Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[ce-test, qualified testing bv - Gert Gremmen]

2004/104/EC will be withdrawn in November 2014 and be replaced
by the UN regulations.
Not having the texts at hand... will this difference remain...

Gert

-Oorspronkelijk bericht-
Van: T.Sato [mailto:vef00...@nifty.ne.jp] 
Verzonden: woensdag 11 juni 2014 23:43
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

On Wed, 11 Jun 2014 13:18:15 +0100,
  "McCallum, Andy"  wrote:

> But the difference is only 2dB - I don't see the point.

Sorry, I forgot of thinking of vehicle limits in 2004/104/EC.

For the 2004/104/EC vehicle narrow band limits which is 2 dB lower than
that of EN 55012, the latter requires that the results are at least 2 dB
below the specified limits when a single sample is tested, and then,
they will be effectively identical.

Regards,
Tom

--
Tomonori Sato  
URL: http://homepage3.nifty.com/tsato/

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[PSES] RoHS

[Moshe Henig]

Dear team

I need to perform RoHS 2 XRF and Chemical analysis to a medical equipment
with external charger

The charger has all regulatory approvals for medical.

The  Charger manufacturer issued RoHS decleration.

Is this decleration sufficient or I need to perform  XRF and Chemical
analysis.

For North America the RoHS Directive is not valid. What are the RoHS for
North America

Thanks

Moshe

Moshe Henig Dipl. Ing.

NCE SM IEEE SM SEEEI

iNarte Certified EMC engineer

EMC and Safety consultant

Mobile +972 52 8951449

Skype mhenig

he...@bezeqint.net

moshe.he...@ieee.org

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Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[T.Sato]

On Wed, 11 Jun 2014 13:18:15 +0100,
  "McCallum, Andy"  wrote:

> But the difference is only 2dB - I don't see the point.

Sorry, I forgot of thinking of vehicle limits in 2004/104/EC.

For the 2004/104/EC vehicle narrow band limits which is 2 dB lower
than that of EN 55012, the latter requires that the results are
at least 2 dB below the specified limits when a single sample is
tested, and then, they will be effectively identical.

Regards,
Tom

-- 
Tomonori Sato  
URL: http://homepage3.nifty.com/tsato/

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Re: [PSES] Safety Interlock Switches

[Paul Milton]

Hi Dave,



I tend to agree with Doug.  Applying the Machinery Directive does not
necessarily require the use of EN 60204-1.  I would however document the
Annex I requirements from the MD, and do a risk assessment to ISO 12100, in
addition to applying the standards Doug references below.  There may be
other standards under the MD that apply to your equipment as well.





*Paul MiltonG&M Compliance, Inc.714-628-1020 x 104*

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*From:* Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
*Sent:* Wednesday, June 11, 2014 6:51 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Safety Interlock Switches



Machinery Directive and LVD are most certainly applicable to the products
in question, these types of products have been around for quite a while and
the NRTLs and independent EU CE inspectors agree.  I believe this also
means EN 60204-1 and EN 60950-1 are also applicable respectively.



I’m not familiar with EN ISO 14119 so I guess I’ll need to get a copy to
review.  Are there any specific ties between then Machinery Directive
and/or EN 60204-1?  In other words, to make the argument that compliance to
EN ISO 14119 is also applicable to the product assuming the Machinery
Directive is or non-compliance to EN ISO 14119 is non-compliance with the
Machinery Directive.



EN ISO 13849 is applicable, I’ve been reviewing it but I’m not an expert
with it yet.  (Products do use some pneumatics and vacuum) Certainly the
PLr has an impact on the interlock system design but I was hoping to get
some general feedback on the specific questions independent of the PLr.



Thanks

-Dave



*From:* Douglas Nix [mailto:d...@ieee.org ]
*Sent:* Wednesday, June 11, 2014 9:32 AM
*To:* Nyffenegger, Dave
*Cc:* EMC-PSTC@LISTSERV.IEEE.ORG; ibm...@gmail.com
*Subject:* Re: [PSES] Safety Interlock Switches



Dave,



After reading your original post, I have to question the use of EN 60204-1
for your application. Can the product reasonably be considered to fit
within the scope? Considering the first paragraph of the scope of the 2006
edition:



 This part of IEC 60204 applies to the application of electrical,
electronic and programmable

electronic equipment and systems to machines not portable by hand while
working, including

a group of machines working together in a co-ordinated manner.



