Re: [PSES] ACMA labelling arrangement change announcement

2012-03-13 Thread Martin Garwood
Hi Ron,

 

The ACMA are confident the new system will be in place July 1, although we
are sceptical.

 

Regards,

Martin.

 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Pickard
RPQ
Sent: Tuesday, 13 March 2012 2:17 PM
To: 'Martin Garwood'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] ACMA labelling arrangement change announcement

 

Hi Martin,

 

Thank you for the detailed brief summary. Does anyone know if the ACMA
expects this to be in place and functioning by their effectivity date or
will it be delayed. Have you heard if there any expectation or rumblings
from the ACMA that this will be delayed?

 

Also, if Sergei German is still at Austest, tell him I said hi.

 

I look forward to your reply.

 

Best regards,

 

Ron Pickard

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Martin
Garwood
Sent: Sunday, March 11, 2012 10:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] ACMA labelling arrangement change announcement

 

Hi All,

 

I have put together a summary of the new Australian Electrical Safety System
(as of today) with details of compliance levels and documentation
requirements on our blog.

 

http://www.approvalsblog.com/?p=717

 

Regards,

Martin.

 

 

Martin Garwood

 

Austest Laboratories

Unit 2, 9 Packard Avenue,

Castle Hill, NSW 2154, Australia

Tel: +61 2 9680 9990 | Fax: +61 2 8850 3113

 http://www.austest.com.au/ www.austest.com.au  (Offices in Sydney,
Central Coast NSW, Melbourne, Adelaide)

 http://www.harvestlabs.com/ www.harvestlabs.com  (Auckland) 

 http://www.approvalspecialists.com/ www.approvalspecialists.com  (Global)

Local and Global Approvals News  http://www.approvalsblog.com/
www.approvalsblog.com

Austest Laboratories is 100% Australian Owned

 

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Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread Anthony Thomson
Hello John, et al,

 3rd para: NBs “freely supporting” exemptions are not required, and I doubt in 
practice that any of them would want to stick their neck out to support such a 
move.
I am moved to use a texting abbreviation, ROFL!
*IN MY OPINION* that’s EXACTLY why some companies use Notified Bodies; to skimp 
or circumvent testing which they then support with a written technical and/or 
operational justification. The notified body reviews the limited/partial 
testing, accepts the justification, issues a positive opinion and import 
authorities are happy.
I could tell you stories that would make your toes curl.
T
- Original Message -
From: John Cotman
Sent: 03/12/12 04:44 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity 
(DOCs)

Using a standard that gives a presumption of conformity has obvious benefits, 
both in the legal protection of due diligence and in meeting customer 
expectations. It would be rather perverse not to do so if there is a standard 
that is a good fit to the product. ITE is clearly the type of product where 
close adherence is more important, and in many cases it is interoperability as 
much as safety that determines this. 
(Test labs in particular like to issue Pass/Fail reports to current standards, 
much more than decisions about compliance with directives. It’s nice and tidy 
and saves all the agonising about whether or not the latest amendment actually 
conveys the slightest benefit in improving the safety of a product, and getting 
customers into the mindset that every revision needs a retest is good for 
business) 
But going another route is legally permissible, and it does not mean that a 
Notified Body necessarily has to be involved. The CE process, for most products 
and directives, is one of self-declaration (yes, not in every case, and there 
are situations that have to involve an NB). But for that “most” situation, if 
you as the manufacturer are satisfied that your product meets the Essential 
Health and Safety Requirements of all relevant Directives, and that the 
evidence in your Technical File supports it, you may make a Declaration of 
Conformity, whatever standards, test methods, calculations etc have led you to 
that conclusion. No NB has had to agree or disagree with you, you take the 
responsibility. That is both the beauty and the problem with CE marking. NBs 
“freely supporting” exemptions are not required, and I doubt in practice that 
any of them would want to stick their neck out to support such a move. 
Now it may turn out that you are wrong, your declaration shouldn’t have been 
made, and you face enforcement action. It’s for any court action to prove 
non-compliance with any EHSRs, not failure to comply with a particular 
standard. And, of course, the prosecution has to prove its case, the defence 
does not. Any defence is going to be more difficult if you have used methods of 
your own devising, especially if it turns out that applying the “proper” 
current standard would have led you to a different conclusion, though there is 
a difference in culpability between a reckless declaration and one made in good 
faith, albeit incorrectly. 
Not sure if this clarifies or confuses the issue? 
John C 

-
From: Monrad Monsen [mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 15:39
To: John Cotman
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity 
(DOCs)
John,
 You made a very interesting statement ... especially for someone whose e-mail 
address indicates that you are in Europe. You said:
 You have also complicated the issue by supposing that changed standards 
 (as distinct from legislation) are “mandatory” – they aren’t.

