Following on what I said earlier, the most disadvantaged parts of the industry are the SMEs where the relevant experience, assessment facilities, finance, and, most critically, management understanding, of the problems involved are all very limited - and so they sometimes attempt the DIY approach, with very varying degrees of success.
Therefore, whilst the Compliance 101 (whatever it may be - I don't know) and any similar approach is welcome, I very much doubt that it will actually get to, and be understood by, the vast majority of SMEs (especially those from the Far East), where the management doesn't have the time, or, more importantly, the inclination to get to try understand and deal properly with the issues involved. That is why, unfortunately, I used to (and still do!) take any DoCs/other compliance documentation provided by many of them with very great "mistrust" - and so, for example, I would be very wary of becoming a EU importer of anything that is not supported by 3rd party certification (both for "type-test" and product control). That is not to say that appropriate documentation and control processes cannot be established because it can - but, again, it takes time, effort and, most importantly, effective management understanding and support for that to work. PS: happy to help any UK company (I'm biased - especially with "BREXIT" looming!) and so PM me if you think I might be able to (given that I am now, thankfully, almost fully retired from all that hassle fulltime!). John E Allen Compliance with Experience Ltd (that's what I named the company - with good reason, I consider!) W. London, UK From: John Woodgate [mailto:[email protected]] Sent: 01 February 2017 20:45 To: [email protected] Subject: Re: [PSES] Do it yourself safety reports? Good, but you need the slogan, so people remember. 'Compliance 101' is neutral and boring. It could be DESIGN IT IN! but maybe someone can produce a better one. With best wishes DESIGN IT IN! OOO - Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: John Allen [mailto:[email protected]] Sent: Wednesday, February 1, 2017 8:34 PM To: [email protected] Subject: Re: [PSES] Do it yourself safety reports? This is what the Compliance 101 Track is all about!! Learn more about it and/or how to help at IEEE PSES Symposium - http://2017.psessymposium.org/ IEEE is also reaching out to corporations worldwide. Any support and/or promotion we can get would be great. As Acting President of IEEE's PSES, I'd be happy to talk to any corporation, free of charge about how we can help make Certifications easier and more cost effective. Best Regards, John John Allen | President Product Safety Consulting, Inc. Your Outsourced Compliance Department www.productsafetyinc.com 630-238-0188 On Feb 1, 2017, at 2:24 PM, John Woodgate <[email protected]> wrote: Yes, this is DESIGN IT IN!, and I think everyone here thinks it's the right way to go. But we need to spread the word to CEOs and line managers because, like everything else, it needs setting up, as JA explains below. With best wishes DESIGN IT IN! OOO - Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: John Allen [mailto:[email protected]] Sent: Wednesday, February 1, 2017 8:07 PM To: [email protected] Subject: Re: [PSES] Do it yourself safety reports? I think (from bitter experience over many years!) that one of the biggest problems that the "do it yourself" safety compliance report company encounters is that most people who do that first then try to use the IEC Test Report Forms (TRF), but find that the format and content of those, and what appears to be missing, are fairly incomprehensible to the average development (as opposed to safety test lab) engineer - especially when he tries to match that format up with what is written in the relevant standard(s), because they basically don't match very well in many areas. Met this issue at a number of companies, and so had to virtually dissect the relevant standards (an old version of 60950 and the 3rd edition of 61010-1 in my case, plus bits of a few others) to "reduce" them to logical sequences of questions that the non-test lab engineers could follow and "answer". The nett result was long tabulated lists of questions with simple possible answers of "Not applicable", Complies" or "Unknown at present" - and in each case some supporting evidence was either needed, or then needed to be found (e.g. test data such as temperature rises and so on) and sometimes demanded use of test equipment which they didn't have or couldn't get, or was going to cost a lot of time and money to get.. Development engineers don't like that because it takes a lot of time and (often boring to them) work to understand & answer the questions and to establish the