Dave,

Firstly you need to decide what EU directives apply.  This may sound a little
obvious, but the LVD (for example) excludes equipment from its scope if these
are covered by other regulatory provisions.  Such considerations could apply
to your military and aerospace products. The same would also apply as regards
to the voltage limits of the LVD, i.e. if the input or output voltages were
below 75 Vdc (50 Vac) - or above 1500 Vdc (1000 Vac) - then the LVD is not
applicable.

Presumably, it is Racal Instruments that is supplying these items as stand
alone 'equipment' rather than the parent ATE vendor.  As such, it is your
responsibility to make sure that your products are safe and that if the safety
of your products depends upon some expected feature of the parent ATE then
that is made known to the user of your products.

It is perhaps instructive to consider a couple of simple products that are
considered to be examples of 'equipment' that should be CE marked according to
the LVD: one is plastic conduit and another are mains couplers (e.g. EN 60320
type - but not mains plugs which are specifically exempt). 

Your products sound as though they probably need to offer at least the same
level of safety as the above examples and it therefore seems logical that your
products are also covered by the LVD.  As such, they should be CE marked and
you should prepare and maintain a suitable declaration of conformity and
technical file.  

As regards the EMC Directive, I would have thought that a function of your
equipment could be to maintain the shielding effectiveness of some
interconnecting cable or other, and perhaps to ensure that measures were
provided to prevent cross-talk between paths carrying high frequency signals
(or power) and other I/O lines.  Perhaps this is not an issue with the
existing EMC directive (?), but surely it an item that will be covered with
the revised EMC Directive?

Best regards,

Richard Hughes
Safety Answers Limited

In a message dated 11/11/2003 09:51:20 GMT Standard Time,
[email protected] writes:




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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