You are correct that Compliance with a 'harmonised standard' is not 
compulsory. (EMC Directive 2004/108/EC, Article 6, section 1). However, 
compliance of equipment with the relevant harmonised standards ... shall raise 
a presumption ... of conformity with the essential requirements (EMC 
Directive 2004/108/EC, Article 6, section 2) Otherwise, a manufacturer would 
have to use (and pay for) a notified body to learn about our product and make 
up their own rules which will generally adopt the harmonized standards if they 
can be applied to the product. For products for which there are specific family 
standards developed like information technology equipment (ITE), the harmonized 
standards are effectively compulsory. 

 Since my experience is with ITE products, I have not actually worked through a 
notified body. Are you implying that a notified body would freely support a 
product not updating to comply with new revisions of the harmonized standards? 
Would a notified body make a blanket finding for a company's whole portfolio of 
ITE products? Or would a company have to pay a fee to the notified body to 
effectively exempt each and every 

[PSES] Construction directive/regulation in EU

2012-03-13 Thread Kim Boll Jensen
Hi

One of our customers has asked us how to understand the Construction
directive and the new regulation, concerning their products.

The make different kind of stationary road traffic signs according to
standards;

· EN 12966

· EN 12368

· EN 12899

At the moment they have no NB involved in their CE marking. We have made
some test for them concerning EMC and electrical safety.

I'm not sure how to read the directive/regulation and understand when a
product is under which system (1, +1, 2 etc...).

Will all tests have to be made by an accredited laboratory?

Do all products require the use of a NB?

Is there issued a guide on this regulations

Best regards,

 

Mr. Kim Boll Jensen

Bolls Aps

Ved Gadekæret 11F

DK-3660 Stenløse

 

Phone: +45 48 18 35 66

 

k...@bolls.dk

www.bolls.dk

 


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Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread Michael Derby
Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized 
standards, then a company must go to a notified body to get an 
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
  Yes: It's possible. For example, an update might well require   emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product must
be tested if the product has a clock/oscillator over 108MHz.  More likely,
the product will be sold also in USA and Canada, so the product is already
tested above 1GHz even if there was a slightly different test methodology.
My e-mail was addressing the case if a hardware change is required to meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception and
cite that finding/exception in the DOC.  To do any less would invite some
regulator to take time to investigate your product documentation with a risk
of either stopping a product in customs or demanding a recall of any
products that did get through to customers.

You also state:
  Again, no Notified Body need be involved. Revised standards apply   in
Europe only after a (normally) 3 year transition period. For   some types
of product, that is short compared with the normal   product replacement
cycle, but surely it isn't for ITE. Your   preference is thus often
achievable.
Might be true for laptops, but I normally deal with professional products
like servers and massed storage products that  have a sales life going as
long as  4-8 years with minor updates (drop-in CPU updates or drop-in
replacements with faster disk or tape drives).  Even beyond the period of
new product sales, there is also a market for used product sales that could
bring products to Europe from outside years later.  As you know, the
directives apply to all products (new or used) at the time when it is
placed on the market and/or put into service which impacts used product
sales when it first enters the European market.

By the way, the Europe Commission issued Decision 2010/571/EU on 24 Sep
2010 that announced expiration dates for several RoHS exemptions that were
within a year of the decision.  Fortunately, the more frequently used RoHS
exemptions 7(c)-III and 11(b) expiration dates were given two years notice.
Hence, even your hopeful 3 year transition period is not rigorously
followed by Europe.

Note:  All opinions expressed in this e-mail are my own only and do not
necessarily reflect the opinions of any company I work for or have ever
worked for.   In fact, my opinions may change in the progress of this
discussion.

