A "risk management process" describes how a company management addresses risks 
with their products.
It describes responsibilities and functions and the process of risks, hazards 
and incidents.
The "risk assessment" describes the process of determining risk of a device.
Techniques for risk assessment are Top-down and bottom-up analysis and FMEA . 

Some facts I learned:

1. No risk assessment process will tell you what risks are acceptable or not.
2. The risk assessment will document all risks/aspects you have considered, and 
if carried out
probably allows you to conclude that you did not overlook something: the most 
important conclusion.
3. Techniques as FMEA allow you to rank risks in order of relevance, so as to 
cope with highest risks first.
3b. The order is created by multiplying chance , severity and detectability 
into a arbitrary risk value.
3c. There are not much conventions in valuing those 3 factors and applying 
numeric values to them. Each analysis is engineer specific.
Only the ranking is an objective result. 
4. This ranking allows the risk management engineer to define a arbitrary risk 
threshold value above what any risk needs to be fixed.
5. The result of the full process is a "remaining risks list" that can be 
addressed in educating your customers. (don't dry the cat in the microwave)

If you take a machine directive standard such as the 60204 you can clearly see 
how risk enabled standards interact with the risk management process.


Regards,

Ing. Gert Gremmen
Approvals manager
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From: Nick Williams [mailto:[email protected]] 
Sent: Friday 1 April 2016 00:03
To: [email protected]
Subject: Re: [PSES] EU's new approach directive transitions

David,

The risk assessment you refer to below is not same as the risk assessment 
referred to in the new LVD (and some other NLF directives). The risk assessment 
below is specifically aimed at determining whether or not the product presents 
a risk which is sufficient to warrant post market action, and in particular 
whether or not a product recall is necessary. This is obviously related to the 
product design risk assessment which is required before placing the product on 
the market, but it is not the same thing.

Nick. 




On 31 Mar 2016, at 22:09, David K Bell <[email protected]> wrote:

Scott,
With regard to the risk assessment requirement in the Directives revised under 
the New Legislative Framework (NLF):
This excerpt is from a discussion of the proposed EU Consumer Product Safety 
Regulation (CPSR):
 
The European Commission will undertake a risk analysis of the product to 
determine whether the product is likely to pose a 'serious' risk. The default 
risk analysis methodology to be used is the already established EU Risk 
Assessment Methodology (Decision 2010/15/EU), by which products can be assessed 
and classified as posing a 'Low', 'Medium', 'High' or 'Serious' risk. If this 
risk assessment methodology is not appropriate for the particular product, the 
Commission must give a detailed description of the methodology used in its 
place. 
 
Appendix 5 of Decision 2010/15/EU on pages 33—64 covers Risk Assessment.  This 
is the methodology that a EU enforcement body would use to determine if a 
product poses a serious risk and should therefore be withdrawn from the market 
and notified to other EU member states via the EU RAPEX rapid alert system.  
Any risk analysis that we do to satisfy the requirements of the new LV  and EMC 
Directives should be no less rigorous.

Best regards,

David K. Bell
Senior Regulatory Compliance Engineer
Milestone AV Technologies 
[email protected]
+1.952.225.6782


On Thu, Mar 31, 2016 at 11:35 AM, Scott Xe <[email protected]> wrote:
There are two major changes in new LVD.  One is the risk assessment that is to 
be the obligation for the manufacturers.  The other one is that the DoC is 
required to have object of declaration.

The risk assessment is unclear how to do it and any reference to follow.  
Currently there is few testing laboratories to provide such service to the 
manufacturers.  Hope there is harmonised standard and/or guidance for 
compliance in near future.

Scott


On 31 Mar, 2016, at 1:50 am, Ronald Pickard 
<[email protected]> wrote:

Hi Charlie,
Thank you for your reply along with those linked references. Those ETSI links 
provide projected target dates for approval and availability for the 
new/revised standards being drafted for the RED, which are generally targeted 
to be complete by the 13-Jun-2017 effectivity date for the RED. Kudos to ETSI 
for that work.
 
Best regards,
 
Ron Pickard
Regulatory Compliance Engineer
Compound Photonics 
D | +1 (602) 883-8039
 
From: Charlie Blackham [mailto:[email protected]
Sent: Tuesday, March 29, 2016 11:34 PM
To: Ronald Pickard <[email protected]>; 
[email protected]
Subject: RE: EU's new approach directive transitions
 
Ron
 
Few short answers:
 
•         No sign of that happening at all and I cannot see it happening
•         No, existing Directives are repealed by the new Directives on the 
dates indicated,  but you may wish to look at Recommended format for DoC that 
can reference existing and new 
Directives,http://ec.europa.eu/DocsRoom/documents/14886/attachments/1/translations/en/renditions/native
  (referenced from 
http://ec.europa.eu/growth/sectors/electrical-engineering/emc-directive/index_en.htm
 )
•         ETSI are working hard on updating over 150 standards, some more 
information available:
o   https://docbox.etsi.org/Workshop/2015/201511_RED-WORKSHOP/ for 
presentations from November workshop
o   Work program on radio standards: 
http://webapp.etsi.org/ena/cvp.asp?search=RADIO and a number of RED standards 
have a been published or are available as final draft
o   Work program on EMC standards: 
http://webapp.etsi.org/ena/cvp.asp?Search=emc&Status=&Directive=&submit1=Get+Work+Items
•         Lists of HS for current standards can be used for new Directives 
until new lists are published as per relevant article in the directive such as 
article 27 of the 2014/35/EU LVD.
•         So far I’m aware of:
o   LVD guidance on transition to new 
LVD,http://ec.europa.eu/DocsRoom/documents/13141/attachments/1/translations/en/renditions/native
 available 
athttp://ec.europa.eu/growth/sectors/electrical-engineering/lvd-directive/index_en.htm
o   RED guidance is being worked on, but RED is not mandatory until 2017 so 
there is more time for this.  
http://ec.europa.eu/DocsRoom/documents/11983/attachments/1/translations/en/renditions/pdf
 provides guidance on transitions for equipment moving into and out of 
R&TTE/RED.
•         No one is expecting anything.
 
Regards
Charlie
 
Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
LinkedIn: uk.linkedin.com/in/charlieblackham/
Web: www.sulisconsultants.com
Registered in England and Wales, number 05466247
 
 
 
From: Ronald Pickard [mailto:[email protected]
Sent: 29 March 2016 23:46
To: [email protected]
Subject: [PSES] EU's new approach directive transitions
 
Hi to all, and especially to those that are knowledgeable of the EU’s processes 
on this subject,
 
I know that this subject has been discussed before without resolution, but the 
time is nearing the end of the transition periods of the EU’s new EMC, LV and 
RE directives and I (I’m guessing I’m not alone) was wondering if anyone knows 
what the EU intends to do when these directives reach beyond their respective 
transition periods with no listed harmonized standards?
 
- Will the directives’ transition dates be extended?
- Will a presumption of conformity continue to exist to the repealed directives 
after the transition period?
- What is ETSI’s timeline to revise its harmonized standards to reflect these 
new directives?
- Will harmonized standards under the current respective directives continue to 
be utilized under the new directives (probable)?
- Is there any EU guidance that addresses the above questions? If so, please 
provide a link(s).
- Will the EU pull a rabbit out of its hat at the last moment?
 
Can anyone shed any light on this?
 
I look forward to your reply.
 
Best regards,
 
Ron Pickard
Regulatory Compliance Engineer
Compound Photonics 
D | +1 (602) 883-8039
 
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