[PSES] RED

[Pearson, John]

Hi All

So let me see if I have this right please guys.

RED is being fully implemented in June 2017.  In this radio receiver 
requirements are now essential requirements.  So come June 2017, focusing on 
technical performance only for now, to supply to the EEA we need product to 
meet these additional requirements.  However to date only 25 specs or so have 
been written and published as Harmonized Standards under the RED and those of 
course include radio receiver performance.  The other required HS’s are in 
draft form in various levels of preparation.

My question is what does the European Commission expect us to do with products 
not covered by these RED Harmonized Standards and if standards do suddenly 
emerge in the next few weeks how are we meant to meet them with 6 months or so 
notice?  One answer of course is to use a Notified Body but is that all we are 
being left with?

Does anyone else feel this is a mess?

Thanks

John

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Re: [PSES] Updating EU ErP reports for Level VI adapters?

[Pearson, John]

Hi David

Agreed re intrinsic value.

The EU in particular has been that way ever since the EMC and LV directives 
impose new requirements (harmonized stds) on arbitrary dates for continued 
supply of product lines.  Energy efficiency is becoming another with, I hear, 
plans for a level VII.

John



From: Dave Heald [mailto:emcp...@gmail.com]
Sent: 06 November 2015 22:48
To: Pearson, John
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Updating EU ErP reports for Level VI adapters?

Hi John,
  Agreed.  EMC & Safety reports should be updated as applicable as these could 
have meaningful changes in performance.

I was mostly focusing on the need for updated ErP (Energy related Products) 
reports, as they solely deal with energy efficiency & the Level VI change is to 
move to more efficient supplies.
It would seem that if I'm meeting the requirements with a less efficient EPS, 
that re-testing to qualify a more efficient EPS is simply a bureaucratic 
exercise that has little intrinsic value & just costs me money and time to 
re-test my entire product line.

Best Regards,
-David





On Fri, Nov 6, 2015 at 7:40 AM, Pearson, John 
<john.pear...@polycom.com<mailto:john.pear...@polycom.com>> wrote:
Hi

Change of PSU to VI could affect EMC performance Radiated and Conducted as well 
as Immunity for the wacky places that insist on this (EEA etc).  You need 
representative results for these requirements (i.e. test reports with the 
correct/representative PSU)

John


From: Rodney Davis 
[mailto:rodney.da...@mitel.com<mailto:rodney.da...@mitel.com>]
Sent: 03 November 2015 21:20
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] Updating EU ErP reports for Level VI adapters?


I would say that the limits are being exceeded, hence a manufactures technical 
letter of explanation in support of your DoC is sufficient ! No test required. 
Test data must be available though to support your technical judgement?


Rodney Davis


From: Dave Heald <emcp...@gmail.com<mailto:emcp...@gmail.com>>
Sent: Tuesday, November 3, 2015 4:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Updating EU ErP reports for Level VI adapters?

(apologies if this is a re-post - it's not showing on my 
mail.google.com<http://mail.google.com> inbox, so I'm assuming it didn't go 
through the first time around)

All,
  Do you think it's necessary to update EU ErP reports when transitioning from 
a Level V to a Level VI adapter?  Or would an explanatory statement suffice?

Technically our products are HiNA anyway, so that further reduces our 
compliance burden, but even without that consideration it would be nice to 
explain this away in my compliance folder rather than to pay for re-testing & 
new reports for all of our products.


Thoughts & feedback appreciated!

Best Regards,
-David Heald

Regulatory Engineer / Project Manager
Cradlepoint
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Al

Re: [PSES] Updating EU ErP reports for Level VI adapters?

[Pearson, John]

Hi

Change of PSU to VI could affect EMC performance Radiated and Conducted as well 
as Immunity for the wacky places that insist on this (EEA etc).  You need 
representative results for these requirements (i.e. test reports with the 
correct/representative PSU)

John


From: Rodney Davis [mailto:rodney.da...@mitel.com]
Sent: 03 November 2015 21:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Updating EU ErP reports for Level VI adapters?


I would say that the limits are being exceeded, hence a manufactures technical 
letter of explanation in support of your DoC is sufficient ! No test required. 
Test data must be available though to support your technical judgement?


Rodney Davis


From: Dave Heald >
Sent: Tuesday, November 3, 2015 4:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Updating EU ErP reports for Level VI adapters?

(apologies if this is a re-post - it's not showing on my 
mail.google.com inbox, so I'm assuming it didn't go 
through the first time around)

All,
  Do you think it's necessary to update EU ErP reports when transitioning from 
a Level V to a Level VI adapter?  Or would an explanatory statement suffice?

Technically our products are HiNA anyway, so that further reduces our 
compliance burden, but even without that consideration it would be nice to 
explain this away in my compliance folder rather than to pay for re-testing & 
new reports for all of our products.


Thoughts & feedback appreciated!

Best Regards,
-David Heald

Regulatory Engineer / Project Manager
Cradlepoint
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Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) Where?

