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: dan.kin...@heapg.com Website: http://www.heapg.com > -----Original Message----- > From: Michael Mertinooke [SMTP:mertino...@skyskan.com] > 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: 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
