http://www.ieee-pses.org/symposium http://www.emc2004.org/
-------------------------------------------------- 
Hi Folks
 
Fully agree with Brian's comments, but with some additions!
 
Regarding Q1-Q3, these are quite definitely all the responsibility of the
Design Authority for the equipment - which is typically someone within the
company where the person is located that actually signs the DoC, but not
ncessarily the signatory person.
 
However, the signatory person is legally responsible for making sure that the
technical files and evidence are all in place and valid.
 
There is no way that a test lab can, or should EVER, take Design Authority
responsibility for the design, manufacturing or testing of a product which has
been submitted to it by a client company. They can test equipment and prepare
reports etc., for the Design Authority to include in his technical files, but
there is no way they can exercise any real control over how it is actually
built, tested and documented!
In this respect I have to say that I disagree with Brian: CE Marking
legislation is enacted under criminal law provisions, and there is no way that
you can transfer liability for criminal acts by the exchange of appropriate
contracts (that would be the ultimate "get out of jail" card!)
 
Similarly, a company that builds a product to another company's design
drawings must never sign the DoC even if asked - this issue is addressed in
various guidance from the EU Commission. My previous company fell for this
trick the first time - but not thereafter!
 
Regarding Q4, this is very much country-dependent and authority-dependent.
Some countries do a lot, others do nothing (or virtually nothing) - even
within Europe.
 
John Allen,  
Technical Consultant 
EMC and Safety Engineering 
ERA Technology Ltd. 
Cleeve Road 
Leatherhead  
Surrey KT22 7SA 
UK 
Tel: +44-1372-367025 (Direct) 
+44-1372-367000 (Switchboard) 
Fax: +44-1372-367102 
Please take a minute to visit my web pages at
http://www.era.co.uk/services/rcm.asp  and the main ERA Website at
http://www.era.co.uk


From: Brian O'Connell [mailto:[email protected]]
Sent: 12 July 2004 14:59
To: [email protected]; [email protected]
Subject: RE: Manufacturer / Test Lab / Regulatory Agency responsibilities


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

I am not an expert, but..... 

1. D of C signatory 
2. D of C signatory 
3. Depends on words in the contract with the test house, whether the failure
to comply with applicable standards results in non-conformity, and if the
finding is based on a complaint.

4. Typically not done, unless someone complains 

luck, 
Brian 

-----Original Message----- 
From: [email protected] 
[ mailto:[email protected]] 
Sent: Monday, July 12, 2004 6:45 AM 
To: [email protected]; [email protected]; 
[email protected] 
Subject: Manufacturer / Test Lab / Regulatory Agency responsibilities 

Dear Experts, 

      I request you all to clarify me the following: 

1. Who is responsible for identifying the appropriate EMI / EMC standards 
for a product to comply with, for placing the product in different 
countries. Is it the manufacturer of the product  or the accredited test 
lab in which the product final certification testing is being done and the 
report is being compiled or both? 
2. Who is responsible to ensure that the product is complying with all the 
necessary provisions / sections of a standard. Is it the manufacturer or 
the test lab or both? 
3. What will happen if something is found wrong at a later  date, either a 
wrong standard is followed or the testing is insufficient to prove the 
compliancy with all the necessary clauses of the specified standards? 
4. How the regulatory agencies (FCC / CE  etc.) are ensuring that  every 
product that is placed in the market is complying to the necessary clauses 
of appropriate standards? 

Sincerely 

K.Balasubramanian 
Sr.Engineer, Hardware. 


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