Joe,
In effect, nothing changed. To comply with the RTTE directive, you must
meet Safety EN 60950 and EMC standards in the OJ. The same is true to meet
the EMC and LVD directives. However, if the RTTE directive does not apply
to your equipment and it's source power is 60VDC or lower, then you are not
required to meet the LVD. Only the RTTE directive calls for "no voltage
limit applying" in Article 3, 1. (a).
The definition in the thread seems to fit your equipment and so, is your
equipment actually TTE? Does the Plexus 9000 enable communication using an
E1 interface? Is it connected directly or indirectly by any means to
interfaces (like E1) of public telecom networks? If the directive does not
include "Network Equipment", why is Network Equipment not excluded in the
Annex 1 list? What is Network Equipment that Mark refers to? Does he mean
Database storage equipment and other Data Center type equipment, that
obviously is not intended to be used for Telecommunications enabling of
links or interfaces.
Regards,
Gary Raper
Hardware Compliance Engineering
Joe Finlayson <jfinlay...@telica.com>@world.std.com on 10/03/2002 09:16:44
AM
Please respond to nebs@world.std.com
Sent by: nebs-appro...@world.std.com
To: "'EMC PSTC'" <emc-p...@ieee.org>, "'TREG Newsgroup'"
<t...@world.std.com>, "'NEBS Newsgroup'" <NEBS@world.std.com>
cc:
Subject: FW: RTTE or LVD for Equipment with E1 SELV interface
All,
Below is a response from Mark Bogers reinforcing my, as well as
other's, position on the applicability of Network Equipment under the R&TTE
Directive. Based on this response, it is clear that the intent of the
directive was not to include Network Equipment.
Thx,
Joe
-----Original Message-----
From: Mark Bogers [mailto:mark.bog...@skynet.be]
Sent: Thursday, October 03, 2002 6:45 AM
To: 'jfinlay...@telica.com'; mark.bog...@cec.eu.int
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Network equipment isn't covered by the R&TTE Directive. It is only covered
by the EMC and LVD Directives and you need to ensure compliance with those.
Please note, you might still have a problem in Italy as they retained an
approval system for such equipment. My understanding is that that
regulation will however be removed in the near future.
Further information can be found on our website. Central entry point to
those of the mentioned 3 Directives is on
http://europa.eu.int/comm/enterprise.
Mark Bogers
-----Original Message-----
From: jfinlay...@telica.com [SMTP:jfinlay...@telica.com]
Sent: woensdag 2 oktober 2002 20:07
To: mark.bog...@cec.eu.int
Subject: FW: RTTE or LVD for Equipment with E1 SELV interface
Hello Mark,
Roger Magnuson recommended I run this situation by you as you are,
in his words, the contact point for R&TTE issues. You could follow the
thread, but I'll try to summarize the question instead.
My company, Telica, Inc., would like to sell our Plexus 9000 in the
EU. The Plexus 9000 does provide E1 as well as OC-3 and OC-12 interfaces
although they are not intended to be offered to the General Public for
sale.
This product is classified as SELV per IEC 60950 and in destined only for
the Central Office. As this product is Network Equipment, has no physical
capability of connecting to a PSTN E1 port, etc. (our E1 cards accommodate
28 E1's per card and the connection scheme is a 60-pin telco connector) and
will not be placed on the EU market for general availability (Network
Operators only), does this product fall within the scope of the R&TTE
Directive? The general consensus seems to be "no" although there are some
who feel it does. I would like to get an official ruling on the intent of
the R&TTE Directive to ensure we meet the full intent of the EU Directives.
Regards,
Joe
*******************************************
Joe Finlayson
Manager, Compliance Engineering
Telica, Inc.
734 Forest Street, Bldg. G, Suite 100
Marlboro, MA 01752
Tel: (508) 804-8212
Fax: (508) 480-0922
Email: jfinlay...@telica.com
-----Original Message-----
From: Roger Magnuson [mailto:ro...@tgc.se]
Sent: Wednesday, October 02, 2002 2:07 PM
To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS
Newsgroup'
Cc: Roger Magnuson
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Joe et al,
It seems a little overambitious to declare it under R&TTE as Network
Equipment did not even require type approval under the old TTE Directive.
If
you need a comment right from the source I suggest you contact Mark Bogers
(mark.bog...@cec.eu.int), he is the contact point for R&TTE issues.
