RE: Telecom Regulatory Generator

2000-03-30 Thread Nick Evans

You could also try our regulatory fact files.  More info at
www.gentel.co.uk
Enter the site and follow buttons and links to Information or Approvals
Info

The site has been modified a little lately so if you have trouble let me
know.

Nick
Genesys
-Original Message-
From:   owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org] On Behalf Of
Peter Merguerian
Sent:   30 March 2000 12:02
To: emc-p...@majordomo.ieee.org
Subject:Telecom Regulatory Generator


Dear All,

Anyone knows of a telecom regulatory generator where one can easily find
the regulatory requirements in a particular country, including but not
limited to: regulating authorities and contacts; test labs and contacts;
applicable safety/emc/telecom standards and mutual recognitions (acceptance
of international test reports).

Thanks
Peter Merguerian
Managing Director
Product Testing Division
I.T.L. (Product Testing) Ltd.
Hacharoshet 26, POB 211
Or Yehuda 60251, Israel

Tel: 972-3-5339022 Fax: 972-3-5339019
e-mail: pmerguer...@itl.co.il
website: http://www.itl.co.il






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RTTE Directive Survivala guide revision 2

1999-10-12 Thread Nick Evans
Dear All

Following developments and clarifications by a number of bodies, we have placed 
revision 2 of our RTTE Directive Survival Guide on to our website 
www.gentel.co.uk  

As before the guide is free to download to any interested party.  The guide can 
be located by following the RTTE links.

If anyone has problems with the download and would like a copy e-mailed, please 
contact Claire Townsend at gene...@dial.pipex.com or Matthew Sykes at 
matthew_sykes_gene...@msn.com

Best regards


Nick




RTTE Directive information available

1999-09-15 Thread Nick Evans

Dear all

If it useful to anyone, we have just placed a copy of our RTTE Directive
Survival Guide on our web site.   This document is available for free
download by following the RTTE links on the web site www.gentel.co.uk

If anyone has any problems with the download, please let me know and we can
e-mail you or mail a copy, etc.

Best regards


Nick




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RE: Upgrades

1999-08-03 Thread Nick Evans

Brian

Your obligation is to ensure that all products placed on the market, in
whatever configuration, comply.   There is no stipulation as to how you
place products and configurations on the market.

Whether you need to CE mark the upgrade itself depends on what the upgrade
is.   If the upgrade is a component (or components) that have no
functionality on their own then it in itself does not need to be CE marked
but you must ensure that the instrument when fitted with the upgrade
continues to comply.Normally this would be done when developing the
upgrade by investigation and testing if required of the instrument + upgrade
combination.   As noted by others you would then need to update or issue a
new Delcaration of Confirmity covering the new product configuration.

Assuming that you are confident that any installation instructions provided
to the customer are straightforward and do not allow any risk that the
upgrade could be fitted in such a way as to compromise the compliance of the
instrument then all is fine.

Your customer does not need to get the instrument re-tested.I would say
that your obligation is to take all reasonable steps to ensure that the
instrument when fitted with the upgrade (following the instructions you
provide) continues to comply and that you have documentation to support this
argument (ie technical file, Declaration, etc) if asked to defend your
claim.

Best regards


Nick Evans
Genesys

-Original Message-
From:   owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of Brian Harlowe
Sent:   02 August 1999 16:57
To: emc-p...@ieee.org
Subject:Upgrades


Please can you give me some opinions on the following.

I have a customer who has one of our Scientific instruments that he
wishes to upgrade.

If I supply him with CE marked everything to allow him to carry out
this up grade and I also provide him with a detailed manual on how to
install and connect up these items to be emc compatible.

Do my responsibilities end there and does the customer have to get
the instrument re tested and CE mark it?

Regards

Brian Harlowe
* opinions expressed here are personal and in no way reflect the position of
VG Scientific

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RE: Basic EMC Standards

1998-06-17 Thread Nick Evans
The Basic EMC standards, ie EN 61000-4 series (or at least some of them),
are harmonised and are published as EN documents in each member state.
They are not in themselves, however, designated for use under the scope of
the European EMC directive.

The use of these basic standards is entirely by reference made to them by
other product specific or product generic standards which are designated for
use through the official journal.   The most obvious example of this, with
respect to the EN 61000-4 series, is the latest (1997) version of the
generic immunity standard, EN 50 082-1.   This standard makes reference to
various of the EN 61000-4 series and calls upon the use of the test methods,
etc described in these basic standards.

