Ed, All,
 
DEF STAN 59-41 has been/ is being revised to DEF STAN 59-411- It is intended
to publish DEF STAN 59-411 in the late autumn of 2006, Part 3 Issue 1 Draft
was to be posted on the DStan website ( <http://www.dstan.dii.r.mil.uk/>
http://www.dstan.dii.r.mil.uk/) for general public comment around August.  
 
Regards
 
Tim

  _____  

From: [email protected] [mailto:[email protected]] On Behalf Of Price, Ed
Sent: 17 October 2006 02:07
To: IEEE EMC Discussion Group
Subject: RE: CE Marking for Military equipment


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From: Doug Beckwith [mailto:[email protected]]
Sent: Monday, October 16, 2006 12:23 PM
To: [email protected]
Subject: CE Marking for Military equipment

Hi All,
Can anyone provide some information or a pointer to some information on CE
marking of Military equipment. We have a product that is going to be sold in
the EU, and it is used by both Military  and police forces. The question has
come up regarding the CE marking requirement.

Regards

Doug Beckwith


The problem starts from the fact that the military buys as if it is an "expert
customer", that is, they use a contract system to specify every detail of
performance and reliability. The contractual relationship takes precedence
over any standard or practice, so the thinking goes that "if it isn't in the
contract, it's not applicable." Equipment bought commercially off-the-shelf
imposes considerable usage restrictions on the military (because the military
operational environment is so harsh), so you have to be very careful about
integrating COTS into that environment. For instance, commercial hiking boots
might be really nice, but what about their resistance to jungle rot and sole
penetration, and what about the infrared signature of the material?

Asking for military gear to also be CE is interesting, as there isn't any
Military Directive. <g> OTOH, the customer can ask for anything, and they can
contractually try to invoke it. If your contract invokes DEF STAN 59-41, and
then says that the equipment should also be in compliance with any relevant
civilian standards for the country of use, then you just may have to provide
evidence that the product meets the intent of the Low-voltage, EMC, Machinery,
pressure vessel, radhaz, etc directives.

The amount of risk involved is hard to predict. The least stringent military
standard levels are often much more rigorous than the equivalent commercial
requirements. OTOH, there are some commercial tests that are not required by
the military, so asking for CE does pose some additional engineering risk.

Much could be simplified if the extant military standards better addressed
COTS procurement. In the USA, our MIL-STD-461E barely addresses COTS; perhaps
this will change with the upcoming Revision F. The British MoD now does a
better job with their DEF STAN 59-41, Part 3, Section 2, which addresses
military use in a civilian environment. Still, here's a fun quote from that
document:

The procedures and limits outlined within this Section produce tests which are
generally more stringent than those evoked by the European Directive
89/336/EEC. These reflect the harsher environment in which military support
equipment will operate. It is not permissible or acceptable to compare or
cross reference test results from Euro Norms or Commercial Specifications with
the procedures and limits contained within this Section.

This quote seems to be saying that there may be no COTS, because even the
military support environment is harsher than the civilian environment. But
it's only sane that we admit that the military has a large percentage of
"civilian office environment" usage. The photocopier and the coffee maker in
the Colonel's office shouldn't need to be a single bit different than civilian
quality.

Of course, if you sell commercially in the EU, even if it's only to municipal
agencies (like police or fire or paramedics), then you definitely have to meet
the civilian requirements.

 

Regards,

Ed Price
[email protected]
NARTE Certified EMC Engineer & Technician
Electromagnetic Compatibility Lab
Cubic Defense Applications
San Diego, CA  USA
858-505-2780 (Voice)
858-505-1583 (FAX)
Military & Avionics EMC Is Our Specialty
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