[Pearson, John]

Hello

If you are selling into the EU your DoC declaring to the harmonized std 
(assuming you are taking this route) states that you are confirming that each 
and every item of product placed upon the market is compliant to the limit and 
not just the test sample.  Does that not mean you will either have to test 
every item prior to shipment and sale, or apply some level of margin to feel 
comfortable in making this declaration?  Of course testing every item is the 
total solution but is likely cost prohibitive unless you sell very high value 
items in single figures a year.  Even if the stds makers have applied margin in 
writing the spec the DoC process does not recognize this and requires the 
above.  

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: 13 October 2015 18:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?

Bingo. Safety and EMC standards have 'built-in' margins per committee members 
that cared to converse with this plebian.

A supplier's margin is in internal policy, or is per your customer's spec, or 
is per empirical numbers from the end-use installation. Measurement Uncertainty 
is not necessarily a 'margin', but does have statistical relevance.

Control of manufacturing process and product construction cannot be reasonably 
specified in EMC standards, unless you want to write EMC standards to the 
content and format of safety standards. Have fun with that.

Indeed, per Mr. Crane, why assume anything?

Brian
Sr Burrito and Ale Test Engineer


-Original Message-
From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]
Sent: Tuesday, October 13, 2015 9:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] Stricter limits than legal (CISPR11, IEC, etc,) 
Where?

All the issues being raised regarding possible variability must be known to the 
members of various standards committees. Does anyone know that the issues are 
*not* taken into account when the committees set test levels? If standards are 
followed, including any instructions regarding EUT sampling and measurement 
uncertainty, why assume additional margins must be applied?

Regards,
Lauren Crane
KLA-Tencor

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Re: [PSES] EMC Benign devices (was:RE: [PSES] Friday night conundrum)

[Pearson, John]

Hi

Thanks for the latin lesson John.

Equipment which is inherently benign in terms of electromagnetic compatibility 
is excluded from the scope of the EMC Directive25. Equipment is considered 
inherently benign in terms of electromagnetic compatibility if:
* its inherent physical characteristics are such that it is incapable of 
generating or contributing to electromagnetic emissions which exceed a level 
allowing radio and telecommunications equipment and other equipment to operate 
as intended; and,
* it will operate without unacceptable degradation in the presence of the 
electromagnetic disturbance normally present in its intended environment.

Both conditions need to be met in order to classify equipment as inherently 
benign.

I don't yet see that this excludes cards from compliance.  Does anyone know how 
much power these cards draw.

Thanks

John


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 18 August 2015 07:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC Benign devices (was:RE: [PSES] Friday night conundrum)

In message
b8f3f23a24ba3f4688cc5275527cb98bc4526...@chwpiexc10.sats.corpmailto:b8f3f23a24ba3f4688cc5275527cb98bc4526...@chwpiexc10.sats.corp,
 dated Mon, 17 Aug 2015, Grasso, Charles 
charles.gra...@echostar.commailto:charles.gra...@echostar.com
writes:

John Woodgate posted  Like a digital watch, it's regarded as 'EMC
benign', so no EMC test and no CE mark

The FCC defines an EMC benign device as: Digital  devices that have a
power consumption of 6 nanowatts or less, such as digital watches and
solar calculators. Section 15.103(f)

Do the EU EMC standards have an equivalent?

It's not in standards because it is a regulatory issue, and those can't be put 
in standards. It's in 1.1.4 of the Guide for the EMC Directive 2004/108/EC (8th 
February 2010).
--
OOO - Own Opinions Only. With best wishes. See 
www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk When I turn my back on the 
sun, it's to look for a rainbow John Woodgate, J M Woodgate and Associates, 
Rayleigh, Essex UK

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Re: [PSES] Friday night conundrum

[Pearson, John]

Hi

Thanks

When the card is inserted in the reader it is powered.  Thus it also makes 
sense to test the card in a representative reader as well as the other way 
around. 

Re CE marking I can't find the document on Europa you referred to Charlie to 
(can you point to it please for interest).  Can John remember what TUV Sud said?

I don't understand de Minimus.  Clearly better read than me (that's not hard, 
don't ever partner with me in a pub quiz.  Useless)

John


-Original Message-
From: CR [mailto:k...@earthlink.net] 
Sent: 15 August 2015 15:00
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Friday night conundrum

On 8/15/2015 9:01 AM, John Woodgate wrote:
 The enquiry was about credit cards, not RFID. 


Good to be reminded.  If the card contains a device used only in the reader, it 
would make sense for the *reader* to be tested -- with representative cards.

Near-field reading is possible with some cards, and those could only be tested 
in the presence of a properly operating near-field reader, which includes the 
transmission of verification codes to prevent unauthorized access to financial 
and personal data (and funds!), not just just an energizing EM field.

THAT applies to a number of access cards/badges used since the 1980's , so 
presumably has already been addressed some years ago in the appropriate 
standards.


