever existing >>>> precedents you can find. In this case, DOI would fit the situation >>>> perfectly: the device cannot be meaningfully tested all by itself, >>>> but you need to declare that when properly installed in accordance >>>> with user instructions, the device will meet all the declared >>>> requirements. >>>> >>>> One other point is the ongoing debate about random combinations >>>> of modular products. It is questionable whether the configuration >>>> you tested actually represents the real world. A DOI would sidestep >>>> this whole rathole, whereas a DOC is sort of a gamble. If you declare >>>> absolute conformity with a DOC, how do you know some customer won't >>>> put together a magic combination of modules that will violate >>>> emissions or immunity requirements? Personally, I spent a lot of >>>> test money proving to my satisfaction that I was really and truly >>>> testing the absolute "worst case" configuration for each test. >>>> I shipped with a DOC and a clear conscience, but a DOI would have >>>> made life a lot simpler and cheaper. >>>> >>>> See ya. >>> > Mike Mertinooke >> >>------------------------------------------- >>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] >> >> >>
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