Monrad

On 3/12/2012 10:18 AM, John Woodgate wrote:
 In message 4f5e1878.2000...@oracle.com, dated Mon, 12 Mar 2012, 
 Monrad Monsen monrad.mon...@oracle.com writes:

 You made a very interesting statement ... especially for someone 
 whose e-mail address indicates that you are in Europe.  You said:
 You have also complicated the issue by 

Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread Robert Heller
What if your equipment is multi-functional? Say a passport reader that has 
a RFID mode (RTTE) as well as a functional mode to read UV inks or 
invisible data (EMC). Or a laptop (EMC) with a wireless mouse (RTTE)?

Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:   Michael Derby micha...@acbcert.com
To: 'Charlie Blackham' char...@sulisconsultants.com, 
EMC-PSTC@LISTSERV.IEEE.ORG
Date:   03/13/2012 04:33 AM
Subject:RE: [PSES] Identifying Apparatus in Europe Declarations of 
Conformity (DOCs)
Sent by:emc-p...@ieee.org



Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized 
standards, then a company must go to a notified body to get an 
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the 
EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
  Yes: It's possible. For example, an update might well require   
emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no 
significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not 
necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer 
using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product must
be tested if the product has a clock/oscillator over 108MHz.  More likely,
the product will be sold also in USA and Canada, so the product is already
tested above 1GHz even if there was a slightly different test methodology.
My e-mail was addressing the case if a hardware change is required to meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception 
and
cite that finding/exception in the DOC.  To do any less would invite some
regulator to take time to investigate your product documentation with a 
risk
of either stopping a product in customs or demanding a recall of any
products that did get through to customers.

You also state:
  Again, no Notified Body need be involved. Revised standards apply   in
Europe only after a (normally) 3 year transition period. For   some types
of product, that is short compared with the normal   product replacement
cycle, but surely it isn't for ITE. Your   preference is thus often
achievable.
Might be true for laptops, but I normally deal with professional products
like servers and massed storage products that  have a sales life going as
long as  4-8 years with minor updates (drop-in CPU updates or drop-in
replacements with faster disk or tape drives).  Even beyond the period of
new product sales, there is also a market for used product sales that 
could
bring products to Europe from outside years later.  As you know, the
directives apply to all products (new or used) at the time when it is
placed on the market and/or put into service which impacts used product
sales when it first enters the European market.

By the way, the Europe Commission issued Decision 2010/571/EU on 24 Sep
2010 that announced expiration dates for several RoHS exemptions that were
within a year of the decision.  Fortunately, the more frequently used RoHS
exemptions 7(c)-III and 11(b) expiration dates were given two years 
notice.
Hence, even your hopeful 3 year 

Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread John Woodgate
In message 
of3cd9390f.9696df42-on862579c0.003df660-862579c0.003e7...@mmm.com, 
dated Tue, 13 Mar 2012, rehel...@mmm.com writes:


What if your equipment is multi-functional? Say a passport reader that 
has a RFID mode (RTTE) as well as a functional mode to read UV inks or 
invisible data (EMC). Or a laptop (EMC) with a wireless mouse (RTTE)?


'Render unto Caesar' - Apply the relevant Directive to each functional 
part. Can indeed be a complex matter. Here is a case where a Notified 
Body, that may have experience of similar hybrid products, may give 
valuable **advice**.

--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for?

-

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://listserv.ieee.org/request/user-guide.html
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas emcp...@radiusnorth.net
Mike Cantwell mcantw...@ieee.org

For policy questions, send mail to:
Jim Bacher:  j.bac...@ieee.org
David Heald: dhe...@gmail.com


Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread Charlie Blackham
 Or a laptop (EMC) with a wireless mouse (RTTE)?

Presumably there'd be some wireless in the laptop as well :)

Regards
Charlie

From: Robert Heller [mailto:rehel...@mmm.com]
Sent: 13 March 2012 11:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity 
(DOCs)

What if your equipment is multi-functional? Say a passport reader that has a 
RFID mode (RTTE) as well as a functional mode to read UV inks or invisible 
data (EMC). Or a laptop (EMC) with a wireless mouse (RTTE)?

Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:Michael Derby micha...@acbcert.com
To:'Charlie Blackham' char...@sulisconsultants.com, 
EMC-PSTC@LISTSERV.IEEE.ORG
Date:03/13/2012 04:33 AM
Subject:RE: [PSES] Identifying Apparatus in Europe Declarations of 
Conformity (DOCs)
Sent by:emc-p...@ieee.org




Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com]
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
 Yes: It's possible. For example, an update might well require   emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product must
be tested if the product has a clock/oscillator over 108MHz.  More likely,
the product will be sold also in USA and Canada, so the product is already
tested above 1GHz even if there was a slightly different test methodology.
My e-mail was addressing the case if a hardware change is required to meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception and
cite that finding/exception in the DOC.  To do any less would invite some
regulator to take time to investigate your product documentation with a risk
of either stopping a product in customs or demanding a recall of any
products that did get through to customers.

You also state:
 Again, no Notified Body need be involved. Revised standards apply   in
Europe only after a (normally) 3 year transition period. For   some types
of product, that is short compared with the normal   product replacement
cycle, but surely it isn't for ITE. Your   preference is thus often
achievable.
Might be true for laptops, but I normally deal with professional products
like servers and massed storage products that  have a sales life going as
long as  4-8 years with minor updates (drop-in CPU updates or drop-in
replacements with faster disk or tape drives).  Even beyond the period of
new product sales, there is also a market for used product sales that could
bring products to Europe from outside years later.  As you know, the
directives apply to all products (new or used) at the time when it is
placed on the market and/or put into service which impacts used product
sales when it first enters the 

Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread Robert Heller
Not in my Abacus Model 1 ;)

Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:   Charlie Blackham char...@sulisconsultants.com
To: rehel...@mmm.com rehel...@mmm.com, 
EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG
Date:   03/13/2012 07:27 AM
Subject:RE: [PSES] Identifying Apparatus in Europe Declarations of 
Conformity (DOCs)



 Or a laptop (EMC) with a wireless mouse (RTTE)?
 
Presumably there?d be some wireless in the laptop as well J
 
Regards
Charlie
 
From: Robert Heller [mailto:rehel...@mmm.com] 
Sent: 13 March 2012 11:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of 
Conformity (DOCs)
 
What if your equipment is multi-functional? Say a passport reader that has 
a RFID mode (RTTE) as well as a functional mode to read UV inks or 
invisible data (EMC). Or a laptop (EMC) with a wireless mouse (RTTE)? 

Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:Michael Derby micha...@acbcert.com 
To:'Charlie Blackham' char...@sulisconsultants.com, 
EMC-PSTC@LISTSERV.IEEE.ORG 
Date:03/13/2012 04:33 AM 
Subject:RE: [PSES] Identifying Apparatus in Europe Declarations of 
Conformity (DOCs) 
Sent by:emc-p...@ieee.org 




Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized 
standards, then a company must go to a notified body to get an 
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the 
EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
 Yes: It's possible. For example, an update might well require   
emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no 
significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not 
necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer 
using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product must
be tested if the product has a clock/oscillator over 108MHz.  More likely,
the product will be sold also in USA and Canada, so the product is already
tested above 1GHz even if there was a slightly different test methodology.
My e-mail was addressing the case if a hardware change is required to meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception 
and
cite that finding/exception in the DOC.  To do any less would invite some
regulator to take time to investigate your product documentation with a 
risk
of either stopping a product in customs or demanding a recall of any
products that did get through to customers.

You also state:
 Again, no Notified Body need be involved. Revised standards apply   in
Europe only after a (normally) 3 year transition period. For   some types
of product, that is short compared with the normal   product replacement
cycle, but surely it isn't for ITE. Your   preference is thus often
achievable.
Might be true for laptops, but I normally deal with professional products
like servers and massed storage products that  have a sales life going as
long as  4-8 years with minor 

[PSES] Fwd List of Test Equipment for Sale

2012-03-13 Thread Macy
Ladies/Gentlemen:

I am not associated with this firm, nor benefit from any sales they may make.
I have worked with this firm before and appreciated their Quality of Products 
and Professionalism at supplying Test Equipment.

I thought someone in this group may benefit from new contact and from the Test 
Equipment they are offering.

