Having tracked development of the proposed Market Surveillance Regulation, and stared for hours at NLF model language now incorporated in LVD... it is frustrating how ambiguous the actionable criteria are for this sort of thing. Authorities may act on "Risk", but there is no risk assessment standard referenced and no threshold of risk required. So regardless of anything to do with standards, an authority's assessment that there is risk could allow empounding, third party testing etc... all on your nickel. The finding of risk is not 100% precluded by the use of harmonized standards (though it may be lessened).
I also find it interesting that only the EMCD has language requiring keeping pace with the state of the art. Regards, Lauren -----Original Message----- From: Scott Xe [mailto:scott...@gmail.com] Sent: Thursday, July 31, 2014 12:22 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Definition of unsafe product Recently we received a sales ban from an authority. The authority took a sample from the market and appointed a 3rd party laboratory for verification of LVD conformity. They found a non conformance on construction according to the latest version of safety standard and concluded the product is unsafe. The requirement is new in the latest version and did not appear in the previous version. When our product was verified by the 3rd party test house, it complied with previous version of safety standard but was the latest version of the safety standard at time of testing. The new version was issued 2 months later and has an additional construction requirement. The DoW of previous version of safety standard is in 2016. We are at loss how come they consider our product unsafe with the latest version of the standard during this transitional period. Any previous experience to deal with such authority can be shared? It sounds ridiculous charge on our product. Thanks and regards, Scott - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
