Testing and meeting essential requirements. – indeed an interesting combination.
A man goes to a doctor and asks how he can meet his bodies directive that it receives essential nourishment without using his stomach because his stomach ‘changes’, gives him gas and gets upset too often. The doctor says, well, the body never said you had to eat in order to meet its requirement of essential nourishment. You can choose another method if you want it is just simpler to eat than to take another route. It is true that the EMC directive does not require testing. But then one does not test to the directive, one tests to show compliance to a standard which is used to show a device meets the essential requirements of the directive. So, because a mfg used standards to show they meet essential requirements, when those standards that are not mandatory change, does one need to retest? There are two issues really, the first is how a party responsible shows they continue to meet the essential requirements of the directive. Second, if the path used to show meeting the essential requirements has changed (i.e. use of a standard), what are the requirements to show continued compliance to those changes? Remember, it is no longer simply the essential requirements of the directive that needs to be met, but showing how the path chosen is still sufficient to meet those essential requriements. The first is always a requirement and meeting essential requirements is not optional. The second, how that is done, is optional and can and does change. While testing is not required to be used to show meeting essential requirements of the directive, if the party responsible chose and is still using the standards methods to show how they meet the essential requirements, then it is the standard that dictates if testing is or is not (dare I use the word) required. If you do not want to test, then don’t use a test standard. But the options are far more complicated. Generally one of the statements in any standard is something akin to “THE EQUIPMENT SHALL BE TESTED…….” So, if the party responsible is going to continue to use the standards route to show how their device meets the directive, then when a standard changes they must do as the standard says and test in order show how the results in accordance with the most recent standards still meets the essential requirements. If nothing in the standard changed the way a previous test was or was not applied, then no new testing would be required. If however the standard did change in an area that affected test or test limits, then in order to still show how it meets the essential requirements of the directive, retesting would be required. Again, remember that it is not a requirement of the directive, but it is a requirement of the path chosen to use to meet the essential requirements of that directive; and, if you do not test, then you are no longer using the standard as the method to show meeting essential requirements and you must choose another path in order to do that. More simply put, if the party responsible wishes to continue to use a standard to show meeting essential requirements, then when testing or retesting is required, that is what they must do. If they no longer wish to test to a standard to show meeting the directive requirements, they will still be required to show, aside from testing, how the device continues to meet the essential requirements. thanks Dennis Ward Senior Certification Engineer PCTEST This communication and its attachments contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient (s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachment(s) are free from computer virus or other defect. Thank you. From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] Sent: Saturday, August 31, 2013 4:31 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Retest because of supersded standard? John Wrote: >The EMC Directive doesn't demand ANY testing. Maybe, but it demands EVIDENCE of compliance. Annex IV - 1 Two Definitons of "Evidence" Law: The documentary or oral statements and the material objects admissible as testimony in a court of law. Law: information drawn from personal testimony, a document, or a material object, used to establish facts in a legal investigation or admissible as testimony in a law court. The rest of your email witnesses daily practices in factories, but is strictly spoken bad advice. It's a shortcut and if routed without care could have serious consequences. The test labs suggestion is basically right, and the manufacture should prove (to the authorities, not the test house) that the changes in the standard do not affect its product. If the highest test frequency has been changed, the only way of proof is re-testing. If the I/O port requirements have changed and the product has none, the proof is easily constructed as you said. The full assessment includes therefore an comparison between the standards, and a written motivation per test / port if re-testing is required. The assessment may require an expert on EMC, I have seen too many unexpected results. Note that even if port/limits/frequencies did not change, the test method may have been changed due to a modified reference to the basic standards. It’s something that is easily overlooked. If the test house carries a private label (in addition to CE), you probably just have to comply to their requirements Regards, Ing. Gert Gremmen, BSc g.grem...@cetest.nl 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: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate Verzonden: Friday, August 30, 2013 10:47 PM Aan: EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Re: Retest because of supersded standard? In message <617eb8c8634c9149aa66c853d7b8ac5322b70...@ch1prd0310mb392.namprd03.prod.o utlook.com>, dated Fri, 30 Aug 2013, "Crane, Lauren" < <mailto:lauren.cr...@kla-tencor.com> lauren.cr...@kla-tencor.com> writes: >A test lab is suggesting that because EN61000-6-4:2007 will be >superseded in 2014, all conforming products must be retested to the new >standard, even if no changes have occurred in the product. > > > >Is this a fair claim? No; there is no obligation to re-test if you can write an honest EMC assessment (maybe after pre-compliance testing) that the product conforms to the new edition, maybe because, for example, the changes do not affect your product in any way. For example, a new edition of a standard might change requirements for immunity of data ports. If your product doesn't have data ports, it's not affected by the change. The EMC Directive doesn't demand ANY testing. -- OOO - Own Opinions Only. With best wishes. See <http://www.jmwa.demon.co.uk> 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. 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