Just throwing this out there - how about Safety and EOL (End of Life). Let’s
see quarterly inspection. Recertification (CB SCHEME) certs every three years,
possible re-evaluation even though nothing has changed. More money spent. 
What’s the difference between this and EMC? Maybe I am missing something. In
many cases the potential for EMC profile changes are greater due to the newer
technologies and obsolescence of digital components. Yet no need to control
EMC performance with the exception of the good honest integrity of most
Regulatory Compliance (EMC) personnel/departments. Why is it different for
Safety? Safety people have just as much integrity? 

Thoughts?

 

Regards,

Mark

 

From: [email protected] [mailto:[email protected]] On Behalf Of
[email protected]
Sent: Tuesday, June 15, 2010 1:08 PM
To: [email protected]
Subject: Re: [PSES] EMC Performance Changing With Age Of Product

 


Even if it were found necessary to control EMC performance of a product over
its functional lifetime, I don't see how that could be done in practice.   If
it were common place that older electronic products became a RF nuisance,
surely they would be evidence by an abundance of complaints to the
authorities.   Electrolytic capacitors and solder or mechanical connections do
fail over time, but I suggest when they do the device likely also fails to
function and is taken out of service.    The apparent lack of legal control of
EMC of products over their service life may simply indicate that none is
warranted. 
_______________________________________
_____________________________________________ 

Ralph McDiarmid  |   Schneider Electric   |  Renewable Energies Business  |  
CANADA  |   Compliance Engineer




From: 

John Woodgate <[email protected]> 

To: 

[email protected] 

List-Post: [email protected]
List-Post: [email protected]
List-Post: [email protected]
Date: 

06/15/2010 03:44 AM 

Subject: 

Re: [PSES] EMC Performance Changing With Age Of Product

 

________________________________




In message 
<[email protected]>, dated 
Tue, 15 Jun 2010, "Pawson, James" <[email protected]> writes:

>EMC performance of a product is likely to vary with age as the physical 
>characteristics change e.g. caps dry out, metal junctions oxidise, etc.
> 
>Obviously the product is designed with the intention of consistent 
>compliance over the life of the product, but are there any requirements 
>or guidance relating to preventing or controlling this change in EMC 
>performance over time?

Americas or Europe? I don't want to comment on the Americas position. 
For Europe, there seems to be an on-going problem that no-one wants to 
resolve, at least in some countries.

For example, in UK, the Wireless Telegraphy Acts (WTA) used to apply 
legal controls to sources of interference, regardless of the age of the 
product or anything else. When the (second) EMC Directive was 
introduced, applying to products in general, not a specific range, those 
parts of the WTA seem to have been repealed.

However, the EMC Directive applies requirements to *manufacturers 
(and/or their agents)* only. It isn't helpful to ask whether the 
Directive applies to newly-sold products or throughout their life. The 
requirements for manufacturers can only possibly apply *while the 
product is under the manufacturer's control*. It is reasonable to hold 
that the manufacturer must not neglect the reliability of any parts that 
affect EMC, but it is not possible to ensure that a given part will not 
fail very early in life. It is also not possible for the manufacturer to 
control what a user might do to or with the product (e.g. just connect a 
signal generator to an antenna and modulate it with audio).

So effectively there appears to be no legal control in UK of the EMC 
performance of products during their life, and the same applies to any 
other EU state that changed its legislation in the way the UK did.

If anyone believes differently, please respond (politely).
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
I should be disillusioned, but it's not worth the effort.

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