http://www.ieee-pses.org/symposium http://www.emc2004.org/ -------------------------------------------------- Peter, As I'm sure you know, the RTTED is the Telecommunications TERMINAL EQUIPMENT Directive. The device in question is a component, not equipment. Therefore my view is that the RTTED does not apply. I repeat my view that no CE marking directive applies and so this device must not have a CE marking, just as CDs do not and LEDs do not. However, just because there is no CE marking directive that applies to an item does not mean that the item need not meet standards. If the product for use by consumers (e.g. members of the general public) then the General Product Safety directive would apply. This directive would also apply to so called 'migrated' products (see the GPSD for an explanation). It seems unlikely that the product in question would fall under this directive, however. If the equipment is used in the workplace (as would seem likely for this product) then in the UK it must comply with "Health and Safety at Work etc Act 1974" [HS@WA]. Other EU Member States have similar legislation and there are many EU directives dealing with the many aspects of workplace safety: however, this legislation is made under different Treaty Articles and (unlike CE marking directives) the intention here is not to create a free market for the movement of goods but instead is intended to facilitate the free movement of workers. Therefore, the EU directives describe MINIMUM criteria that Member States are free to 'tighten up' if they wish. Now, getting back to the situation in the UK, Section 6(1) of the [HS@WA] requires the following: "It shall be the duty of any person who designs, manufactures, imports or supplies any article for use at work
(A) to ensure, so far as is reasonably practicable, that the article is so designed and constructed as to be safe and without risks to health when properly used; (B) to carry out or arrange for the carrying out of such testing and examination as may be necessary for the performance of the duty imposed on him by the preceding paragraph; (C) to take such steps as are necessary to secure that there will be available in connection with the use of the article at work adequate information about the use for which it is designed and has been tested, and about any conditions necessary to ensure that, when put to that use, it will be safe and without risks to health." Section 6(4) goes on to require: "It shall be the duty of any person who manufactures, imports or supplies any substance for use at work (A) to ensure, so far as is reasonably practicable, that the substance is safe and without risks to health when properly used; (B) to carry out or arrange for the carrying out of such testing and examination as may be necessary for the performance of the duty imposed on him by the preceding paragraph;" Of course, the above are words of laws that are to be interpreted by courts. Naturally the caveat in such cases is that you are advised to consult legal council, but an engineer's view is that it would be a good way of "ensuring, so far as is reasonably practicable, that the article is so designed and constructed as to be safe" would be to check it against applicable standard(s). The 'check' part, if done with sufficient thoroughness would then meet the "carry out or arrange for the carrying out of such testing and examination as may be necessary" requirement. Naturally, this being a component, it requires certain measures to be taken by the component's user that it is safe when installed or, in the words of the legislation, to provide "adequate information about the use for which it is designed and has been tested, and about any conditions necessary to ensure that, when put to that use, it will be safe and without risks to health". All very turgid stuff, but I hope the above has been of some help in further explaining what I think the requirements are, and why they are. This being a Friday, I now leave it for someone else to insert a little levity into our lives in readiness for the weekend... Richard Hughes In a message dated 07/09/2004 19:01:38 GMT Standard Time, [email protected] writes: Since the product has a telecom application and the RTTED removed the lower voltage limitation in the LVD, and since EN60825-2 is in the harmonized standards list for the RTTED... Regards, Peter L. Tarver, PE ------------------------------------------- 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