Regards,
Robert


The following email is TEXT only:
=-=-=
From:   Jennifer DuMond jdum...@prioritytest.com 
To: 'undisclosed recipients' nthr...@prioritytest.com
Subject:Priority Test - March Check In!
Date:   Mon 03/12/12 06:22 PM

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AT/HP 3325B - Synthesizer/Function Generator - $795
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AT 85033D - Calibration Kit 3.5MM - $2795
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Remember to give us a call or email when you need to buy, rent or repair test 
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Nanette Throne
Account Manager
Priority Test Equipment   
925-513-7300 ofc  
925-513-7338fax   
925-759-1093 mobile
nthr...@prioritytest.com
www.prioritytest.com

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Inside Sales Representative
Western  Northern United States
jdum...@prioritytest.com

Chelsea Alayne
Inside Sales Representative
Eastern  Southern United States
cala...@prioritytest.com
=-=-= 

-

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:
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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 
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Instructions:  http://listserv.ieee.org/request/user-guide.html
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Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread ce-test, qualified testing bv - Gert Gremmen
You were on Hogwarts with Harry too ? He got the Nimbus 2000 !

 

 

 

Regards,

Ing.  Gert Gremmen, BSc

 

 

 

 

Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens
rehel...@mmm.com
Verzonden: Tuesday, March 13, 2012 1:33 PM
Aan: Charlie Blackham
CC: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: RE: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

 

Not in my Abacus Model 1 ;) 

Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:Charlie Blackham char...@sulisconsultants.com 
To:rehel...@mmm.com rehel...@mmm.com,
EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG 
Date:03/13/2012 07:27 AM 
Subject:RE: [PSES] Identifying Apparatus in Europe Declarations
of Conformity (DOCs) 






 Or a laptop (EMC) with a wireless mouse (RTTE)? 
  
Presumably there'd be some wireless in the laptop as well J 
  
Regards 
Charlie 
  
From: Robert Heller [mailto:rehel...@mmm.com mailto:rehel...@mmm.com ]

Sent: 13 March 2012 11:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs) 
  
What if your equipment is multi-functional? Say a passport reader that
has a RFID mode (RTTE) as well as a functional mode to read UV inks or
invisible data (EMC). Or a laptop (EMC) with a wireless mouse (RTTE)?


Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:Michael Derby micha...@acbcert.com 
To:'Charlie Blackham' char...@sulisconsultants.com,
EMC-PSTC@LISTSERV.IEEE.ORG 
Date:03/13/2012 04:33 AM 
Subject:RE: [PSES] Identifying Apparatus in Europe Declarations
of Conformity (DOCs) 
Sent by:emc-p...@ieee.org 

 







Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require
a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the
EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com
mailto:char...@sulisconsultants.com ] 
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized 
standards, then a company must go to a notified body to get an 
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the
EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [mailto:monrad.mon...@oracle.com
mailto:monrad.mon...@oracle.com ]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would
freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
 Yes: It's possible. For example, an update might well require  
emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no
significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not
necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer
using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on
whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product
must
be tested if the product has a clock/oscillator over 108MHz.  More
likely,
the product will be sold also in USA and Canada, so the product is
already
tested above 1GHz even if there was a slightly different test
methodology.
My e-mail was addressing the case if a hardware change is required to
meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in
the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception
and
cite that finding/exception in the DOC.  To do any less would invite
some
regulator to take time to investigate your product documentation with a
risk
of either stopping a product in customs or 

Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread Michael Derby
Then it's an RTTE Device.

 

If you have a piece of apparatus that has no radio or telecoms
(wirelessless?), you would normally apply the EMC and Safety Directives.
Then you add a radio device to it and it becomes an RTTE Directive device.

The RTTE Directive includes EMC (article 3.1b) and Safety (article 3.1a)
and states that once you apply the RTTE Directive, you no longer apply the
EMC and Safety Directives.

 

Now, you might say.. But my device is complex and the harmonised standards
I apply are in the EMC OJ and the Safety OJ, not the RTTE OJ!

..well, that's ok, you can use standards from the EMC OJ and the Safety OJ
to demonstrate compliance with articles 3.1b and 3.1a of the RTTE Directive
but that doesn't mean you're applying the EMC or Safety Directives.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 13 March 2012 12:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

 

 Or a laptop (EMC) with a wireless mouse (RTTE)?

