Yes, manufacturers would be well advised to take precautions not to kill potential customers. Can we rely on them to do that? 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: Pete Perkins [mailto:[email protected]] Sent: Thursday, February 2, 2017 10:36 PM To: 'John Woodgate' <[email protected]>; [email protected] Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU John, et al, My point, which I believe that I made below, is that even for board kits which leave everything out in the open there are techniques to minimize the exposure problems since not all of the users are experienced or fully qualified to know the risks and keep themselves out of harm's way. The manufacturer has the responsibility to provide a device that is easy to use in a 'safe' manner (the definition of which I have expanded to include EMC issues altho not technically safety per se). It's not good enuf to hide behind 'we met all of the requirements' - which were mostly none. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 <mailto:[email protected]> [email protected] From: John Woodgate [mailto:[email protected]] Sent: Thursday, February 2, 2017 9:44 AM To: 'Pete Perkins' <[email protected] <mailto:[email protected]> >; [email protected] <mailto:[email protected]> Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU I'm not quite sure of your point. The thread is about evaluation kits, which are very often just populated PC boards with I/O and power connectors. Everything is accessible, so if the board uses voltages that hurt (which is uncommon but not unknown), you don't touch. Equally, there are no fire enclosures. 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: Pete Perkins [mailto:[email protected]] Sent: Thursday, February 2, 2017 5:21 PM To: 'John Woodgate' <[email protected] <mailto:[email protected]> >; [email protected] <mailto:[email protected]> Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU John, et al, It's nice to look for exemption loopholes but . I would be careful in encouraging too much loosening based upon the skill of the users. In today's environment many engineers and technicians are primarily software folks who are working with hardware to implement systems and these folks do not have the same training or appreciation of electrical hazards in equipment. This comment applies equally to problems arising from EMC interference in applications; we know that there are a myriad of issues arising from the advent of multiple cell towers in operation. Dropped call issues are usually dealt with by modifying software not repositioning antennas or other hardware fixes which are above the technicians pay grade. I include radios generally in this comment because of the widespread use of digital radio equipment and the IoT explosion underway. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 <mailto:[email protected]> [email protected] From: John Woodgate [mailto:[email protected]] Sent: Thursday, February 2, 2017 4:55 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] DoC when exempted from RED 2014/53/EU 'Being safe' with quite a loose interpretation thereof, because the users can be confidently taken to know what not to touch. Similarly for other hazards. 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: Charlie Blackham [mailto:[email protected]] Sent: Thursday, February 2, 2017 11:14 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] DoC when exempted from RED 2014/53/EU Amund Hmmm, as I understand it, the exemption you refer to originates in the New Legislative Framework realignment with reference to provisions in Decision No 768/2008/EC <http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008D0768> Article 4 Conformity assessment procedures 4. For custom-made products and small series production, the technical and administrative conditions relating to conformity assessment procedures shall be alleviated. These exemptions are discussed in the guide to the LVD and draft guide to the RED, but not in the RoHS2 FAQ. The rules on what is and what is not a "custom-built evaluation kit" are reasonably tight, but the product meets the requirements, it should be exempt from all CE marking, though it is of course not exempt from "being safe" regards Charlie _____
From: Amund Westin <[email protected] <mailto:[email protected]> > Sent: 02 February 2017 07:54 To: [email protected] <mailto:[email protected]> Subject: [PSES] DoC when exempted from RED 2014/53/EU Radio equipment not covered by RED 2014/53/EU as Custom-built evaluation kits destined for professionals (Annex I), should they have a Declaration of Conformity? They are exempted from RED, but I would assume ROHS apply. In such a case, should a DoC only cover ROHS listing? I can not find any discussion about such situation in the Blue Guide. Best regards Amund - ---------------------------------------------------------------- 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 <[email protected] <mailto:[email protected]> > 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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[email protected]> > - ---------------------------------------------------------------- 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 <[email protected] <mailto:[email protected]> > 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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[email protected]> > - ---------------------------------------------------------------- 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 <[email protected] <mailto:[email protected]> > 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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[email protected]> > - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
