In message 
<[email protected]>, dated 
Wed, 3 Jan 2007, "Tyra, John" <[email protected]> writes

>Agreed John but not every company has or can afford a dedicated Product 
>Safety/ EMC team to work with the designers from cradle to grave..

Of course not. But it isn't vital to have one IF the design team know 
how to design for safety. Besides, a small company needs only one 
competent technician to do some in-house tests (usually easier for 
safety than for EMC), not a team.
>
>Before accepting my current position I was on the other side of the 
>fence as I worked for a large name European Safety Agency for many 
>years. I can't tell how many calls I fielded from manufacturers, with 
>no in house safely engineer, who wanted to know what was required to 
>meet the EU CE Marking requirements and had to ship product in a couple 
>of weeks to meet contract commitments.

Indeed; it was astonishing how long it took for the concept of 'EMC 
Directive' to penetrate some managerial skulls.

>In many cases the caller was stunned at the perceived complexity of 
>what they had to do to show compliance to place a CE Mark on their 
>product. IN most cases I never heard from them again after that initial 
>call and it left me wondering what the did to verify their product was 
>compliant to bear a CE Mark and ship in such a short time 
>frame...........Since they did not have a Safety person involved in the 
>design of the product it is hard for me to believe their product were 
>compliant and ready for CE marking with out some type of modifications 
>being required.

Well, I took a very small firm from ignorance to compliance in one day, 
but it was a special case - a heating product that was technically 
compliant with LVD anyway and there were no EMC issues. All that was 
necessary was to implement a production-line hi-pot test and add the CE 
mark. Plus, of course, compiling a technical file including both safety 
and EMC data.
>
>Certainly the ideal implementation of the CE Mark is the right way to 
>go but what percentage of products which bear the CE mark truly are 
>compliant?? I thought I read an article in the past where a audit of 
>toys shipping with the CE Mark to a particular country showed over 70% 
>had some form of noncompliance and should not have been marked with the 
>CE Mark.

Yes, well, that's toys. The German authorities said last year that they 
found 38% of products that they tested to be non-compliant. This shows a 
great lack of efficiency in selecting products for test - they should be 
finding 99% of the selected products non-compliant. (;-)
>
>Unfortunately with out proper market surveillance as a deterrent I 
>suspect that there are fair amount of products currently being shipped 
>to the EU which have some type of nonconformance and would not be CE 
>Marked.

There is a lot of 'formal' non-compliance, certainly (poor labelling, 
for example). The amount of non-compliance that actually results in 
trouble of some sort seems to be minimal. If it doesn't appear to be 
broke, why break a leg to fix it?
>
>I agree the CB Scheme is a preferred way to require compliance I just 
>question how effective it has been...I look forward to feedback and 
>opinions from our EU colleagues................

CB mostly applies to countries outside Europe, of course, because it 
refers to IEC standards and the corresponding ENs are often NOT entirely 
identical.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Politically unexceptionable seasonal greetings to all.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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