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
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