http://www.ieee-pses.org/symposium
          http://www.emc2004.org/


It appears that using harmonized standards for a "presumption of conformity"
to the LVD is not the only route to compliance.  Article 8 and Annex I of
that directive appear to provide an "essential requirements" route similar
to that available in the EMCD.

A technical file (perhaps more accurately, a TCF) is put together by a
manufacturer and then audited by a Notified Body.  (exactly as you would do
in order to claim compliance with the protection requirements of the EMCD
using a Competent Body).  The employ of a certified body is thus necessary
and proper in this case to ensure the safety objectives of the LVD are
satisfied.

This seems a reasonable approach, particularly so for industrial equipment,
and it may alleviate the necessity of retesting and reissuing a DofC ever
time a harmonized standard is revised.

This approach wouldn't please all customers, however, and so a manufacturer
might be pressured to update their DofC and test reports regardless.

This is a point I wanted to raise at the PSES symposium, but I could not
find an appropriate moment.

Comments from the group?


Ralph McDiarmid, AScT
Compliance Engineering Group
Xantrex Technology Inc.



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