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
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