John,
Thanx, I believed that we were in agreement on this all
along; we've now clarified it in detail.
:>) 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 2:37 PM
To: 'Pete Perkins' <[email protected]>; [email protected]
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU
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] <mailto:[email protected]>
>; [email protected] <mailto:[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
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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.
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