I especially question the use of EN 60204-1 in conjunction with EN 60950.
There seems little value and much confusion to be generated by this
decision.



Since the product falls under the scope of the Machinery Directive, you
should be looking at EN ISO 14119, Safety of machinery — Interlocking
devices associated with guards — Principles for design and selection, for
information on the interlocking device. This standard will provide you with
the requirements for selection and installation of interlocking devices,
and I can assure you that, unless the risk related to the hazards inside
the machine are extremely low, the device you describe won’t pass muster.
This standard also describes the requirements for defeat resistance of the
interlocking device.



In addition, a functional safety analysis of the safety related control
functions is required under the Machinery Directive, and for that you can
choose either EN ISO 13849-1 & -2, or IEC 62061 (see EN 60204-1:2006, 9.4).
The former is generally easier to use, but the latter may fit the design of
the equipment better, since it doesn’t sound like there is any fluidic
power systems, and the equipment is predominantly electrical/electronic and
programmable.



I’d be happy to discuss this with you in more detail off line if you’re
interested.



Doug Nix

+1 (519) 729-5704

d...@ieee.org



On 11-Jun-14, at 08:20, Nyffenegger, Dave 
wrote:



Yes, Omron D3D series.  And I also have a similar looking switch on my HVAC
air handler in the primary circuit made in 1995  for US (probably no CE).
I am concerned not only with the issue of inadvertent activation but also
the operational acceptability (min operations).  Hence the questions about
the applicable switch standards.  But I don’t know if the argument
presented where reactivation buy closing the switch by itself is not
normally possible stands up.  The challenge with concealing behind a small
hole is keeping the equally small switch actuator protrusion from becoming
a hazard itself.  For example when used with a hinged guard that opens up
to avoid a hand getting a good jab when the cover is closed.  There are
ways to do it with the right mounting arrangements a

Re: [PSES] Safety Interlock Switches

[CR]

On 6/10/2014 11:39 PM, Nyffenegger, Dave wrote:

  EN 60950-1 says that interlocks must be designed to prevent inadvertent 
reactivation and that the ability to operate the interlock with a test finger 
is considered likely to cause inadvertent reactivation of the hazard.


How do they expect the equipment to powered up for troubleshooting?

The  300 Kg office copier; it has a combination safe holding the interlock.

Cortland Richmond

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Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[John Woodgate]

In message , dated Wed, 11 Jun 2014, 
John Woodgate  writes:



No: their scopes are, or should be, mutually exclusive.


Should be (perhaps) but aren't.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[John Woodgate]

In message 
, 
dated Wed, 11 Jun 2014, "McCallum, Andy"  
writes:



Politics ? Oh dear (or words to that affect)
So as 55012 is harmonised under the EMC directive you could in theory 
meet that directive but fail the automotive directive.


No: their scopes are, or should be, mutually exclusive. The point is 
that 2 dB isn't going to make the difference between a product that is 
safe to use in a car and one that isn't, especially as production units 
could vary by more than 2 dB when installed (e.g. due to different 
wiring). So there really seems no technical reason for the difference, 
but different people and different committees prepared the documents.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Safety Interlock Switches

[Nyffenegger, Dave]

Machinery Directive and LVD are most certainly applicable to the products in 
question, these types of products have been around for quite a while and the 
NRTLs and independent EU CE inspectors agree.  I believe this also means EN 
60204-1 and EN 60950-1 are also applicable respectively.

I'm not familiar with EN ISO 14119 so I guess I'll need to get a copy to 
review.  Are there any specific ties between then Machinery Directive and/or EN 
60204-1?  In other words, to make the argument that compliance to EN ISO 14119 
is also applicable to the product assuming the Machinery Directive is or 
non-compliance to EN ISO 14119 is non-compliance with the Machinery Directive.

