Dave,
You've got my attention on item 4, but still confused. Agreed there is
no requirement for a Korean lab in the CB report, but as you also point out it
has nothing to do with meeting the Korean national requirements. So it seems we
agree that this can't be the full path to conformance from a Korean perspective.
The issue now seems to be whether or not a non-Korean lab can provide
data satisfactory to the Koreans.
With every regulation and test house that I come into contact with the
word has always come back the same. Korea wants a Korean lab, and about the
only exception I can think of is KTL in Ottawa and I made them show me the
documents that allow them to do so. They have had for a while the ability to do
the radiated portion, but they did not until very recently have the same
ability for the immunity requirements. The net effect was that the equipment
still needed to be shipped to Korea.
My prime vendor for this would love to be able to provide that service
but after much checking into the regulations on his part, including direct
query with the Korean the best he could offer was to do the project management
for it, ship the product, pay the fees, and act as an intermediary. As you can
imagine he and I occasionally may have discussions about interpretations of the
regulations etc, but I have a very high regard for his ability to either
provide sound factual information or in this case, research it and respond.
(Don't tell him this part he'll just raise my rates :) )
The same data came from other vendors as well. Now this is for ITE, buy
the way, I do believe that for telecom stuff Korea has signed the MRA's both
government to government and industry specific.
Obviously it is pretty hard to argue with success so if you are telling
me that you can go to your local EMC NIST approved lab with ITE equipment, get
the test done locally and submit only the test report I am all ears.
We aren't able to send folks to the various governmental symposiums so
I do rely on knowledgeable vendors, but would be happy to hear the information
is wrong. I suspect my main vendor would love to hear it as well. Taiwan
requires test reports, but that data can come from US Labs. Are you sure you
are not confusing the two.
Gary
-----Original Message-----
From: Clement Dave-LDC009 [mailto:[email protected]]
Sent: Thursday, August 08, 2002 1:26 PM
To: EMC-PSTC (E-mail)
Subject: RE: Korea Deviation to IEC60950 CB report.
Seems strange that the IECEE allowed an EMC requirement to be added as a
national deviation to a Safety Standard, but they did, and it's even more
bizarre that Japan has the same deviation and has no national mandatory EMC
requirement. But anyway;
There is no requirement that to meet the requirements for the Korean
deviation in a CB report that the EMC report must come from a Korean lab.
Also, having a CB safety report that shows the EMC deviation as passing has
nothing to do with meeting the Korean national requirements for EMC. So in
actuality there is a 4th option.
4- Have an EMC report from any recognized lab - Pass
I routinely obtain CB reports from UL, CSA or TUV that meet this requirement
with a CISPR test report from our OATS.
Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:[email protected]
http://www.motorola.com/globalcompliance/
-----Original Message-----
From: Gary McInturff [mailto:[email protected]]
Sent: Thursday, August 08, 2002 12:52 PM
To: EMC-PSTC (E-mail)
Subject: Korea Deviation to IEC60950 CB report.
Korea - Differences to IEC60950, Third Edition (1999)
7 Addition: EMC. The apparatus shall complies with the relevant CISPR
requirements
As I understand it there are three options for this deviation.
1 - Have a Korean Test Report - Pass
2 - Don't have a report - Fail
3- Write a letter to the CB author stating you meet the requirements
- pass
Seems to be a particularly interesting case of circular reasoning
going on here.
Korea requires test data from a Korean approved lab to be submitted
to them for EMC approval.
Basic property of approval is that one meets the EMC requirements as
demonstrated by a test report from a Korean authorized laboratory and also
meets the Safety requirements as documented in a CB report. Most often these
documents are obtained from different companies, but all nicely bound in one
documentation bundle by the manufacturer when they submit for Korean
acceptance.
Assume one has Korea as a market then this section in the CB report
makes no sense.
For the first option Korea already requires that one verifies
emissions with a test report from a Korean approved laboratory and
presumably they read it or at least check it off their bureaucracy forms
when it arrives. The equipment still can' t be imported until they see a CB
report they accept. If they have the emissions report and the CB report in
front of them then the first condition of this requiring the safety
evaluator to confirm that they also have a copy of this report is
non-sensical. In fact I suspect that as proof they have done their job the
safety evaluator would include as an appendix a copy of the emissions
report. So know the Korean officials have two copies of the same report.
For option 2, Either one doesn't have Korea as a market and is not
interested in meeting any of their deviations so the clause isn't needed, or
they are interested, have the report, and send it to CB author. So now we
are back to circular reasoning item 1.
Option 3 may be my favorite. They authorize only a few labs to
submit data. The only reason to require a Korean certified lab test is that
they don't trust manufactures when they simply tell them the requirements
are met. On Its own that is not an unreasonable request, independent
verification of test results is always better than just trusting the
manufacturer. But now in the CB report, that as I noted before either
provides a copy of the emissions report as an annex or amendment to the CB
report because of circular reasoning item 1 or Circular reasoning item 2
comes into play, and defaults to item 1. But if either of those two useless
clauses isn't enough now there is a third option. Just write a letter that
says trust us. It will be included in the CB report as an appendix or an
annex. Of course this letter doesn't make any sense either because they
require along with the CB report, a test report from a previously Korean
approved lab. This requirement is because they !
obviously don't trust a manufacturer to just say they meet the requirements.
And back to useless option 1.
What am I missing here? Seems like its time to break out the old
Fecalencephalometer ( a large painful instrument intended to measure just
how far your head is up your rear end!
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