When deciding on which EMC standards to apply to a particular product for
EMC compliance, you should always start with the product specific standards
which are designated through the Official Journal.If there are no
product specifics, fall back to the most appropriate generic standards.
Once these have been identified, they will tell you which basic standards
you need to look at and how to apply them.

If anyone would like a copy of the latest (full) list of EMC standards
published in the OJ, let me know.   We have this as a word document.

Best regards


Nick Evans
Managing Director
Genesys IBS Ltd
Worldwide ITT Product Design  Compliance
Tel:+44 1600 710300
Fax:+44 1600 710301
Mobile: +44 385 367348  (GSM)
E-mail: nick_evans_gene...@msn.com
(if sending attachments, please copy e-mail to our central e-mail account:
gene...@dial.pipex.com)
Web:Http://www.gentel.co.uk/genesys
-Original Message-
From:   owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of Chris Dupres
Sent:   16 June 1998 22:47
To: R. Heller
Cc: emc-pstc
Subject:Basic EMC Standards

Hi R.Heller.

You wrote:
 Are basic EMC standards harmonized? I have yet to see a basic EMC
standard show up in the OJ. The 61000-4 series are widely used but are not
in the OJ. What gives?

Basic EMC standards must be harmonised, that is the point of national
legislation coverings such things.   The generic standards are EN 50081 and
EN50082.  In the UK they are BS EN 50081 etc.  EN meaning Euronorm =
harmonised.

You can only meet the requirements of national legislation if you comply
with harmonised standards otherwise the Common Market principle will not be
relevant.

The 61000 etc series are based on IEC standards to which all European
States are signatory, but in many cases I don't think you can claim
compliance with them in order to apply a CE mark.   The EN standards ,
though, do call up these standards in the 'Annexes' at the back so in that
respect they are relevant.

Another couple of cents worth of humble opinion.

Chris Dupres
Surrey, UK.



RE: GS Requirements

1998-04-27 Thread Nick Evans
I think the following is basically right.

One of the fundamental objectives (and requirements) of the original treaty 
of Rome, which has been re-inforced since as the treaty has been amended, 
is the free movement of goods within the EU and the removal of barriers to 
trade.In recent years, under the terms of the new approach 
directives, there has been a move towards presumption of conformity for 
products placed on sale provided that such products carry the CE mark.

There is European directive numbered 83/189/EEC which addresses procedures 
to be followed for introducing new technical requirements.   This directive 
is basically targetted at removing the possibility of new barriers to trade 
being introduced.

83/189/EEC requires certain procedures to be followed by the European 
Commission when it comes to commissioning new technical standards. 
 Importantly, it also defines procedures to be followed by each member 
state if implementing new or modified technical regulations ( I think this 
is the case, it always used to be).  This procedure basically requires 
notification through the European Commission of the proposed standard, 
regulation, etc.   This notification and draft of the relevant documents is 
translated by the EC into the native language of each member state and 
distributed for review by relevant authorities in each member state.   In 
this way, each member state has the opportunity to review and oppose new 
national legislation and standards.

Also, importantly, the issue of European standards under the scope of 
product compliance directives have the force of law in that conflicting 
national standards must be withdrawn by the final designated date of 
withdrawal.

So I think the bottom line is that a EU state can implement a national 
regulation relating to product compliance provided that it does not 
conflict with existing European legislation and European standards and that 
the regulations have passed successfully through the 83/189/EEC procedures. 
  This actually is a little bit of a joke as the  documents distributed 
under 83/189/EEC have always been circulated to a very small audience and 
some quite interesting things have found their way through with no 
objections.

I didn't catch the beginning of this thread so I am not sure what the 
original problem was reported to be.   However, there is an 
anti-competition unit at the EC which monitors this kind of thing that is 
usually very interested to hear of problems with respect to barriers to 
trade.   Also, I think I am right in saying that each member state has an 
anti-competition unit which also makes all the right noises about fighting 
the good fight in terms of barriers to trade.

Best regards


Nick Evans
Managing Director
Genesys IBS Ltd
Worldwide ITT Product Design  Compliance
Tel:+44 1600 710300
Fax:+44 1600 710301
Mobile: +44 385 367348  (GSM)
E-mail: nick_evans_gene...@msn.com
(if sending attachments, please copy e-mail to our central e-mail account: 
gene...@dial.pipex.com)
Web:Http://www.gentel.co.uk/genesys

-Original Message-
From:   WOODS, RICHARD [SMTP:wo...@sensormatic.com]
Sent:   27 April 1998 13:07
To: 'emc-pstc'
Subject:RE: GS Requirements

This has been a very interesting thread. There appears to be two distinct
groups of thought. One group believes that an EU state can enforce a state
law affecting trade as long as it is not in violation of a Directive.
Another group seems to believe that no EU state may enforce a law the tends
to impede trade. To this latter group I ask the question, what is the legal
basis for this claim?

