Maybe Tech Pubs won’t use the word “shall” because plainlanguage.gov says not to:
http://www.plainlanguage.gov/howto/guidelines/bigdoc/writeMust.cfm Jim Hulbert From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Wednesday, June 21, 2017 11:12 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Compliance [General Use] I stand corrected. I use “shall” in our warning statements in our User’s Manual but our Tech Pub people always changes it to “must”. They have their reasons and I’m tired of fighting them on this. But you are absolutely right on this. Hee hee. The Other Brian From: Charlie Blackham [mailto:char...@sulisconsultants.com] Sent: Tuesday, June 20, 2017 4:47 PM To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: RE: [PSES] CE Compliance [General Use] >“but can lead to”, means it does not have to lead to, otherwise it would say, >“but must lead to”. I think it would say “Shall lead to” 😊 The phrase is “This web-address does not necessarily need to directly refer to the document but can lead to a specific Internet address (URL) where the DoC’s are maintained” So, if you don’t provide a direct link to the document, then you can provide a link to the page where they are listed – the guide is saying that you don’t have to provide a specific URL for each individual DoC, but equally you are not meant to just put “Declarations are available from www.ourcompany.com<http://www.ourcompany.com>” This requirement is not new as it was in the R&TTE Directive, and plenty of companies have been providing a single page for years. Regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> Registered in England and Wales, number 05466247 From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: 20 June 2017 21:00 To: Charlie Blackham <char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>>; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: RE: [PSES] CE Compliance [General Use] “but can lead to”, means it does not have to lead to, otherwise it would say, “but must lead to”. Some interpret the Machinery Directive, which has similar requirements for the DoC, to mean that each individual product built must have a unique DoC that lists the product’s specific serial number (or some other unique way of identifying it). So if you built a million products, you would have a million different DoCs on file. This is not practical. So if you literally do what the Directive say, you will have an officer of your company sitting at the end of every production line with a stack of DoC, filling in the model and serial number for each product, signing and dating each, then making a photo copy of each placing one in the box and one in a file cabinet. Or scan the DoC and place an electronic copy on your Corporate Website with some type of search utility so people can find that one and only one DoC for their specific product. Yes, I’m being absurd on purpose. But this interpretation does meet the requirements, does it not? My advice is to find a practical way of providing the DoC to your customers. The Other Brian From: Charlie Blackham [mailto:char...@sulisconsultants.com] Sent: Tuesday, June 20, 2017 3:29 PM To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: RE: [PSES] CE Compliance [General Use] Brian Quoting from the RED Guide<http://ec.europa.eu/docsroom/documents/23321/attachments/1/translations/en/renditions/pdf>: The simplified DoC shall indicate the web-address where the complete DoC can be found. This web-address does not necessarily need to directly refer to the document but can lead to a specific Internet address (URL) where the DoC’s are maintained by the manufacturer enabling a simple identification or search for the relevant DoC. Even if the simplified DoC refers only to RED, the complete DoC located on Internet has to refer to all applicable legislation to the radio equipment This option is allowed as an alternative to shipping a full DoC with the actual product, so the full DoC should be readily available and you should not have to request it. Regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> Registered in England and Wales, number 05466247 -----Original Message----- From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: 20 June 2017 20:09 To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] CE Compliance [General Use] " it shall contain the exact internet address where the full text of the EU declaration of conformity can be obtained" Can I interpret the above to mean that the website only has to include instructions on how to obtain the full DcC and not necessarily a direct link to the electronic copy of the DoC itself? For instance, we have a link on our corporate website where a person can Request the DoC. Doesn't that meet the requirement of "can be obtained"? The Other Brian -----Original Message----- From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] Sent: Tuesday, June 20, 2017 1:26 PM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] CE Compliance [General Use] Agreed, but the for the new Radio Directive the DoC shall be included with the product; Article 1.9 Manufacturers shall ensure that each item of radio equipment is accompanied by a copy of the EU declaration of conformity or by a simplified EU declaration of conformity. Where a simplified EU declaration of conformity is provided, it shall contain the exact internet address where the full text of the EU declaration of conformity can be obtained. For all other Directive it is not mandatory. As an alternative it can be an electronic copy on a webpage. Sincerely, Dieter Paasche Senior Product Developer, Electrical CHRISTIE 809 Wellington Street North Kitchener, ON N2G 4Y7 Phone: 519-744-8005 ext.7211 www.christiedigital.com<http://www.christiedigital.com> This e-mail message (including attachments, if any) is confidential. Any unauthorized use, distribution or disclosure is prohibited. If you have received this e-mail message in error, please notify the sender by reply e-mail or telephone and delete it and any attachments from your computer system and records. -----Original Message----- From: John Woodgate [mailto:jmw1...@btinternet.com] Sent: Tuesday, June 20, 2017 9:04 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] CE Compliance [General Use] The Declaration of Conformity is essential. While it is not compulsory to supply it to the end-user unasked, it is advisable to do so and many end-users insist on it. With best wishes DESIGN IT IN! OOO - Own Opinions Only www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. -----Original Message----- From: Price, Andrew (Leonardo, UK) [mailto:andrew.p.pr...@leonardocompany.com] Sent: 20 June 2017 13:46 To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] CE Compliance [General Use] Hi all, Can a statement that a product is compliant with the EMC Directive 2004/108/EC or 2014/30/EU in the support documentation be regarded as proof of conformity or does there have to be a Declaration of Conformity which states compliance with the Directive via appropriate standards??? Also to refresh my memory does the DofC have to be supplied to the end user or can it be held by the products distributor in the EU?? Regards Andy Andrew Price Land & Naval Defence Electronics Division Prinicpal Environmental Engineer (EMC) Leonardo MW Ltd Sigma House, Christopher Martin Rd, Basildon SS14 3EL, UK Tel EMC LAB : +44 (0)1268 883308 Mobile: +44 (0)7507 854888 andrew.p.pr...@leonardocompany.com<mailto:andrew.p.pr...@leonardocompany.com<mailto:andrew.p.pr...@leonardocompany.com%3cmailto:andrew.p.pr...@leonardocompany.com> > leonardocomapany.com HELICOPTERS / AERONAUTICS / ELECTRONICS, DEFENCE AND SECURITY SYSTEMS / SPACE * Please consider the environment before printing this email. Leonardo MW Ltd Registered Office: Sigma House, Christopher Martin Road, Basildon, Essex SS14 3EL A company registered in England & Wales. Company no. 02426132 ******************************************************************** This email and any attachments are confidential to the intended recipient and may also be privileged. If you are not the intended recipient please delete it from your system and notify the sender. You should not copy it or use it for any purpose nor disclose or distribute its contents to any other person. ******************************************************************** ________________________________ - ---------------------------------------------------------------- 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>
