I think this is another example of the high standard you set. Please see
my responses below.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-24 09:29, Gert Gremmen wrote:
The discussion on languages and grammar has been very useful.
I would like your opinion and answers on the following standards
clause, as found in a concept cited harmonised EMC product family
standard:
/If hardware or software are modified subsequent to the completion of
the tests described in this standard//
//an impact analysis shall be carried out and it shall be decided
whether the EMC test shall be repeated as //
//a whole, in parts or not at all. Impact analysis and decision shall
be added to the EMC test plan for the////apparatus./
I have some questions on this clause:
1. What is this clause doing in a standard describing technical
requirements for an apparatus?
/JMW: Because the committee decided it was necessary. /
1. Shouldn't this be part of a basic standard describing the test method?
/JMW: Very possibly, but it can be difficult and cause a long delay for
one committee, that decides that hardware and software changes should be
addressed, to refer that to the a Basic standard committee and wait some
years for that committee to agree to amend its Basic standard and
publish it./
1. Who should carry out the impact analysis (not the manufacturer of
course) and decide on what retesting to do?
/JMW: Only the manufacturer knows enough about the hardware and software
to do the assessment. Besides, no-one can take away the manufacturer's
responsibility for compliance./
1. Why this should be made part of the test plan and not in the test
report?
/JMW: It's probably a mis-wording that no-one noticed. But the test plan
should certainly document what to do about hardware and software changes
after testing./
The principle of EMC- testing equipment, is that a full test is
required upon any modification, as a modification makes it a a
different equipment, but i also understand that a strict
interpretation of this might lead to excessive test costs, and some
test reductions are possible based on EMC expertise , experience in
testing and knowledge of the equipment. I also consider that the
EMC-directive is requiring as assessment and not testing (though
testing seems an essential part of assessing and test reports are
mentioned explicitly in the EMCD annexes.
But there is much more to say about an impact analysis than a simple
clause .....
How would you treat the problem of infinite testing, -to-be-sure-,
versus realistic testing, and how would you implement such a "impact
analysis" in the different standards, in the light of creating HS with
legal effects.
/JMW: I can't understand why the court ruling about ENs being 'sort-of'
laws hasn't been challenged. As a result of it, the correct decision
that some ETSI standards that left crucial provisions to be agreed
between the manufacturer and the test house cannot be permitted has been
vastly over-interpreted to mean effectively that even the word
'manufacturer' cannot be mentioned. For example, it is not being allowed
to say that the manufacturer provides the performance specification of
the product. There are even hints that some legal people believe that
every product of a given type, e.g electric fan, should have the same
performance! Do we expect all cars to have the same performance as a
Bugatti supercar?//
/
//
Gert Gremmen
--
Independent Expert on CE marking
Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC
EMC Consultant
Electrical Safety Consultant
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