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> From: John Woodgate > Sent: Wednesday, August 18, 2004 1:26 PM > > Peter L. Tarver <[email protected]> writes > > Ruritania is a fictitious European country, > created by Anthony Hope I forgot to insert my ";)" There are web sites out there that include mimicry of 'official' national web sites, with respect describing treaties, UN membership ... > >More to the point, consider a product intended > to be CE Marked and sold > >in the EU; this implies that it might enter the > market in one EU member > >state, where a distributor is acting as the > importer, and passes through > >customs there. Let us assume the product is > intended for resale and > >installation in other EU member states, without > limiting distribution by > >exclusion of any member state on the basis of > OSM Decision applicability > >(the distributor might be entirely ignorant of > OSM Decision existence), > >as a new product (and all the legalities that > aspect might entail are > >met). > > The distributor might be ignorant, but should not > be. The manufacturer, > however, MUST not be ignorant; this is an aspect > of 'due diligence'. So let us consider, then, that the manufacturer was following what they were led to believe were all the necessary requirements applicable to their product. The manufacturer was working with a well known, long established test house of German heritage, who went so far as to issue a GS License for the product. Germany is one of those states I refer to, above. > >Let us further assume some aspect of the > product's construction > >is impacted by an OSM Decision. Let us assume > further still that the > >OSM Decision was not considered, for whatever > reason, and that the OEM > >made a good faith effort to conform through > third-party testing and > >certification and issuance of a test report and > the OEM makes a MDoC > >regarding the product, based on the standards > approach. No national > >certification marks are obtained or required by > customers, up to this > >point. > > > >When the product is installed and either tested > prior to installation or > >in situ as a part of a continuing compliance > scheme mandated by national > >legislation in the country where the product is > ultimately deployed, and > >fails to meet the legislated compliance > criteria. The product is forced > >out of service, due to the testing. > > Well, this is an extreme scenario, since it > assumes that the non- > compliance discovered is not remediable. Can you > give an example of an > OSM decision that applies to just one (or some > but not all) EU member > states. I think that such OSM decisions are rare. Not so extreme. I give a specific example in the anecdote e-mail for a real world case. the manufacturer had no clue and was relying on the advice of a test houses of world renown ON TWO LEVELS - the power supply and the end product. Examples of OSM Decisions with limited nation applicable (emphasis added): EN 60950:2000 and EN 60950-1:200___ 1.5.1, Varistors across the mains, Pluggable Equipment Type A, Accepted by all countries (when the varistor is separately certified) ***except*** Austria, Belgium, Denmark, Finland, Germany, Norway, Sweden, United Kingdom 2. 7. 1 The maximum rated current in different CENELEC countries for fuse-links inside the equipment are as follows: Pluggable Equipment Type A Denmark 16 A Finland 16 A Norway 16 A Sweden 16 A ***Switzerland 10 A*** United Kingdom 16 A (This one might not count, per se, within the specifics of my proposition, since Switzerland isn't a member of the EU, though they are members of CENELEC.) > >If the OSM Decision were applied this issue > would not have arisen and > >the product would operate blithely to the end of > it's anticipated useful > >life. However, since the route to compliance > did not mandate > >application of the OSM Decision and because the > OSM Decisions, as more > >than one person has stated, are applicable only > to CENELEC member test > >houses, the OEM is completely blind-sided. > > OSM decisions are NOT applicable only to CENELEC > member test houses; in > fact, I'm not sure what you mean by that. OSM > decisions apply to the > *equipment*, which is why manufacturers must be > able to learn of their > existence and provisions without hindrance. As I stated above, the origin of that comment was statements made in this forum that were not contradicted. Perhaps my use of the word "applicable" is at fault. The most recent reference was along the lines of, "only EU test houses apply the OSM decisions," in my response within this thread that the OSM Decision need to be applied. Regards, Peter L. Tarver, PE [email protected] This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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