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In article <[email protected]>, Peter L. Tarver <[email protected]> writes >I realize you're trying to write in an example, but Ruritania isn't >identified on the Europa web site as a member country of the EU, nor is >Ruritania identified as a candidate country; neither does the CENELEC >web site state so. Ruritania is a fictitious European country, created by Anthony Hope the author of 'The Prisoner of Zenda' (Go to http://www.bibliomania.com/0/0/25/53/ for example.) I use it deliberately so as not to imply that a comment applies to any particular real country, since that can create greater confusion. > >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'. >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. > >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. > > [snip] > OSM decisions >> are NOW publicly available on the Web; the former >> position where the >> access to them was restricted was indeed unsupportable. > >True, that in the last few months, they've become available on the web, >completely removing my previous complaints from the picture; keep in >mind that was a relatively recent feat. I entirely agree: I began to pursue this issue in UK about five years ago, and I'm sure I was not the first to do so. >However, certain of the OSM >Decisions are not documented in *any* annex of EN 60950 or EN 60950-1, >but have been applicable for a relatively long time. I provide an >example in my anecdote posting. There is now (too late, you will say, with some justification) a specific procedure whereby OSM decisions are considered by the relevant committee responsible for the standard and either adopted (possibly in a modified form) in an amendment or issued as an official Interpretation. In a few cases, other resolutions are possible. This applies both in CENELEC for OSM decisions and in IEC for CTL decisions. -- Regards, John Woodgate, OOO - Own Opinions Only. The good news is that nothing is compulsory. The bad news is that everything is prohibited. http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. IEEE PSES Main Website: http://www.ieee-pses.org/ To post a message send your e-mail to [email protected] Instructions for use of the list server: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html 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] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