Roger Magnuson
TGC Communication AB
-----Original Message-----
From: treg-appro...@world.std.com [mailto:treg-appro...@world.std.com]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Dave,
My position was based on my particular interface (in this case also E1)
and, based on my interpretation, concluded that it does not fall under the
scope of the R&TTE Directive. Based on your examples below, I can see that
apparently there are PSTN interfaces that can be classified as SELV. We
definitely seem to have a divided field here. I've seen posts stating
"Absolutely R&TTE" as well as "Absolutely not R&TTE".
Is there anyone out there who was involved in the draft of the R&TTE
that can comment on the intent?
Thx,
Joe
-----Original Message-----
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 11:47 AM
To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Joe,
Maybe I have missed something here but how does the TNV-X vs SELV from a
safety perspective define if the product falls under the R&TTE Directive?
Many telcom interfaces are SELV from a safety perspective and clearly fall
under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected
to WAN services via a CSU/DSU and ISDN Basic Rate S/T.
Also, I believe Peter's original post stated intrabuilding and did not
state
it was CO equipment. In any case there are expectations and I believe you
are going to spend more time trying to justify why you did not declare to
the R&TTE than if you just do it. Again because of expectations I would
have
a TBR12/13 test report to back up the declaration even if it's no longer
mandatory. NOTE: meeting the over voltage requirements of these standards
has nothing to do with the classification of the port from a safety
standpoint since the surges are applied to the AC mains (not even
applicable
ifDC powered)
Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:dave.clem...@motorola.com
http://www.motorola.com/globalcompliance/
-----Original Message-----
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 9:29 AM
To: Clement Dave-LDC009; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Dave,
Please reference the subject title of this thread. My position is that
by declaring compliance to the R&TTE Directive, we would then be stating
that we have designed to and/or are capable of connecting to the PSTN.
This
would contradict our IEC 60950 SELV classification and would then change
our
classification to TNV-X (depending on the interface). That would open up a
whole new can of worms and is a good example of how declaring blindly could
leave you in an undesirable situation.
Thx,
Joe
-----Original Message-----
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 02, 2002 9:05 AM
To: 'Joe Finlayson'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
This whole discussion is some what of a moot point. Under the R&TTE
directive there are no mandatory telecom standards anyway.
Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:dave.clem...@motorola.com
http://www.motorola.com/globalcompliance/
-----Original Message-----
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 8:53 AM
To: 'Pausch, Robert'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Hi Robert,
I'm glad to see you're still in the game. I think the issue here is
that "terminal equipment" is that which connects directly or indirectly to
the PSTN. This type of product does neither as it installed in the Central
Office and is NOT in free circulation on the market in the EU (only
available to Network Operators).
Thx,
Joe
-----Original Message-----
From: Pausch, Robert [mailto:robert.pau...@hp.com]
Sent: Wednesday, October 02, 2002 4:05 AM
To: Joe Finlayson; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Joe,
my position is that the RTTE directive does apply for all types of radio or
terminal equipment unless
it has been excluded by article 1(2) or annex I and is in free circulation
on the market in the EU.
However, the RTTE does only specify the essential requirements in article 3
which equipment has to
comply with. It does not regard any specific standard like E1.
Peter,
I think You must declare conformity to the RTT directive. What is the point
not to do it?
Regards
Robert
Robert Pausch, Regulatory Compliance Engineer
and Compliance Project Manager
Hewlett-Packard EMEA, Einsteinring 30, 85609 Dornach, Germany
Tel: +49 (89) 9392 2352, FAX: +49 (89) 9392 2336
Mailto: robert.pau...@hp.com
-----Original Message-----
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: Wednesday, October 02, 2002 12:15 AM
To: 'Richard Hughes'; 'EMC PSTC'; 'NEBS Newsgroup'; 'TREG Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Richard,
Good point - the "directly or indirectly" part grabbed my attention
but that seems too broad a description which could encompass quite a wide
range of equipment. However, the point of discussion here is whether a
product classified as SELV by IEC 60950, Type 2 by GR-1089, etc. and does
not connect (interface) to the "Public" telecommunications network is
included in the scope of the R&TTE Directive. This type of product resides
in the network and does not connect to outside plant conductors -
terminates
to another piece of equipment with the proper isolation to outside plant
conductors. My interpretation is that if there is no provision for
physical
connection to the PSTN, the R&TTE does not apply.
Any takers??? I'll copy the TREG and NEBS gurus on this one as well.