 

Presumably there'd be some wireless in the laptop as well J

 

Regards

Charlie

 

From: Robert Heller [mailto:rehel...@mmm.com] 
Sent: 13 March 2012 11:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

 

What if your equipment is multi-functional? Say a passport reader that has a
RFID mode (RTTE) as well as a functional mode to read UV inks or
invisible data (EMC). Or a laptop (EMC) with a wireless mouse (RTTE)? 

Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:Michael Derby micha...@acbcert.com 
To:'Charlie Blackham' char...@sulisconsultants.com,
EMC-PSTC@LISTSERV.IEEE.ORG 
Date:03/13/2012 04:33 AM 
Subject:RE: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs) 
Sent by:emc-p...@ieee.org 

  _  




Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [ mailto:char...@sulisconsultants.com
mailto:char...@sulisconsultants.com] 
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized 
standards, then a company must go to a notified body to get an 
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [ mailto:monrad.mon...@oracle.com
mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
 Yes: It's possible. For example, an update might well require   emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product must
be tested if the product has a clock/oscillator over 108MHz.  More likely,
the product will be sold also in USA and Canada, so the product is already
tested above 1GHz even if there was a slightly different test methodology.
My e-mail was addressing the case if a hardware change is required to meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception and
cite that finding/exception in the DOC.  To do any less would 

Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread Anthony Thomson
Of course, you couldn’t have a wireless abacus. That’d be just a frame and a 
pile of beads!
T

- Original Message -
From: Robert Heller
Sent: 03/13/12 12:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity 
(DOCs)

Not in my Abacus Model 1 ;)

Bob Heller
 3M EMC Laboratory, 76-1-01
 St. Paul, MN 55107-1208
 Tel: 651-778-6336
 Fax: 651-778-6252
 =




From: Charlie Blackham char...@sulisconsultants.com
To: rehel...@mmm.com rehel...@mmm.com, EMC-PSTC@LISTSERV.IEEE.ORG 
EMC-PSTC@LISTSERV.IEEE.ORG
Date: 03/13/2012 07:27 AM
Subject: RE: [PSES] Identifying Apparatus in Europe Declarations of Conformity 
(DOCs)
-



 Or a laptop (EMC) with a wireless mouse (RTTE)?

Presumably there’d be some wireless in the laptop as well J

Regards
Charlie

 *From:* Robert Heller [ rehel...@mmm.com ]
 *Sent:* 13 March 2012 11:22
 *To:* EMC-PSTC@LISTSERV.IEEE.ORG
 *Subject:* Re: [PSES] Identifying Apparatus in Europe Declarations of 
Conformity (DOCs)

What if your equipment is multi-functional? Say a passport reader that has a 
RFID mode (RTTE) as well as a functional mode to read UV inks or invisible 
data (EMC). Or a laptop (EMC) with a wireless mouse (RTTE)?

Bob Heller
 St. Paul, MN 55107-1208
 Tel: 651-778-6336
 Fax: 651-778-6252
 =




From: Michael Derby micha...@acbcert.com
To: 'Charlie Blackham' char...@sulisconsultants.com, 
EMC-PSTC@LISTSERV.IEEE.ORG
Date: 03/13/2012 04:33 AM
Subject: RE: [PSES] Identifying Apparatus in Europe Declarations of Conformity 
(DOCs)
Sent by: emc-p...@ieee.org
-




Yes, I think you're thinking of the RTTE Directive Monrad.

 For the RTTE Directive, the lack of a harmonised standard would require a
 Notified Body opinion.
 For the EMC Directive, the use of a Notified Body is optional.

 Remember that if the RTTE Directive applies to your device, then the EMC
 Directive does not apply. You don't apply them both.

 Michael.


 Michael Derby
 Regulatory Engineer
 ACB Europe


 -Original Message-
 From: Charlie Blackham [ char...@sulisconsultants.com ]
 Sent: 12 March 2012 20:58
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
 Conformity (DOCs)

 Monrad

 My understanding is that unless the DOC cites the current harmonized
 standards, then a company must go to a notified body to get an
 exception and cite that finding/exception in the DOC

 That is not required - the use of a NB is completely voluntary under the EMC
 Directive as per Article 7. You can put whatever standards you choose on
 your DoC.

