http://www.ieee-pses.org/symposium http://www.emc2004.org/
Thank you, John. I appreciate your candor. I hope you take the time to read and respond to my (only just transmitted) anecdote. > From: John Woodgate > Sent: Wednesday, August 18, 2004 10:13 AM > > Peter L. Tarver <[email protected]> writes > > > >> From: John Woodgate > >> Sent: Monday, August 09, 2004 11:00 AM > >> > >> Peter L. Tarver <[email protected]> writes > >> > >> >Correct or not, it has been posited to me that > >> the OSM Decisions are > >> >sometimes based on installation code issues. > >> > >> OSM decisions are the results of enquiries by > >> test-houses, manufacturers > >> or *anyone* about the meaning of a standard in a > >> particular situation, > >> or how it applies to a new technique. The object > >> is to have all test- > >> houses across Europe apply the standards in > the same way. > > > >OK ... Some of the OSM decisions are identified > as effective > >for only specific EU member nations and not all member > >nations. Your statement that "all test-houses > across Europe > >apply the standards in the same way," only adds mud to an > >already unclear process. I'd appreciate a little more > >education. > > By 'in the same way' I mean, in this context, > that if an OSM decision > applies only to Ruritania, test houses in every > country will apply it > only to products intended for sale in Ruritania. 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. 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). 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. 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. > >The following statement can be misconstrued. It is not > >intended to offend or disparage. > > > >For all the criticism Canada and the USA have > received for > >including installation code based national > differences and > >national laws (meaning, there are lots of them), > they are, > >at least, not located entirely outside our national > >standards and are duly noted in CB Scheme Test Reports > >(which leads me to conclude they are also in the CB > >Bulletin). > > I'm not quite sure what you mean. National > deviations are included in > Annexes (usually Annexes ZB and perhaps ZC) to > the ENs. 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. 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. Regards, Peter L. Tarver, PE [email protected] 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
