Gert, thanks for your comments. If what you say is true, how do you explain
that the performance standard for b&w cameras has been published in the OJ
under the LVD?

Richard Woods

        ----------
        From:  Gert Gremmen [SMTP:[email protected]]
        Sent:  Wednesday, March 08, 2000 1:48 AM
        To:  [email protected]; [email protected]
        Subject:  RE: CCTV and Access Control in the EU


        Hello Richard,

        I do think that you are going to far in drawing conclusions.

        The requirements in the safety directive and safety standards under
the LVD
        are concerned with dangers (hazards) some equipment may *create* for
it's
        operators (and others...) by using it. The generic safety standard
nor any
        safety standard is concerned by dangers the equipment might present
by not
        operating as presumed. I sensed the latter in your conclusions.

        Said another way (like they do in insurances) dangers that are a
direct
        cause of using the equipment, and not the indirect (consequently ?)
dangers
        are covered.

        The danger by not operating as presumed is the same as not having
the
        equipment at all. We can hardly say that is a danger caused by using
the
        equipment.


        The EMC directive itself, by means of fa and especially the EN
50130-4 does
        present functional demands however. In general all criteria in all
immunity
        standards are concerned with maintaining a minimum level of
operation.

        I would not be very opposite if such conditions were added to safety
        standards, as your customer relies on the equipment to detect any
dangerous
        situation (fire , burglar etc) and a non-functional equipment is
probably
        more dangerous (though possibly not to the operator :<), then no
equipment
        at all. I think however, that this kind of standards go beyond the
        requirements for ce marking, essentially meant to gain access to
community
        markets , not to be concerned about functional quality.

        I can imagine also that certain organizations are concerned with
        functionality and may impose such requirements before adding their
label of
        "quality", or even demanding certain performance levels before
granting
        installation.




        Regards,

        Gert Gremmen, (Ing)

        ce-test, qualified testing

        ===============================================
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        >>-----Original Message-----
        >>From: [email protected] [mailto:[email protected]]On
Behalf
        >>Of [email protected]
        >>Sent: Tuesday, March 07, 2000 10:27 PM
        >>To: [email protected]
        >>Subject: CCTV and Access Control in the EU
        >>
        >>
        >>
        >>As you may know, there are several CENELEC performance standards
for
        >>components of Alarm Systems and more in the works. For example,
        >>EN 50132-2-1
        >>is for black and white cameras for CCTV surveillance systems for
use in
        >>security applications.  The Alarm Systems immunity standard, EN
50130-4,
        >>makes reference to these component standards, but I never
considered
        >>compliance to the performance standards themselves to be
mandatory. That
        >>view has changed.
        >>
        >>Article 2 of the LVD contains a general safety clause which says,
" . . .
        >>equipment may be placed on the market only if  . . . .  it does
        >>not endanger
        >>the safety of persons, domestic animals or property when installed
and
        >>maintained and used in applications for which it was made." On
22-9-1999,
        >>the performance standard for black and white CCTV cameras was
published in
        >>the Official Journal of the EU (OJ) under the Low Voltage
Directive (LVD).
        >>It now appears that "performance" of Alarm Systems is considered
to be a
        >>safety concern.
        >>
        >>I concluded that all of the performance standards for Alarm System
        >>components will eventually be published in the OJ under the LVD.
        >>
        >>Now things get complicated. The LVD applies only to electrical
products
        >>operating above 50VAC or 75VDC. Products operating at 24VAC, for
example,
        >>are not required to comply with the LVD. However, they must
        >>comply with the
        >>General Safety Directive which applies to all products unless a
specific
        >>safety directive applies.
        >>
        >>The General Safety Directive requires that a safe product "does
        >>not present
        >>any risk or only the minimal risks compatible with the product's
use,
        >>considered as acceptable and consistent with a high level of
        >>protection for
        >>the safety and health of persons". These words combined with
others in the
        >>directive leaves me with the conclusion that performance of a
component of
        >>an Alarm System is a safety concern. The directive indicates that
        >>a standard
        >>may be used to demonstrate compliance.
        >>
        >>Do you agree with my analysis?
        >>
        >>Richard Woods
        >>
        >>-------------------------------------------
        >>This message is from the IEEE EMC Society Product Safety
        >>Technical Committee emc-pstc discussion list.
        >>
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        >>
        >><<File: Gert Gremmen.vcf>>

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