EN ISO 13849 is applicable, I've been reviewing it but I'm not an expert with 
it yet.  (Products do use some pneumatics and vacuum) Certainly the PLr has an 
impact on the interlock system design but I was hoping to get some general 
feedback on the specific questions independent of the PLr.

Thanks
-Dave

From: Douglas Nix [mailto:d...@ieee.org]
Sent: Wednesday, June 11, 2014 9:32 AM
To: Nyffenegger, Dave
Cc: EMC-PSTC@LISTSERV.IEEE.ORG; ibm...@gmail.com
Subject: Re: [PSES] Safety Interlock Switches

Dave,

After reading your original post, I have to question the use of EN 60204-1 for 
your application. Can the product reasonably be considered to fit within the 
scope? Considering the first paragraph of the scope of the 2006 edition:

 This part of IEC 60204 applies to the application of electrical, electronic 
and programmable
electronic equipment and systems to machines not portable by hand while 
working, including
a group of machines working together in a co-ordinated manner.

I especially question the use of EN 60204-1 in conjunction with EN 60950. There 
seems little value and much confusion to be generated by this decision.

Since the product falls under the scope of the Machinery Directive, you should 
be looking at EN ISO 14119, Safety of machinery - Interlocking devices 
associated with guards - Principles for design and selection, for information 
on the interlocking device. This standard will provide you with the 
requirements for selection and installation of interlocking devices, and I can 
assure you that, unless the risk related to the hazards inside the machine are 
extremely low, the device you describe won't pass muster. This standard also 
describes the requirements for defeat resistance of the interlocking device.

In addition, a functional safety analysis of the safety related control 
functions is required under the Machinery Directive, and for that you can 
choose either EN ISO 13849-1 & -2, or IEC 62061 (see EN 60204-1:2006, 9.4). The 
former is generally easier to use, but the latter may fit the design of the 
equipment better, since it doesn't sound like there is any fluidic power 
systems, and the equipment is predominantly electrical/electronic and 
programmable.

I'd be happy to discuss this with you in more detail off line if you're 
interested.

Doug Nix
+1 (519) 729-5704
d...@ieee.org

On 11-Jun-14, at 08:20, Nyffenegger, Dave 
mailto:dave.nyffeneg...@bhemail.com>> wrote:


Yes, Omron D3D series.  And I also have a similar looking switch on my HVAC air 
handler in the primary circuit made in 1995  for US (probably no CE).  I am 
concerned not only with the issue of inadvertent activation but also the 
operational acceptability (min operations).  Hence the questions about the 
applicable switch standards.  But I don't know if the argument presented where 
reactivation buy closing the switch by itself is not normally possible stands 
up.  The challenge with concealing behind a small hole is keeping the equally 
small switch actuator protrusion from becoming a hazard itself.  For example 
when used with a hinged guard that opens up to avoid a hand getting a good jab 
when the cover is closed.  There are ways to do it with the right mounting 
arrangements and offsets.

thanks
-Dave

From: IBM Ken [mailto:ibm...@gmail.com]
Sent: Wednesday, June 11, 2014 1:05 AM
To: Nyffenegger, Dave
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety Interlock Switches

I had a very similar situation.  Are you using a C&K or Omron switch?  I also 
remember seeing the switch and thinking it looks like the door light switch 
from an old refrigerator.  I have a very similar-looking switch in my home oil 
furnace (which is from the 1980s)

What we did was put the switch inside a little metal enclosure with a small 
hole on the top.  The panel then had a small metal protrusion which reached 
inside the hole, this way the test finger could never actuate the switch.

You could try to take your designer's argument to your NRTL, but I doubt they 
will accept it; I think the point is not that someone's finger slips onto the 
switch accidentally and activates it, but rather - a service person wants to 
see if the product he just worked on will start up and so pushes in the 
in

Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[McCallum, Andy]

John

Politics ? Oh dear (or words to that affect)
So as 55012 is harmonised under the EMC directive you could in theory meet that 
directive but fail the automotive directive.

Madness oh yes you explained its Politics.

