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. _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com ------------------------------------------- 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 ********************************************************************** Copyright ERA Technology Ltd. 2004. (www.era.co.uk). All rights reserved. The information supplied in this Commercial Communication should be treated in confidence. No liability whatsoever is accepted for any loss or damage suffered as a result of accessing this message or any attachments. ********************************************************************** _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com ------------------------------------------- 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

