Dear Gert, Thanks for trying to answer my questions - I thought your comments are so misleading, at least I would have been fooled if I were not in the profession of regulatory compliance. I thought manufacturers have already taken too much trying to understand what are the routes to comply. Obviously - if the harmonized standards are available, simply following the standards would be sufficient to declare conformity, I believe that's why the standards are there in the first place. Why should we ask manufacturers to comply with "essential requirements" instead of following what standard says.
TCF is only for certain conditions either when there is no harmonized standard available or the standard testing is not feasible to the EUT, etc. even though during TCF assessment, standard procedures should be followed as much as possible. If your comments were not misleading, I thought we should replace all test "standards" with test "guidelines" so that we could be exploring as much "value-added" "essential requirements" as possible and fully instilling our "spirit of immunity testing". As test labs, we must be laughing as we are charging by time, and our manufacturers would never get out of debts. I would like to stop here, no more discussions on this, and you know time is money, once again we are charging you, dear manufacturers, by time Leslie I declare I am running a lab in California and partially own one lab in China. Gert Gremmen wrote:Hi Leslie, some answers: Is this called compliance testing or engineering verification?"Anything that has to do with product quality (like EMI) needs to be addressed in termsof engineering. "Can we do this and declare compliance?" Sure you can declare compliance, as the European System is simply not targeted to complying with standards,but to complying with "essential requirements". Of course you cannot declare compliance withthe standard (to the letter). Using standards is just a way to presumption of compliance. Art 10.1 EMCDIf you really DO deviate from the standard , you will needto follow the TCF route using a Competent Body to show compliance. Art 10.2 EMCD Any deviation of the standard is doomed to art 10.2 , but changing an undefined dwelltime to better meet the intention of the standard won't lead to a law suite. Several product type of standards do address the topic of dwell time btw. One never can get condamned by not following the prescriptions of the EMCD or standard, onlyby creating to much EMI or lacking susceptability (and other essential phenomenae). Gert Gremmence-test-----Original Message----- From: Leslie Bai [mailto:[email protected]] Sent: donderdag 3 oktober 2002 21:37 To: Gert Gremmen; [email protected]; [email protected] Subject: RE: Dwell time for Immunity under EN55024? Gert Gremmen wrote: "....... prescan with Increase frequency step size ! (watch out for resonances) Modify equipment to decrease fault response time (low pass filters ; software ) Build Specifc test features Write specific test software ....." "I am wondering whoelse out there doing these - Is that not sufficient to demonstrate conformity by follwoing standard procedures? What specific test features, what specific test software, are they specifed in the standards? Is this called compliance testing or engineering verification?" "Of course you will be violating the standard;" "Can we do this and declare compliance?" Leslie Bai NARTE Certified Engineer (EMC-002112-NE) www.siemic.com --------------------------------- Do you Yahoo!? New DSL Internet Access from SBC & Yahoo! --------------------------------- Do you Yahoo!? New DSL Internet Access from SBC & Yahoo!