Best Regards

Andy



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 11 June 2014 13:39
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

In message
,
dated Wed, 11 Jun 2014, "McCallum, Andy" 
writes:

>But the difference is only 2dB - I don't see the point.
Politics.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid 
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[Luke Turnbull]

I think the 2dB difference is because either CISPR 12 or 2004/104 had an 
allowance for conformity of production and the other one didn't - however, I 
can't be certain about this.  If this is really important to understand the 
difference, please email me directly and I'll put you in touch with people who 
know the story - chapter and verse.

Luke Turnbull

-Original Message-
From: McCallum, Andy [mailto:andy.mccal...@mottmac.com] 
Sent: 11 June 2014 13:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

Hi Tom

But the difference is only 2dB - I don't see the point.

Regards

Andy

-Original Message-
From: T.Sato [mailto:vef00...@nifty.ne.jp]
Sent: 11 June 2014 13:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

On Wed, 11 Jun 2014 12:28:44 +0100,
  "McCallum, Andy"  wrote:

> Can anyone explain the difference in the limits between the directive and EN 
> 55012.

EN 55012 is intended to protect off-board receivers, and 2004/104/EC (and ECE 
R10, CISPR 25, and OEM standards) are intended to protect on-board receivers.

Regards,
Tom

--
Tomonori Sato  
URL: http://homepage3.nifty.com/tsato/

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Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[Luke Turnbull]

The EC directive (and related documents) have tests to protect both on-board 
and off-board receivers.  The vehicle test is practically the same as CISPR 12 
and 55012.

Luke Turnbull

-Original Message-
From: T.Sato [mailto:vef00...@nifty.ne.jp] 
Sent: 11 June 2014 13:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

On Wed, 11 Jun 2014 12:28:44 +0100,
  "McCallum, Andy"  wrote:

> Can anyone explain the difference in the limits between the directive and EN 
> 55012.

EN 55012 is intended to protect off-board receivers, and 2004/104/EC (and ECE 
R10, CISPR 25, and OEM standards) are intended to protect on-board receivers.

Regards,
Tom

--
Tomonori Sato  
URL: http://homepage3.nifty.com/tsato/

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Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[John Woodgate]

In message 
, 
dated Wed, 11 Jun 2014, "McCallum, Andy"  
writes:



But the difference is only 2dB - I don't see the point.

Politics.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Safety Interlock Switches

[Nyffenegger, Dave]

Yes, Omron D3D series.  And I also have a similar looking switch on my HVAC air 
handler in the primary circuit made in 1995  for US (probably no CE).  I am 
concerned not only with the issue of inadvertent activation but also the 
operational acceptability (min operations).  Hence the questions about the 
applicable switch standards.  But I don’t know if the argument presented where 
reactivation buy closing the switch by itself is not normally possible stands 
up.  The challenge with concealing behind a small hole is keeping the equally 
small switch actuator protrusion from becoming a hazard itself.  For example 
when used with a hinged guard that opens up to avoid a hand getting a good jab 
when the cover is closed.  There are ways to do it with the right mounting 
arrangements and offsets.

thanks
-Dave

From: IBM Ken [mailto:ibm...@gmail.com]
Sent: Wednesday, June 11, 2014 1:05 AM
To: Nyffenegger, Dave
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety Interlock Switches

I had a very similar situation.  Are you using a C&K or Omron switch?  I also 
remember seeing the switch and thinking it looks like the door light switch 
from an old refrigerator.  I have a very similar-looking switch in my home oil 
furnace (which is from the 1980s)

What we did was put the switch inside a little metal enclosure with a small 
hole on the top.  The panel then had a small metal protrusion which reached 
inside the hole, this way the test finger could never actuate the switch.

You could try to take your designer's argument to your NRTL, but I doubt they 
will accept it; I think the point is not that someone's finger slips onto the 
switch accidentally and activates it, but rather - a service person wants to 
see if the product he just worked on will start up and so pushes in the 
interlock to see if what he fixed/replaced worked.

