I read in !emc-pstc that Brian Jones <[email protected]> wrote (in
<008a01c1aa69$1c259e80$8441c0c1@oemcomputer>) about 'SV: Generic
emissions - EN 61000-6-3', on Thu, 31 Jan 2002:
>
>John and everyone
>
>I do not wish to get into a semantics argument as to whether the Commission
>has chosen the most appropriate word to describe the subset of standards in
>connection with the new approach, but the special use of the word
>"harmonised" in connection with new approach directives has been employed
>since at least the mid 1980s.
Many misinterpretations or misrepresentations have survived for a long
time until challenged.
> The term has particular relevance in the EMC
>Directive because if harmonised standards are not applied in full, the TCF
>route must be followed (which is not the case with the LVD).
Does that mean, as it seems to, that this 'special meaning' of
'harmonized' only applies to some Directives, then? That is a recipe for
confusion. Maybe this discussion exemplifies that.
I am extremely disappointed to learn that you support this draconian
interpretation ('applied in full') of the existing EMCD, and the
corresponding explicit, and highly controversial, statement in the draft
new EMCD. This insistence on 'full' application has no technical
justification whatsoever, and appears to be motivated by an intention to
drive all SMEs, who cannot afford their own EMC test facility, into the
welcoming arms of the test-houses.
For example, consider conducted emissions. If I do a broadband
measurement and the result is lower than the limits, why should I have
to do a frequency-selective measurement with a CISPR receiver?
If I measure mains harmonics with an audio wave- or spectrum-analyser
and they are below the limits and do not fluctuate significantly, why do
I have to measure with an IEC61000-4-7 instrument?
If my product does not cause a 60 W coiled-coil lamp to flicker, why
should I have to measure with an IEC61000-4-15 instrument?
In each case, the instrumentation, **which has to be designed to give an
'accurate' result (whatever that means) with the most complex 'EMC
signature'***, is extremely costly and cannot be used for any other
purpose. Few SMEs could justify the purchase or even hire, so are forced
to go to a test-house.
>
>Harmonisation Documents (HDs) are not (necessarily) harmonised standards in
>this context and I'm sure their use varies from directive to directive. HDs
>(now withdrawn) were produced for the IEC 801 series, which were basic
>standards.
I don't go along with that semantic argument. Furthermore, my points
were made in relation to ENs, not HDs. But, as it happens, HDs alone
support the very stringent requirements for cables.
>
>In respect of the extra requirements, I have tried to highlight the relevant
>words below as much as is possible with ASCII text. I know this is European
>English. They are the Commission's words, not mine! The final three points
>are the additional requirements.
>
I have already commented on that in my previous post. Nothing you have
added changes my opinion. It is thoroughly unreasonable to say that an
EN is not 'harmonized' when it is identical in all CENELEC countries,
whether the Commission mandated its preparation or not.
What has happened is that someone in the Commission has attempted, maybe
inadvertently, to hi-jack the term 'harmonized' to mean something that
it was not intended to mean.
--
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk
After swimming across the Hellespont, I felt like a Hero.
PLEASE do NOT copy news posts to me by E-MAIL!
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