This seems to have become unnecessarily complicated.
If a standard changes, and you do some new testing or evaluation, then updating the D of C to reflect that is quite sensible. Your TF will show the new work done to support it. If a standard changes, and you have a quick look at the differences and decide that it is unimportant (as plenty of amendments are) and there’s nothing you need to do, then there’s no technical reason to amend the D of C. Yes, the presumption of conformity may have gone by not referencing the change, but since you’ve concluded that the actual conformity isn’t affected, then there’s no risk of any enforcement action succeeding. It’s making work to update every D of C to track every standards change, as you’ll also have to put a justification in the TF. You might want a nice new D of C to keep your customers happy, but that’s a marketing matter, not one that you must follow. John ________________________________ From: Robert Heller [mailto:rehel...@mmm.com] Sent: 12 October 2010 10:32 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Updating EU DoC Bear in mind that under the latest EMC Directive, the DoC must contain "dated references" (i.e., the standards tested to and their dates)(see note). If the dates of the standards change then the DoC must be updated. Note: Reference Directive 2004/108/EC, Annex IV, paragraph 2, fourth item. Bob Heller 3M EMC Laboratory, 76-1-01 St. Paul, MN 55107-1208 Tel: 651- 778-6336 Fax: 651-778-6252 ========================= <emc-p...@ieee.org> wrote on 10/11/2010 12:49:27 PM: > From: > > "Kunde, Brian" <brian_ku...@lecotc.com> > > To: > > <emc-p...@ieee.org> > > Date: > > 10/11/2010 12:51 PM > > Subject: > > RE: Updating EU DoC > > Sent by: > > <emc-p...@ieee.org> > > Power is control and control is power and once someone has the power > it is difficult for them to give it up. > > I fought like crazy to not have our DOCs controlled through our > Documentation Control department to avoid many of the problems you > are having. They have to be control somehow but I keep track of them > within our Compliance Department. > > How I was able to avoid ECN control of the DOC is on the DOC itself > I reworded the statement to say; > > “The product herewith displaying the CE marking complies with the > requirements of the……” > > So I argued that the CE compliance is not based on the DOC but on > the CE Marking which is ECN controlled. The DOC just shows what the > CE marking means at the time it was generated. > > As far as the DOC generation, we keep the information on all > products in a database which includes the last audit date and other > information that would appear on the DOC. When we pull up a DOC for > any product, the DOC is dynamically generated with all the > appropriate dates and information. We just print/save it to a .pdf > file and store it in an archive area on our Intranet/network Page > where the Sales/Marketing and Manuals departments have READ access. > I’m the only one in the company with WRITE access to these folder so > only I can change the DOCs. > > We also archive all the old DOCs incase someone wants to pull a copy > of an old version. > > I hope this was helpful. > > The Other Brian > > > From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of > peterh...@aol.com > Sent: Monday, October 11, 2010 11:38 AM > To: emc-p...@ieee.org > Subject: Updating EU DoC > > > Hello group, > > I am looking to see how you folks generate and update your EU DOC. > We use the typical MS Word template and every time there is a need > for an update, we update this document and have to go through ECO > (Engineering Change Order) since it is a controlled document and I > found this process to be very time consuming and not really > efficient in particular when you have over 100 DOC's to maintain. Is > there any easier way? Is there an automated process out there? Do we > really need to have it under control revision? > > Thank you > Peter > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society > emc-pstc discussion list. To post a message to the list, send your e-mail to < > emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at > http://www.ieeecommunities.org/emc-pstc > Graphics (in well-used formats), large files, etc. can be posted to that URL. > Website: http://www.ieee-pses.org/ > Instructions: http://listserv.ieee.org/request/user-guide.html > List rules: http://www.ieee-pses.org/listrules.html > For help, send mail to the list administrators: > Scott Douglas <emcp...@radiusnorth.net> > Mike Cantwell <mcantw...@ieee.org> > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org> > David Heald <dhe...@gmail.com> > _________________________ > > LECO Corporation Notice: This communication may contain confidential > information intended for the named recipient(s) only. If you > received this by mistake, please destroy it and notify us of the > error. Thank you. > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society > emc-pstc discussion list. To post a message to the list, send your e-mail to < > emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at > http://www.ieeecommunities.org/emc-pstc > Graphics (in well-used formats), large files, etc. can be posted to that URL. > Website: http://www.ieee-pses.org/ > Instructions: http://listserv.ieee.org/request/user-guide.html > List rules: http://www.ieee-pses.org/listrules.html > For help, send mail to the list administrators: > Scott Douglas <emcp...@radiusnorth.net> > Mike Cantwell <mcantw...@ieee.org> > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org> > David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com>