-Ken

On Tue, Jun 10, 2014 at 11:39 PM, Nyffenegger, Dave 
mailto:dave.nyffeneg...@bhemail.com>> wrote:
Hi folks,

I'm reviewing a design for some medium duty office/business equipment which 
handles mail and is subject to the Machinery and Low Voltage Directives i.e. EN 
60950-1 and EN 60204-1.  The design is using an interlock switch which I think 
is more suitable for turning the light on/off in a refrigerator.  The switch is 
in the secondary low voltage circuit to operate the main contactor coils.  It's 
only rated for 50K min operations (electrical) and is approved to UL 1054 and 
VDE  EN 61058-1.  The electrical specs are fine for the application.  I'm not 
familiar with these standards so one question is if those standards in anyway 
qualify or disqualify (by using the switch in a way not intended) the switch 
for use as a safety interlock.

I thought I read in one of the safety standards that interlock switches should 
be designed/rated to last the lifetime of the equipment (based on some estimate 
of number of operations in application).  But I haven't been able to find that. 
 Does that sound familiar to anyone?  My estimate is that 50K operations is 
much lower than the number of operations over the lifetime of the equipment.

A similar older switch is only rated by the manufacturer for 6K operations.  EN 
60950 2.8.7 basically requires a minimum of 10K operations the way I read it.  
Am  I right in thinking the 6K switch would not be suitable for interlock usage 
regardless of other aspects?

These switches have plungers that can be easily finger operated once the guards 
are opened.  EN 60950-1 says that interlocks must be designed to prevent 
inadvertent reactivation and that the ability to operate the interlock with a 
test finger is considered likely to cause inadvertent reactivation of the 
hazard.  The argument from the designer with this switch is that once the 
guard/interlock is open, reclosing the interlock by itself will not re-energize 
the protected circuit and therefore there is no inadvertent reactivation.  This 
is because the control circuit requires operation of another start switch in 
order to energize.  This assumes there is no concurrent failure of the control 
circuit while the interlock is being manually overridden, one person can't 
operate/reach the start switch and override the interlock at the same time, and 
no second person operating the start switch while someone is overriding the 
interlock.  My question is if this argument actually holds with!
 out violating the EN 60950 requirement.

thanks

David P. Nyffenegger, PMP, SM-IEEE

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Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[McCallum, Andy]

Hi Tom

But the difference is only 2dB - I don't see the point.

Regards

Andy

-Original Message-
From: T.Sato [mailto:vef00...@nifty.ne.jp] 
Sent: 11 June 2014 13:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

On Wed, 11 Jun 2014 12:28:44 +0100,
  "McCallum, Andy"  wrote:

> Can anyone explain the difference in the limits between the directive and EN 
> 55012.

EN 55012 is intended to protect off-board receivers, and 2004/104/EC (and ECE 
R10, CISPR 25, and OEM standards) are intended to protect on-board receivers.

Regards,
Tom

--
Tomonori Sato  
URL: http://homepage3.nifty.com/tsato/

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Re: [PSES] Automotive Directive 2004/104/EC and EN 55012

[T.Sato]

On Wed, 11 Jun 2014 12:28:44 +0100,
  "McCallum, Andy"  wrote:

> Can anyone explain the difference in the limits between the directive and EN 
> 55012.

EN 55012 is intended to protect off-board receivers, and 2004/104/EC
(and ECE R10, CISPR 25, and OEM standards) are intended to protect
on-board receivers.

Regards,
Tom

-- 
Tomonori Sato  
URL: http://homepage3.nifty.com/tsato/

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[PSES] Automotive Directive 2004/104/EC and EN 55012

[McCallum, Andy]

All

Can anyone explain the difference in the limits between the directive and EN 
55012.

Regards

Andy


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[PSES] Test equipment rentals - Northeast USA

[Doug Powell]

 ‎All,‎I have a client who is looking for a for test equipment rental company specializing in compliance testing. This would include tests such as Surge, EFT/Burst for both 100kHz and 1 MHZ, also Ringwave, CDNs and so on.  It may be possible there will also be a need for other equipment such as accessibility probes, impact spheres, etc.A rental house that carries well known brands is preferred and must be able to provide equipment with full ISO 17025 calibration with data from an accredited calibration lab.   My client is in the Philadelphia area and I am personally unfamiliar with any local sources.  So any thing in the Northeast states will do fine.Thanks, - dougDouglas Powellhttp://www.linkedin.com/in/dougp01   
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