All, You may want to reach out to the National Committee in your Country, For the US National Committee (USNC), the best point of contact would be Joel Solis at NEMA who serves as the Secretary. They might be able to bring this up at a future CB Scheme meeting and encourage all countries to establish similar guidelines for mentioning alternate components in CB reports.
Brian is correct about the NRTL Program removing component standards from its list of appropriate test standards. The NRTL Program was never intended to include components as it only applies to end products used in the workplace, but over the years, some predominantly component standards were added to the list, and OSHA is in the process of removing those standards. That said, NRTLs will still be allowed to accept component certifications from others when evaluating end products. Kevin Robinson a.k.a The OSHA NRTL Director Guy :-) robinson.ke...@dol.gov On Thu, Apr 30, 2015 at 9:21 PM, Brian Oconnell <oconne...@tamuracorp.com> wrote: > Doug, > > Thanks, will look for this stuff. The only stuff seen to date for > component evaluation is in UL PAGs, CSA informs, and the IECEE CTL stuff. > Are these component acceptance 'guides' part of the National Differences in > a TRF, or regulatory law administered by the state? > > According to the OSHA guy that is the NRTL program director, they are in > process of removing component standards from their official listing (do a > search on the EMC-PSTC listserv archives for his comments). > > Do not understand "Having a CB report is not a foregone guarantee that it > will always be accepted". Do you mean that the TRF was rejected because of > poor component descriptions, or that changes to the C/C table in the TRF > was rejected, or something else? > > Brian > > -----Original Message----- > From: dougp01 [mailto:doug...@gmail.com] > Sent: Thursday, April 30, 2015 5:53 PM > To: EMC-PSTC@LISTSERV.IEEE.ORG > Subject: Re: [PSES] CB Philosophy Questions > > Brian > > I suggest you reference the IECEE website and read through the component > acceptance requirements for each target country, including the USA. I > haven't checked but there may also be such a document for the -2-29 you > mention. These can be found in the same general area as the national > differences documents. Both are interesting reading. If you are not able > to access these contact your certifying agency and they should be willing > to supply copies. > > As for what is typical in each country, I have learned that this is > variable. In general the office tasked with reviewing and accepting your CB > report definitely feels they have the authority to do as they please. And > to a large extent this is true. Having a CB report is not a foregone > guarantee that it will always be accepted. > > Regards, - doug > > Douglas Powell > http://www.linkedin.com/in/dougp01 > Original Message > From: Brian Oconnell > Sent: Thursday, April 30, 2015 6:39 PM > To: EMC-PSTC@LISTSERV.IEEE.ORG > Reply To: Brian Oconnell > Subject: Re: [PSES] CB Philosophy Questions > > In both procedural controls and scoped test standards, North America > (NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar > where state-enforced codes do not contradict the scoped standard. > > It has been several years since the NRTLs and other test agencies have > routinely accepted a blanket 'equivalent' in the C/C table of submitted > reports for all components. Typically stuff such as components that not > across mains, or are not bridging insulation or a safety boundary can be > cited in general terms with no particular mfr name or part no. > > The issue is that the agency assessment engineer cannot be certain which > characteristics of a component are important to something on the C/C table. > So they test your box with the assumption that the design team has verified > performance only for the particular combination of stuff on the BoM and the > board layout that was submitted for assessment. > > The other issue is that there is no formal IEC or SCC or OSHA standard or > regulation that defines how to assess an equivalent component, or whom in > the company shall be the qualified signatory for equivalent item approval > (exceptions for programs such as CSA cat cert and others). > > Do not agree with much of the shenanigans employed by the various agencies > to effectively control market share through pseudo-engineering principles, > but do agree in principle with the reductions in 'equivalent' components > allowed on the critical component table. > > Brian > > > From: Brian Ceresney [mailto:bceres...@delta-q.com] > Sent: Thursday, April 30, 2015 4:09 PM > To: EMC-PSTC@LISTSERV.IEEE.ORG > Subject: [PSES] CB Philosophy Questions > > Greetings, Compliance Experts, > > I'm finding myself in a curious situation, and wondering if you have had > similar experiences, and may have some advice to share. > We are in the process of using a CB report for an industrial battery > charger( to IEC60335-2-29) to obtain an in-country certification in an > Asian country, and have run into an interesting difficulty. > > When our CB report was issued, the engineer was not willing to add wording > to the Critical Components list to allow alternate components(X, Y caps, > opto-isolators) with equivalent ratings and Regulatory Approvals to be > added, with the implication being that this addition was not allowed by the > authorities. > > As expected, two years later, we are going through one country's approval > process, using our CB report, and the national regulatory organization has > decided that the use of a different brand of opto-isolator and X/Y > capacitor is a non-compliance, as they are not specifically in the CB > report. (The electrical, environmental ratings, and the regulatory > approvals are equivalent to the original components). > > a.) Are these attitudes typical in the CB "world"? > b.) Can anybody explain the apparent reticence of CB testing labs to > allow alternate components in a CB report? > c.) Is it likely that a National Body will eventually compromise, and > use engineering judgement in accepting alternate components? Or is this > usually a firm "no"? > > The North American NRTL organizations are proactive in allowing > equivalently rated and approved components to be sourced in a product, and > frequently state this in their reports. IMHO, it seems a bit archaic to not > account for second-sourcing of common off-the-shelf critical components > such as these. > > d.) Is there a philosophical or historical difference between the two > systems(CB and NRTL) that accounts for this difference in approaches? > > Thanks in advance for your attention- your response is appreciated. > > Brian Ceresney > Regulatory Lead > Delta-Q Technologies Corp. > > - > ---------------------------------------------------------------- > 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 <sdoug...@ieee.org> > 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 <sdoug...@ieee.org> > 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 <sdoug...@ieee.org> > 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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