Thx,
Joe
-----Original Message-----
From: Richard Hughes [mailto:rehug...@nortelnetworks.com]
Sent: Tuesday, October 01, 2002 5:57 PM
To: 'Joe Finlayson'; "EMC-PSTC (E-mail)" <
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Joe,
The R&TTED applies to the following types of equipment:
1) Radio equipment
2) Terminal equipment.
The Directive also contains the following definitions:
'telecommunications terminal equipment' means a product enabling
communication or a relevant component thereof which is intended to be
connected directly or indirectly by any means whatsoever to interfaces of
public telecommunications networks (that is to say, telecommunications
networks used wholly or partly for the provision of publicly available
telecommunications services).
'interface' means
(i) a network termination point, which is a physical connection point
at
which a user is provided with access to public telecommunications network,
and/or
(ii) an air interface specifying the radio path between radio equipment
and their technical specifications
It will be seen from the above that the R&TTED is not limited to PSTN since
it is quite possible that a network operator could provide a business with
an E1 interface, for instance.
Peter,
It is for the manufacturer to decide to which market, e.g. terminal
equipment or central office equipment only, they whish to sell their
product
into. EN 60950 has nothing to do with it since this standard can be used
to
evaluate either type of product - and other non-telecom ICT products as
well
of course.
Simplistically, if the product does not have an input or output voltage in
the range 50-1000Vac, 75-1500Vdc then the LVD does not apply {ref. Article
1
of LVD}. Clearly, if the LVD does apply then certain editions of EN 60950
do provide a presumption of conformity with the safety objectives of the
LVD. If the LVD does not apply then that should not be taken as an excuse
to not comply with EN 60950, but that's another debate entirely.
If the R&TTED applies then the EMC is not applied as such, because the EMC
requirements are then covered by the R&TTED. However, this is largely an
administrative technicality because Article 3(1)(b) points to the EMC
Directive for its essential requirements, just as Article 3(1)(a) points to
the LVD for safety (minus any upper or lower voltage limit).
Well, that's enough personal opinions expressed on this matter for me...
Richard Hughes
-----Original Message-----
From: Joe Finlayson [mailto:jfinlay...@telica.com]
Sent: 01 October 2002 17:52
To: "EMC-PSTC (E-mail)" <
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Peter,
As this product does not connect to the PSTN and is destined for
the
Central Office only, I would say the R&TTE Directive does not apply as the
scope does not include Network Equipment.
Thx,
Joe
-----Original Message-----
From: Peter Merguerian [mailto:pmerguer...@itl.co.il]
Sent: Tuesday, October 01, 2002 9:33 AM
To: "EMC-PSTC (E-mail)" <
Subject: RTTE or LVD for Equipment with E1 SELV interface
Dear All,
For an equipment where the E1 has been assessed for SELV under EN
60
950 (ie for intrabuilding use and not subject to overvoltages), does the
equipment fall under the RTTE Directive or can the manufacturer declare
compliance to the LVD and EMC Directives.
If under the RTTE Directive, what telecom standard applies to the
E1
intrabuilding interface?
This e-mail message may contain privileged or confidential information. If
you are not the intended recipient, you may not disclose, use, disseminate,
distribute, copy or rely upon this message or attachment in any way. If you
received this e-mail message in error, please return by forwarding the
message and its attachments to the sender.
PETER S. MERGUERIAN
Technical Director
I.T.L. (Product Testing) Ltd.
26 Hacharoshet St., POB 211
Or Yehuda 60251, Israel
Tel: + 972-(0)3-5339022 Fax: + 972-(0)3-5339019
Mobile: + 972-(0)54-838175
http://www.itl.co.il
http://www.i-spec.com
-------------------------------------------
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.
Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/
To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc
For help, send mail to the list administrators:
Ron Pickard: emc-p...@hypercom.com
Dave Heald: davehe...@attbi.com
For policy questions, send mail to:
Richard Nute: ri...@ieee.org
Jim Bacher: j.bac...@ieee.org
All emc-pstc postings are archived and searchable on the web at:
http://ieeepstc.mindcruiser.com/
Click on "browse" and then "emc-pstc mailing list"
-------------------------------------------
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.
Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/
To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc
For help, send mail to the list administrators:
Ron Pickard: emc-p...@hypercom.com
Dave Heald: davehe...@attbi.com
For policy questions, send mail to:
Richard Nute: ri...@ieee.org
Jim Bacher: j.bac...@ieee.org
All emc-pstc postings are archived and searchable on the web at:
http://ieeepstc.mindcruiser.com/
Click on "browse" and then "emc-pstc mailing list"
