Rich, As always, you've succinctly provided the full story on an approach that in this case, will work to get Terry's product approved. I think your interpretation of my suggestion of asking "what's the safety concern" is a bit off however.
Personally, I'd rather have a 5 minute conversation first before taking the time to run the tests right away. It's possible the agency rep. may not be all that familiar with the product and so is simply going by the book on default (or what he/she's advised to from more senior staff), thereby eliminating the application of engineering judgment in those areas open to interpretation...a discretionary thing. By asking the question, both parties will bring to light the exact concerns raised in the course of this particular product approval. While it's true that a safety certification agency certifies a product to a given standard, it's the interpretation of that standard's requirements by the parties involved that have raised many an interesting discussion I'd wager. In my own view, engineering judgment is not only to be used by a safety agency rep. when applying the requirements. How else does one raise questions which might result in an interpretive dispute but also deal with such disputes? By the way, the exemption also applies to materials separated by a solid barrier of V-1 or better (60950 ed.2), which might also be the case here....depends on whether the stand-off falls into a "small part" criteria as agreed upon by the agency. My opinion and not that of my employer. Regards, Kaz Gawrzyjal [email protected] -----Original Message----- From: Rich Nute [mailto:[email protected]] Sent: Tuesday, February 20, 2001 10:45 AM To: [email protected] Cc: [email protected]; [email protected] Subject: Re: FLAME RATING OF STANDOFFS Hi Kazimier and Terry: Kazimier suggests asking the question: "what's the safety concern" Unfortunately, safety certification houses do not have the option of accepting products based on the answer to this question. A safety certification house certifies a product to a standard. Supposedly, the requirements contained in the standard make the product safe. In this case, IEC 60950, Sub-clause 4.4.3.2 requires all materials and components be rated V-2 or better. So, the certification house is requiring that the construction comply with the standard. You can't fault the certification house for imposing a requirement explicitly stated in the standard. The small-part exemption cited by Terry only applies to small parts separated from electrical parts by at least 13 mm (1/2-inch) of air. I would guess, from Terry's description and the action of the certification house, that this is not the case. (If it is the case, then you can invoke this sub-clause and the matter is closed.) Fortunately, the standard provides an option of testing. If you test the stand-off for flammability and it is flame-retardant, then your construction is acceptable. Now, instead of proving to the inspector that the material is V-2, you need only prove to the inspector that the stand-off is the manufacturer and "model" number that was tested. If you can't do this, then there is still another test option. You can test a non-flame- retardant standoff. If the resulting fire does not spread within the equipment, then you have proved that the standoff is indeed inconsequential to any fire. If you prove this, then there is no need to control the material. Best regards, Rich ps: Being a long-time certification house basher, I can't believe I've written a message defending a certification house! > Hi Terry, > > Sounds like a discussion with your agency safety engineer might be in order. > It's certain there's a line of reasoning behind the "new" approach taken by > the agency, that you've described below. Question is, since the standard > clauses you've called out make certain allowances, the real issue might > easily be addressed by asking "what's the safety concern"? If the agency > rep. understands your product, your reasoning and it all falls into an area > of interpretation without any blatant standard violations, a certain amount > of engineering judgment might help resolve the situation. > > > My opinion only and not that of my employer. > > Good Luck. > Regards, > Kaz Gawrzyjal > [email protected] > > > -----Original Message----- > From: Terry Meck [mailto:[email protected]] > Sent: Tuesday, February 20, 2001 9:44 AM > To: [email protected] > Subject: FLAME RATING OF STANDOFFS > > > > Hi group! > > I need a sanity check on a `new approach' our safety agency has recently > taken. > > We have an open frame power supply ( has all the certs through the CB report > etc. for EN 60950 UL 1950 ) > > On of the conditions of acceptability is one mounting standoff shall be > insulated. We have this supply in no less then 4 listed products without > any reference to the flame rating of the standoff having to be checked when > the inspector comes in. > I consider that to be reasonable. section 4.4.3.3 UL 1950 has exception: > "gears, cams, belts, bearings and other small parts which would contribute > negligible fuel to a fire;" > > Recently new products have been reviewed and the new procedures require > `traceable 94V-2' standoffs!?!? Which manufacturing engineering says is > difficult to procure a traceable recognized plastic standoff. > > Questions: > Has my fever and pneumonia the past weeks clouded my reasoning? What am I > missing? You place a .5 inch #6 standoff between a V-0 board and a medal > chassis what requires a recognized part except maybe `straining out the > gnats so we can swallow the camel' somewhere else. > > Sick and Tired > Terry J. Meck > Senior Compliance / Test Engineer > Accu-Sort Systems > > > ------------------------------------------- > 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] > > > > ------------------------------------------- > 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] > > > ------------------------------------------- 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]
