This is a natural reaction - and even an 'Enforcement Officer' in the UK has
produced a book suggesting that you can do a safety review and apply the CE
Marking for safety using only ONE template (which happens to be his
book!!!).

Consider the number of PRODUCT standards written - these reflect the
accepted degree of protection (Operator or User) for each product under
specified operating conditions and accepted uses.

Simplistically USE will change  safety. (Indoor - Outdoor and Underwater
lights). Using the SAME STANDARD approach there is a VERY REAL risk of over
design being forced upon manufacturers and product costs soaring.

More subtle situations exist. We have recently obtained a UL Listing for a
UK product (The First Pocket CDR) - the test lab suggested '065 but I
insisted upon '950 because (amongst other things, the Creepage and clearance
distances between the two standards is not compatible and as a result '950
provides a higher level of protection for the user). There is no issue when
two '950 products are interconnected, but the user safety of the '950
product MAY BE REDUCED if a non'950 product is connected.



AGAIN - consider SHORT CIRCUIT protection and investigation. for a domestic
product the issues are simple - does the fuse blow before the cable melts
and catches fire......


For SWITCH GEAR the issues are significantly different. Do the busbar
fixings survive the stresses caused by adiabatic heating or do the bus bars
rip themselves out of the enclosure and beat the operator to death???!!




It is for these and many other reasons that there are SO MANY STANDARDS.




What I have tried to do in my training courses and material is to teach
engineers, not to generalize, but to think laterally of the potential
problems and issues - that is how to develop the probing - enquiring and
disbelieving mind necessary to become expert in the world of product safety.


Best regards

Gregg





-----Original Message-----
From: [email protected]
[mailto:[email protected]]On Behalf Of Rich Nute
Sent: Wednesday, September 26, 2001 1:02 PM
To: Product Safety Technical Committee
Subject: Re: Applying the appropriate ENs





>   It is the primary end use of the product that dictates the standard(s)
>   required.

Unfortunately, this archaic and provincial view on
the part of standards organizations that standards
should be per product has created problems that
most of us would like to avoid.

Consider product safety.  The safeguards required
for protection against electric shock, for example,
are independent of the product.  Although we have
product standards for hair dryers and for computers,
the requirements for safety are common.

Rather than address products, safety standards need
to address hazards.

While the products I deal with are computer
peripherals, I had the opportunity the other day to
attend a seminar on insulation diagrams used for
medical products.  The interesting fact is that the
seminar did not address anything unique to medical
products.  Rather, it addressed a tool --
insulation diagrams -- that is equally applicable
to my products and all other products where
protection against electric shock is required.
Indeed, the insulation diagrams of some of my
products are identical to the medical product
insulation diagrams presented in the seminar!

(For the purposes of electric shock, the only
differences between a computer peripheral and a
medical product are the limit values used for the
various parts of the equipment.)

I would like to see safety standards based on the
hazards.  I would like to see separate, independent
safety standards for electric shock, electrically-
caused fire, thermal injury, moving parts (kinetic
energy), etc.

(Note that the USA and Canada already have
independent safety standards for x-radiation and
electromagnetic radiations.  These standards are
based on the hazard, not on the product.)

Doing this job is not easy.  If you compare
product safety standards, you will find much in
common, but you will also find differences.  It
is these differences that cause difficulties in
writing a generic safety standard.

Committees are reluctant to discard any
requirement on the basis that products built to
the standard have a good record.

Likewise, committees are reluctant to introduce
a new requirement because it may cost
manufacturers more money in the product design,
and products built to existing requirements have
a good record.

Virtually no one is willing to invest in
research in product safety in order to make
decisions on whether or not a safety requirement
is an effective safety requirement.

There are a few -- very few -- exceptions.  The
basis of IEC 664 (dimensioning of insulation) is
research.  More recently, the CES has published
research data on TV fires.

Our EMC colleagues don't appear to be so hampered.
They have peer-reviewed journals, and annual
symposia reporting on the results of research.

A bunch of IEEE folks are doing their best to set
up an IEEE Product Safety Society.  I would hope
that this society will serve to improve product
safety, to bring it to the same level as EMC.


Best regards,
Rich






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