 Regards
 Charlie

 -Original Message-
 From: Monrad Monsen [ monrad.mon...@oracle.com ]
 Sent: 12 March 2012 18:44
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
 Conformity (DOCs)

 John,
 Regarding the question Are you implying that a notified body would freely
 support a product not updating to comply with new revisions of the
 harmonized standards?, you wrote:
  Yes: It's possible. For example, an update might well require  emission
 testing above 1 GHz. If the product clearly has no  possibility of
 producing such emissions, since previous tests  have shown no significant
 emissions above 100 MHz, it does  not need to be tested. But the
 manufacturer can justify that  in his EMC assessment, it is not necessary
 to involve a  Notified Body.
 The declaration of conformity (DOC) must be signed by the manufacturer using
 the harmonized standards. Your example is inadequate. Avoiding even
 testing the new radiated emissions testing above 1GHz for based on whether
 there is significant emissions above 100 MHz is very risky.
 In fact, the emissions standard (EN55022:2006+A1:2007) states product must
 be tested if the product has a clock/oscillator over 108MHz. More likely,
 the product will be sold also in USA and Canada, so the product is already
 tested above 1GHz even if there was a slightly different test methodology.
 My e-mail was addressing the case if a hardware change is required to meet
 the new requirement.

 Are you saying that a manufacturer can justify in his EMC assessment
 to avoid having to complying with the new 4dB tighter limits given in the
 1-3GHz range and implementing a known hardware change?

 My understanding is that unless the DOC cites the current harmonized
 standards, then a company must go to a notified body to get an exception and
 cite that finding/exception in the DOC. To do any less would invite some
 regulator to take time to investigate your product documentation with a risk
 of either stopping a product in customs or demanding a recall of any
 products that did get through to customers.

 You also state:
  Again, no Notified Body need be involved. Revised standards apply  in
 

Re: [PSES] Construction directive/regulation in EU

2012-03-13 Thread Peter Tarver
Kim –



You can review these links as a starter.



http://ec.europa.eu/enterprise/sectors/construction/index_en.htm



http://www.exploreconstruction.eu/index.jspx





Peter Tarver



*From:* Kim Boll Jensen [mailto:k...@bolls.dk]
*Sent:* Tuesday, March 13, 2012 02:24
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] Construction directive/regulation in EU



Hi

One of our customers has asked us how to understand the Construction
directive and the new regulation, concerning their products.

The make different kind of stationary road traffic signs according to
standards;

· EN 12966

· EN 12368

· EN 12899

At the moment they have no NB involved in their CE marking. We have made
some test for them concerning EMC and electrical safety.

I'm not sure how to read the directive/regulation and understand when a
product is under which system (1, +1, 2 etc...).

Will all tests have to be made by an accredited laboratory?

Do all products require the use of a NB?

Is there issued a guide on this regulations

Best regards,



Mr. Kim Boll Jensen

Bolls Aps

Ved Gadekæret 11F

DK-3660 Stenløse



Phone: +45 48 18 35 66



k...@bolls.dk

www.bolls.dk



-


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 
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All emc-pstc postings are archived and searchable on the web at:
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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.

Website: http://www.ieee-pses.org/
Instructions: http://listserv.ieee.org/request/user-guide.html
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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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://listserv.ieee.org/request/user-guide.html
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

2012-03-13 Thread John Woodgate
In message 
64D32EE8B9CBDD44963ACB076A5F6ABB0261B59C@Mailbox-Tech.lecotech.local, 
dated Tue, 13 Mar 2012, Kunde, Brian brian_ku...@lecotc.com writes:


So when a directive says to apply harmonized standards, do we just 
assume it means to apply standards harmonized to THAT directive? Is it 
clear that it doesn?t also mean standards harmonized to ANY directive?


To all the Directives that apply to the product, and *only* those. There 
is no obligation to trawl through every harmonized standard that exists 
and apply it to a product if that product is not included in the scope 
of the standard.


That is why the Commission publishes list of standards that apply under 
each Directive.

--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for?

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[PSES] I am out of the office - for my annual vaccation

2012-03-13 Thread Rene Charton/Twn/TUV
I will be out of the office starting  03/14/2012 and will not return until
04/12/2012.

I will have very limited access to my e-mail,
therefore preferably please contact my deputies:
For FCC/Canada and EU-Notified Body: arvin...@twn.tuv.com
For Telecom International Approvals: jane.p...@twn.tuv.com

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