data, and their managers don't like it because it generally takes a lot more time and money than they originally budgeted for. Been there, seen/experienced all that! OTOH, when these compliance exercises are successfully (or otherwise!) completed, then both the engineers and their managers know a lot more about the standards and how to make their next products meet them - and how to avoid making the same mistakes in the future! John E Allen W. London, UK From: Dan Roman [ <mailto:[email protected]> mailto:[email protected]] Sent: 01 February 2017 11:48 To: <mailto:[email protected]> [email protected] Subject: Re: [PSES] Do it yourself safety reports? No need to limit yourself to 60950 either. Specifically for battery operated equipment, you can use a standard like 60335 that has requirements for battery operated appliances. From the Annex use the testing and construction and user instructions from that standard. -- Dan Roman IEEE Senior Member PSES/EMCS/CES [email protected] -------- Original message -------- From: "ce-test, qualified testing bv - Gert Gremmen" <[email protected]> Date: 2/1/17 4:22 AM (GMT-05:00) To: [email protected] Subject: Re: [PSES] Do it yourself safety reports? I agree with John, batteries are the most critical part. Make sure they are properly approved, and use a fuse in their leads. As it's an RF product, I suppose the LVD comes into play by means of the RTTE (RED) directive. So a full qualification is needed. Many aspects do not apply, but the remaining applicable chapters need evaluation. That requires evaluation of the battery, and possibly fire and heat hazards if the power exceeds "limited power levels". (antenna voltage > 50 ?) Documentation, marking and labelling and a proper definition (intended use) is needed. Installation and safety documentation might be needed. If the battery is chargeable and a power supply is included it needs verification of its documentation and needs reinforced insulation, both mechanically and electrically, as the secondary "live parts" are rarely earthed in these type of equipment's and often must be be classified as accessible parts. Plastics need may not propagate fire, and should have the right V Class. More aspects can be applicable..... making your own test report is possible, but I doubt if it will stand up against examination, unless you have done this before... Regards, Ing. Gert Gremmen Approvals manager ---------------------------------------------------------------------------- -------- + ce marking of electrical/electronic equipment + Independent Consultancy Services + Compliance Testing and Design for CE marking according to EC-directives: - Electro Magnetic Compatibility 2014/30/EC - Electrical Safety 2014/35/EC - Radio & Telecommunication Terminal Equipment 99/5/EC Web: www.cetest.nl (English) www.ce-test.nl (Dutch) www.cetest.fr (under construction) Phone : +31 10 415 24 26 ------------------------------------------------------------------- This e-mail and any attachments thereto may contain information that is confidential and/or protected by intellectual property rights and are intended for the sole use of the recipient(s) named above. Any use of the information contained herein (including, but not limited to, total or partial reproduction, communication or distribution in any form) by persons other than the designated recipient(s) is prohibited. If you have received this e-mail in error, please notify the sender either by telephone or by e-mail and delete the material from any computer. Thank you for your co-operation. From: John Woodgate [mailto:[email protected]] Sent: Wednesday 1 February 2017 09:28 To: [email protected] Subject: Re: [PSES] Do it yourself safety reports? If it's battery-powered, the LVD may not apply, so in turn there is no need to apply 60950. But I would advise applying it as far as possible. We don't want more battery fires, so that is one point to look at carefully; can the battery be short-circuited by a fault and if so, what happens? It's certainly possible to do that without a test house, but of course, it has to be done carefully. With best wishes DESIGN IT IN! OOO - Own Opinions Only www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Curtis McNamara [mailto:[email protected]] Sent: Tuesday, January 31, 2017 11:29 PM To: [email protected] Subject: [PSES] Do it yourself safety reports? A client is asking if it is practical to do their own 60950 safety reports for CE. The device is battery powered, low power RF (they would have complete EMC testing done at a lab). Thanks in advance for your suggestions. Thanks for all the great past advice! Curt - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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