Richard Woods
Sensormatic Electronics
wo...@sensormatic.com
Views expressed by the author do not necessarily represent those of
Sensormatic.



RE: System Integration

1997-07-15 Thread Nick Evans
You need to be careful talking to the European Commission. You've got to 
remember that the European directives have to be transposed into national law. 
   It is all very well and good the European Commission continually 
backtracking and re-defining what they really meant in the EMC directive but 
it has already been transposed into national law in each member state and some 
of what the Commission is saying now, particularly in the respect of CE+CE = 
CE does not tie up with the legal interpretation in most Member States.  The 
EMC directive (and national law) clearly indicates that the responsibility is 
for supplying compliant (final) products onto the market.

The European Commission guidance document does state that under certain 
conditions CE+CE=CE should give confidence in the final system but the 
supplier of the final system still takes responsibility (and must sign a 
declaration of conformity) for that system.(Important Note:   The first 
drafts of the guidance document did not have the requirement that the final 
system supplier produce a declaration of conformity but this was thrown out 
following review and comment by the Member States!)  It is also stated in the 
guidance document that suppliers of modules and sub-assemblies should provide 
adequate installation instructions in order to allow their products to be 
installed whilst maintaining compliance.

This guidance document has to be taken with a pinch of salt.Technically, 
the CE+CE=CE argument is significantly flawed in many situations.   Also our 
experience with surveillance authorities (particularly in the UK) is that 
argument but the module was CE marked! may be OK for a backstreet PC 
assembler whose resources are limited but would not be OK for a multi-million 
dollar organisation who would be expected to at least do some testing on final 
products.   The key principle is due dilligence.  It has to be recognised 
that sub-assembly manufacturers can only do so much themselves in terms of 
testing in representative host systems and providing installation 
instructions.

It is unreasonable to place all of the burden on sub-assembly manufacturers.   
What you are saying is that these manufacturers would need to take 
responsibility for any installation of their products into any host system and 
would legally be bound to this responsibility.   System Integrators have to 
take some responsibility, particularly if installing sub-assemblies in 
non-standard applications where installation instructions could not be 
expected to be valid. 

The European Commission is not the final authority in this matter.   Their 
guidance is just that, guidance and often it is initially hasty and 
technically flawed.   Talk to people responsible for enforcing the EMC 
directive and relevant national legislation in each country and see what they 
have to say about your particular company and situation!  Also talk to some 
Competent Bodies and Notified Bodies and see what they have to say.

Of course, this may all be a bit of a moot argument given the limited 
resources applied to enforcement in most Member States but that is another 
discussion.

Nick

--
From:  owner-emc-p...@majordomo.ieee.org on behalf of Arthur Poolton (MEPCD)
Sent:  14 July 1997 10:19
To:  'emc-p...@ieee.org'
Subject:  System Integration

Ladies  Gentlemen,
I thought that you may be interested in the outcome of a meeting between a 
well-known PC manufacturer and the European Commission, DGIII (Elena 
Santiago) concerning the
legalities of System Integration :-

1.  An integrator of a Core PC (motherboard, power supply, case  drives 
- 6.4.2 para. 4 of the EMC Directive Guidelines) need only follow the
Conformity Assessment Guidelines (10.1 or 10.2 of the Directive, 8.1 or 8.2 
of the Guidelines).  This entails using CE Marked modules, following module 
instructions exactly, providing a Declaration of Conformity, and providing 
a CE Marking on the product.  If he/she does this, then the resultant
product NEED NOT BE TESTED.  Further, if an enforcement organization later 
tests the product and it fails the emissions limits, the System Integrator 
will still be considered in compliance!  The enforcer is then supposed to
turn his/her sights on the module suppliers for not providing sufficient
instructions, and leave the System Integrator alone.  Accordingly, if the
System Integrators under prosecution in the UK followed the Guidelines but 
did not test, they should not be prosecuted.

2.  EMC auditing of production is not mandatory.  Even though EN55022, in
describing the 80/80 rule, indicates that auditing is mandatory, the
European Commission views this as not a standards issue and beyond the
scope of CENELEC to specify.  They also consider this requirement in
conflict with their guidelines and are taking steps to have CENELEC remove 
this wording from EN55022.

3.  We also brought up an issue regarding the use of prototypes for
evaluation and demonstration,