If anyone want an EOE version of Geoff Hoones policy statement for the UK MoD then please email me direct.
John Allen From: David Sproul [mailto:[email protected]] Sent: 11 November 2003 22:35 To: John Allen Subject: RE: More CE mark issues... Hi John, Yes you are absolutely correct. The LVD doesn't have any exemptions for military equipment. I was still thinking EMC directive when I responded to Dave's posting. I have written to him to acknowledge my misinformation, and now also feel a little foolish about my sarcastic comments in my original e-mail. I didn't know about Geoff Hoon's reinforcement of civil safety legislation for military equipment, but I do now. Thanks for keeping me right. Best regards, David Sproul From: [email protected] [mailto:[email protected]]On Behalf Of John Allen Sent: 11 November 2003 15:28 To: 'David Sproul' Cc: EMC-PSTC; Coleman, David Subject: RE: More CE mark issues... David S Unfortunately I have to correct you with respect to the LVD - it currently does not have an exemption for military equipment and neither does most (including UK) national implementing legislation. In the UK, the need for military equipment to comply with "civilian legislation" is reinforced by the Secretary of State for Defence' (Geoff Hoon) Safety and Environment policy statement in July 2000, which basically says the military will follow civilian legislation and standards unless there is an overriding operational need to deviate from the latter requirements - and even then the military must operate precautions to ensure a similar level of overall safety (and do the formal Safety Case). Thus my opinion is "CE Mark" it - And it is easier overall than explaining why you did not.... John Allen (ex Racal/Thales, but now) Technical Consultant EMC and Safety Engineering ERA Technology Ltd. Cleeve Road Leatherhead Surrey KT22 7SA UK Tel: +44-1372-367025 (Direct) +44-1372-367000 (Switchboard) Fax: +44-1372-367102 From: David Sproul [mailto:[email protected]] Sent: 11 November 2003 13:21 To: Coleman, David Cc: EMC-PSTC Subject: RE: More CE mark issues... Hi David, I can only answer with my own opinion which will probably be both backed up and refuted by others who may respond. First of all, military equipment does not have to be CE marked, unless that has been changed very recently. However if the equipment has to go to Germany, they apparently insist that electronic military equipment be CE marked. >From your description it would appear that, to your customer at least, your IA is the part of the ATE that they will access most. Although you are not responsible for the safe design of the ATE, unless you are selling it to the customer, (then you share responsibility with the manufacturer) you are responsible for your IA. You must therefore ensure that it is safe for your customers to use. Supplies passing through your IA from the ATE to the customers equipment must be handled in an acceptably safe manner. Since you are familiar with EN 61010 you will be aware of the potential hazards you should protect against. From discussions with individuals from within your organisation I know that your company can be very thorough in their risk assessment, so identifying those risk probably won't be a problem to you either. As you will be aware, a recent string in this group has been discussing when to CE mark and when not. I will dare to suggest that since without the ATE your IA is an expensive paperweight, you need not CE mark it. However, this does not release you from your obligations to ensure it is safe for your customers to use. I hope this has helped. Undoubtedly confusion will still reign when others tell you that they agree with me, while other will suggest that I should find another profession. Best regards, David Sproul From: [email protected] [mailto:[email protected]]On Behalf Of Coleman, David Sent: 11 November 2003 08:36 To: EMC-PSTC Subject: More CE mark issues... My company designs and manufactures ATE systems and components for the Military, Aerospace and Functional test markets. Often what we are supplying is just an interface adapter (IA) that sits between another suppliers ATE and the customers unit under test (UUT). An IA consists of a metal box mounted on the front of the ATE, with I/O connectors on most panels. Whilst it is normally the case that the IA consists entirely of passive components, they do route AC power through to the UUT. From an EMC point of view, as they are passive and a component of a larger system (the ATE), the EMC directive need not apply. The problem is the LVD. Whilst we design and manufacture the item to meet the relevant harmonised standard (EN61010), the safety of the IA is often heavily dependant on the parent ATE (for which we are not the design authority), due to the use of safety features in the ATE (i.e. interlocks etc.) Historically, we have not CE marked these IAs. Are we correct? regards, Dave Coleman Racal Instruments Group ********************************************************************** IMPORTANT NOTICE The information contained in this e-mail is confidential. It may also be legally privileged. It is intended only for the stated addressee(s) and access to it by any other person is unauthorised. If you are not an addressee, you must not disclose, copy, circulate or in any other way use or rely on the information contained in this e-mail. Such unauthorised use may be unlawful. If you have received this e-mail in error, please inform Racal Instruments Group Ltd. immediately by emailing [email protected] or phoning +44 (0)1202 872800 (ask for the I.T. Dept.) and delete it and all copies from your system. www.racalinstrumentsgroup.co.uk ********************************************************************** This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com ************************************************************************* Copyright ERA Technology Ltd. 2003. (www.era.co.uk). All rights reserved. The information supplied in this Commercial Communication should be treated in confidence. No liability whatsoever is accepted for any loss or damage suffered as a result of accessing this message or any attachments. _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com ************************************************************************* Copyright ERA Technology Ltd. 2003. (www.era.co.uk). All rights reserved. The information supplied in this Commercial Communication should be treated in confidence. No liability whatsoever is accepted for any loss or damage suffered as a result of accessing this message or any attachments. _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
