We disagree much less that you might think. I'll just pick up two points:
/here are even hints that some legal people believe that every product
of a given type, e.g electric fan, should have the same performance!
/
The hints aren't restricted to things that indeed are common, like
safety provisions, but extend to the whole product specification.//That
may be a misinterpretation, but it's how it's seen by people who don't
have your insight./
/
"I can assure you that manufacturers will be able to define the
properties of their equipment."
That is not how the rewrite of the EMC immunity criteria is being
constrained. It seems to have been ruled that 'manufacturer' cannot be
mentioned at all.
//
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-24 11:51, Gert Gremmen wrote:
These very high standards (as you call it) are just part of the
requirements as given in ER3, for example, and are being part of the
current way the EU assesses standards in the current situation, where
standards text have become part of law -so-to-say- .
> /I can't understand why the court ruling about ENs being 'sort-of'
laws hasn't been challenged./
This decision cannot be challenged anymore as it is confirmed by the
highest EU legal authorities. It makes no sense to complain about a
status quo.
>/Because the committee decided it was necessary./
I won't challenge the committee technical expertise, but it makes no
sense writing about things that are not covered by title, scope and
foreword of the standard. The standard is to describe the (minimum)
technical requirements of the equipment in the field of EMC. The TC
should stay on their chair, defining requirements, and not mix the
interests of the standard with those of the manufacturer.
>/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?/
This is an oversimplification of what happens in reality/. /I am one
of the three assessors for ETSI standards and i can assure you that
this does not happen. As it comes to performance/, /only aspects that
_are common to all cars _(to keep your analogy) need to comply with a
kind of common property. A analogy could be the performance of tyres
or brakes, that need to be suitable for the car under test. So if you
say the same "relative performance" your analogy makes sense and,
indeed, that is what happens. All radio devices use a common medium
(ether) and the standards have to make sure every apparatus uses not
more spectrum space and power than required for its defined purpose.
>/left crucial provisions to be agreed between the manufacturer and
the test house cannot be permitted/
Of course the manufacturer should not be able to negotiate crucial
(test) aspects with a test-house. The interest of the manufacturer, is
a completely different one that that of the EU maintaining standards
and the test house, where accredited, needs to remain independent.
Negotiation with its client would jeopardize its accreditation anyway.
I can assure you that manufacturers will be able to define the
properties of their equipment. Its true that the word "manufacturer"
has been subject of challenges in many cases where there could be some
misuse by (Euro-English) statements that allowed impacting the
effectiveness of the standards tests.
An example i found is where the standard defines the requirements for
mobile (automotive) radio and there was no minimum requirement for the
temperature range in which the frequency stability was to be
maintained. (environmental profile to be negotiated between
manufacturer and test agency). The standard thus allowed the test to
be carried out from 30-35 oC (as example). Within the EU market that
is not a realistic minimum requirement as the equipment was for
outdoor use, so it was suggested to add a minimum range more
representative to EU climates.
John, thanks for your opinion anyway (but feel free to continue the
discussions)
Gert Gremmen
On 24-8-2019 10:53, John Woodgate wrote:
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 Associateswww.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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