Well said. We do agree.... But the phrase as John used, is used too often to "just self declare" based on "what the designer knows" , or what he assumes. Or his purchase department.
It's just a bit more complex than saying the directive does not oblige to test. The "evidence" part requires a thoroughly written (as I see it) assessment to the essential requirements, what in 99.9 % of the cases leads to new (partial) testing. An assessment that requires a bit more knowledge and experience than counting data ports. - a test standard is not upgraded for nothing: changes are in most of the cases something essential (last 10 years in most of the cases this lead to a higher test frequency) - the references to the basic standards are updated, which may require another test set up - requirements for ports change, are enhanced, of compliance criteria change If you used a certain standard before, complying to the new standard requires testing in most of the cases. If a always a full re-testing is required ? Most of the time not, but in real life customers tend to change many details such as - change clock frequencies - add features. And if the customer is not changing anything, it's the - components that have changed. SMPS chips are updated by the chips manufacturer, most of the time creating more interference, without notification or even part number change. - Microprocessor get pin-compatible upgrades with faster logic on-board, and the old is not available anymore, - PCB stacks change during the ages (due to change of PCB manufacturer), - a new enclosure contains just some plastic parts where metal was used before, - a minor PCB design change (or what one thougth it was) creates ground slots in the ground plane, - a new PCB process fills up ground plane on top or bottom with hash patterns, or the other way around - a plugin power supply has changed (230-12 volt at 500mA : same specs, same performance ain't it ? - software changes (duty cycle changes for display refresh rate for example - a new brand display with touch feature is used (same specs , so same performance ain't it?) - the assembly company changes brands of capactors, filters, VDR or suppresses them entirely ( I know that this should not happen in the ideal world, but I have seen so). In real life most of the design would (after 5 years) not even pass a test to the old standard, let alone to the upgraded standard. And John, data ports do not exist in EMC world, they are (most often) called I/O ports, and their test requirements change with their projected length: less than 3 meters, more than 10 meters or qualifying for outdoor or telecom use. Specs that do change in time, especially conducted emissions for telecom and network ports. Regards, Ing. Gert Gremmen, BSc [email protected] www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. -----Oorspronkelijk bericht----- Van: [email protected] [mailto:[email protected]] Namens John Cotman Verzonden: Monday, September 02, 2013 11:44 AM Aan: [email protected] Onderwerp: RE: [PSES] Retest because of supersded standard? John Woodgate states the legal position entirely correctly (for the EEA, I don't know about Korea): The CE-marking directives (leaving aside CPR) have mandatory Essential Requirements - meeting those is the law, but testing to a standard or standards is not compulsory. Other than in the unusual situations requiring Notified Body involvement, you are free to decide how you demonstrate compliance, and your Technical File must contain sufficient evidence to support the claims you make in your declaration of conformity, which is a legal document. Standards are therefore voluntary, but often extremely useful. Their key benefit is where they provide a presumption of conformity, this greatly assisting any due diligence defence. Continuing to rely on a superseded standard removes that presumption of conformity, but it does not necessarily remove conformity. So any answer that says you "must" retest when a standard changes, or that you "must" comply with a particular standard, is simply not correct in law. What you most sensibly should do is to evaluate the changed standard, and see if its new provisions might affect whether or not you need to do anything. It is good practice for your Technical File to contain a note that you have carried out this evaluation exercise, even if your conclusion is "no action required". An enforcement action cannot be brought on the basis of "not meeting a standard". It can only be brought for "not meeting an Essential Requirement". Test labs will always want you to go down the testing route - a) because that's how they make their money and b)providing a pass/fail test report is a much easier job than having to think about legal compliance. A lab result also only tells you about the sample(s) tested, it doesn't know anything about your control of series production. Commercially, it may well be that the market requires you always to use the latest standards, but that it is a different argument to the legal one. John C -----Original Message----- From: John Woodgate [mailto:[email protected]] Sent: 31 August 2013 16:56 To: [email protected] Subject: Re: [PSES] Retest because of supersded standard? In message <[email protected]>, dated Sat, 31 Aug 2013, "ce-test, qualified testing bv - Gert Gremmen" <[email protected]> writes: >Are you still sure about your new Signature ?? Yes. But I'm now not sure of the point you are making. There is nothing in my post that you commented on which is inconsistent with what you are now posting. Nowhere did I even hint at not needing to justify a decision not to re-test, and 'justify' means providing evidence. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Why is the stapler always empty just when you want it? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- 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 <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]> - ---------------------------------------------------------------- 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 <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]> - ---------------------------------------------------------------- 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 <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
