>I really think this is beyond sensible. The emission limits have been 
>set, **taking into account that one product is very rarely use in an 
>environment where there is no other product operating and emitting.**

... **taking into account that a single piece of equipment is very rarely used
in (large) numbers together.**

The leakage current issue is much more relevant than you suggest. A single
fault
in a rack of equipment (lost ground = defined test) effectively creates a rack
(assumed metal)
with a touch current equal to the sum of the touch currents of the individual
equipments.

John, while you are in generally well informed and very to the point, in this
issue
you advocate points of view, that may put members of this list and their
customers in legal and technically risky situations.

Please all, be aware that this is a grey area in regulations in the EC
and I must all advice you to be careful when just assemble piles of equipment
in a rack, and put that on the EC market. Read the essential requirements
of the EMCD and LVD, carry out a risk assessment
on EMC and Safety and be "due diligent"  A good TCF may
very well create sufficient protection without (much) testing. 
Some simple measures will almost always be necessary.

And I know John, if you create a rack of equipment the risks are
the same, you are right, but a natural person *has* the right to
live riskfully (is that good English?), but a company does *NOT* have the
right to expose it's
customers to any avoidable risk.

Gert Gremmen
Ce-test, qualified testing



Van: [email protected] [mailto:[email protected]] Namens John Woodgate
Verzonden: vrijdag 30 oktober 2009 8:01
Aan: [email protected]
Onderwerp: Re: certifying overall products vs. certifying individual
constituant chassis

In message <[email protected]>, dated Thu, 29 Oct 
2009, Cortland Richmond <[email protected]> writes:

>Willful ignorance -- choosing to ignore a fact one knew or should have 
>known -- is far from being a defense when questioned on compliance 
>matters.  Would the choice not to test for combined leakage current in 
>a medical device render the a marketer immune who know each part 
>contributed to a level over that permitted?  IMO the same logic applies 
>to emissions. 

No-one is advocating wilful ignorance. I pointed out that the situations 
with safety and EMC are somewhat different. For safety, it may well be 
necessary to investigate temperatures, **whoever** puts the products 
into the rack. With regard to leakage current, the total value of 
current does not depend on whether the products are in a rack or not.
> 
>IMO, even if one is not legally required to test, -- as in the sale of 
>components direct -- one might well find himself in violation of 
>implied warranty of serviceability should a customer find himself 
>forbidden because of emissions to use what we sold him.

I really think this is beyond sensible. The emission limits have been 
set, **taking into account that one product is very rarely use in an 
environment where there is no other product operating and emitting.**

The overall level of emissions cannot possibly be affected by whether it 
was the user or the manufacturer that put a set of compliant products 
into a rack.

-- 
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
Help stamp out intolerance!

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