Having paid the bills on these for years I can tell you that the safety side 
the other side of the pond has never really inspected to a list safety of 
components (they would charge you based on the number of components they chose 
to control) but they never did a product inspection to see if they were being 
used. They did a process inspection. Once a year, I believe they sent someone 
out to go over my QA process - but they never glanced at the multiple products 
being built. It has some sense to it, but on the other hand if I desire I can 
defeat a process both short term and long term, but if you happen to pick up a 
product they might be significantly different.
The US version of the evaluation only looks at the process up front to be 
comfortable that you can build the same thing twice in a row with some 
repeatability, and that you have any necessary production line equipment, it's 
used, and its calibrated. I don't have any argument with your notes below. I 
would only say that there is a certain sense to the critical components list in 
the safety standards. During that evaluation they are running test trying to 
determine what happens a product type (all computer for example), have a 
history of similar failures. A power supply output component fails short or 
open for example. In fact this is a bit of a critical component within a 
critical component. If the power supply was a recognized component then 90% of 
the testing for hazardous output during failure was done on the power supply 
itself, and UL has a file on that construction and those components that must 
be robust or fail in some mode they determine to leave the rest of the system 
without undo hazard. Since it is a recognized component, they pay those 
factories a visit and inspect to see if the output components are different 
that the original product. They will have a series of components, and their 
alternate components, that reflect the specific testing required. When it comes 
to my end unit 1) I avoid most of the test required to insure a component 
failure won't cause my system to erupt in flames. 2) They compare the model 
number on that power supply to the one I submitted in my end unit (and 
alternatives if I thought ahead), and have some confidence that at least that 
part of the design didn't change from what was tested, and it can be expected 
to react the same way during the short circuit tests etc. Some of the 
components are pretty generic. A PCB is most often characterized only by it 
being UL recognized and its flame rating. If it's not a main power board it may 
not even have the exact  manufacturers name and model number associated with 
it. It will have some mark that allows the inspector to determine that some, 
rather than a specific, recognized manufacture produced the PCB and because of 
that it is more likely than not that the flame rating is the same (or better). 
I don't need to know exactly the clock type, the processor type etc, I short of 
know that if these things fail they are anchored to a component that isn't 
won't propagate flame.
So there is some sense to the critical list for safety things, again maybe not 
all inclusive but better than that stick thing.

UL has altered its course over the years. It used to be that when they showed 
up unannounced they would inspect only what was being built and to which their 
logo was being attached. That meant that if there was nothing being built I 
didn't have to pay them an arm and a leg. They discovered the error with that 
cash flow conundrum and now do process inspections if I'm not building anything 
for which they can be legitimately concerned. A movie project using cellulose 
nitrate for example. If they don't have their logo attach to it they couldn't 
complain that I was building a fire hazard.
Now if I'm not building anything they still stick me with a minimum $800 dollar 
visit. I would like to think the change was part of joining the EU under the CB 
scheme test facility - even if I don't fully appreciate that process method of 
control - being both suspicious by nature and cheap by pure joy I simply choose 
to believe it was another method from taking a buck (ha pence, Ruble, Rupee, 
Kroner,  or Confederate dollar, etc out of my pocket.
Gary

From: Ed Price [mailto:[email protected]]
Sent: Wednesday, March 13, 2013 3:25 PM
To: [email protected]
Subject: Re: [PSES] Critical component in EMC report

Well, just about as I expected, EMC compliance can't be defined by some set of 
"critical components." Everything in a product is "critical", as well as the 
component placement and installation. An inspector can't use a checklist of 
"critical components" to ensure continuing EMC compliance because the EMC 
situation isn't as easy as a component inventory. Even if all the EMC "critical 
components" were present, a re-routed wire or a slight difference in a 
mechanical dimension could make a huge difference. Maybe for something like 
Safety, a list of "critical components" is acceptable (it's better than 
nothing, but I don't think Safety is all that much simpler than EMC either).

Maybe I'm just not seeing the bigger picture, but to me, a component list is a 
pretty poor aid to ensuring any continuing product compliance.

Ed Price
WB6WSN
Chula Vista, CA  USA

From: Bayo Olabisi [mailto:[email protected]]
Sent: Wednesday, March 13, 2013 2:51 PM
To: [email protected]
Subject: Re: [PSES] Critical component in EMC report

What's critical for product safety isn't always critical for EMC - they are two 
compliance domains and 3rd party lab reports treat them as such.

While EMC involves assessment to regulatory limits for emissions (potential for 
interference) or immunity to external interference, product safety tends to 
address potential for electric shock, fire, and other hazards. EMC reports 
document EUT test setups, instrumentation used, etc to assure repeatability of 
test data, product safety reports conversely document critical components, and 
some EUT test setups.

One other point (for US based folks) - critical components are typically 
checked by the certifying agency versus the report during routine field 
inspections post-production, though such routine inspections aren't done for 
EMC.


________________________________
From: Scott Xe <[email protected]<mailto:[email protected]>>
To: [email protected]<mailto:[email protected]>
Sent: Wednesday, March 13, 2013 11:48 AM
Subject: [PSES] Critical component in EMC report

It is common not to have critical component list in EMC reports issued from 3rd 
party laboratories.  Those information are essential to track if the correct 
parts to be used in mass production.  What is main reason not to have it as a 
common practice in the field?

Thanks and regards,

Scott
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