Cortland Richmond

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[PSES] Friday night conundrum

[Pearson, John]

Should a Credit Card carry the CE mark

Chip and pin along with NFC

Discuss?

John Pearson, Senior Director, Corporate Product Compliance
Polycom (UK) Ltd. |Singleton Court Business Centre Wonastow Road Ind. Est., 
Monmouth, NP255JA, United Kingdom | T: +44 1753 723165 | M: +44  7968 064105 

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Re: [PSES] Off Topic - Warranty Question

[Pearson, John]

Very good John, and not only humorous!


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 10 July 2015 14:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Off Topic - Warranty Question

In message
04cab9802ba27a409548dd47de1da7efd3429c1...@slomailprd01.polycom.com,
dated Fri, 10 Jul 2015, Pearson, John john.pear...@polycom.com
writes:

Also see Article 5 in its entirety over time limits.  Cl 3 is important 
and the way this is worded helps to add clarity to the 2 year time 
limit (the unless this presumption is incompatible with the nature of 
the goods bit)

Is your head spinning now?

Yes. I was going to complain about my calendar, because it lasted only a year. 
(;-)
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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Re: [PSES] Off Topic - Warranty Question

[Pearson, John]

This is not  a two year warranty.  If the customer buys an item it may last six 
months say and it may be expected to last six months due to its form fit and 
normal expectation (article 2.2) and this is fine.  The 2 year time limit is to 
allow the user to become aware that the item has not lasted as long as normally 
expected not for the item to last that long.  That is a strange concept I know. 

Also see Article 5 in its entirety over time limits.  Cl 3 is important and the 
way this is worded helps to add clarity to the 2 year time limit (the unless 
this presumption is incompatible with the nature of the goods bit)

Is your head spinning now?

John


-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 02 July 2015 17:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Off Topic - Warranty Question

Hi Scott:


One of our international sales guys thought the EU had a minimum two year 
warranty requirement.

True.  Directive 1999/44/EC.

See:  
http://europa.eu/youreurope/citizens/shopping/shopping-abroad/guarantees/index_en.htm

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:1999:171:0012:0016:EN:PDF


Best regards,
Rich

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Re: [PSES] USB Mains Outlet sockets

[Pearson, John]

Hello 

Been doing some more reading

SI 1994 No 1768 is the Plug and Socket safety regs for the UK.  In this it 
appears that this product falls outside the scope of this regulation. 

It seems to be only classifiable under the SI as a Part 1 product, quote  any 
plug, socket or adaptor ordinarily intended for domestic use at a voltage of 
not less than 200 volts, to any fuse link which is suitable for use in any such 
plug being a standard plug and to any cartridge fuse link which is suitable for 
use in any other plugs and adaptors but does not apply to any electrical device 
specified in Schedule 1 to these Regulations. .  

However Schedule 1 specifically excludes Any plug, socket or adaptor which 
incorporates any other electrical device (other than a F fuse link, switch or 
indicator light).  As the product includes a PSU it appears not to be covered 
by this legislation.  

Where does that leave a potential supplier?
 
John

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 14 March 2015 18:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

In message 004401d05e7c$d87423b0$895c6b10$@btinternet.com, dated Sat,
14 Mar 2015, Richard Marshall richard.marshal...@btinternet.com
writes:

All I can add is that it appears to be unclear whether a roof-top 
photovoltaic array on domestic premises is a fixed installation
within the EC EMC Directive definition. The UK authorities say it is 
not - presumably for the common-sense view of John Allen that it is 
unreasonable to make a homeowner a Responsible Person.

That ruling may pre-date the BS7671 amendment, which makes the classification 
as a fixed installation very much less onerous than it might have been 
previously.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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Re: [PSES] USB Mains Outlet sockets

[Pearson, John]

Hi

Entertaining Friday discussion, thank you all.  I tend to conclude that for the 
UK these items probably should not be on the market  if:


* They claim compliance to EN 60950-1 in the DoC as in that I believe 
that reliance on the breaker as the disconnect device is not recognized (must 
be part of the equipment like a mains plug surely)

* Are not CE marked

* Are not Energy Efficiency marked with Level V or above

* Incapable of being Megger tested, they also seem to fail the 
suitable for use requirement of UK Sale of Goods Act

BTW personally I agree that regulations may need to catch up on this but to 
somehow enable them to meet requirements.  Everything else, whilst application 
of requirements may be a little cookie, seems sort of clear.  It appears to be 
an ITE PSU hardwired into the supply as well as an electrical supply accessory.

Any more thoughts?  Concur?

John


From: John Cotman [mailto:john.cot...@conformance.co.uk]
Sent: 13 March 2015 15:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

This doesn't answer all of the question, but the ASTA certification database is 
searchable on line by various search terms, including by manufacturer, so you 
should be able to see if a claim is valid, and hopefully it should tell you 
what standards ASTA has applied.

John Cotman
Senior Consultant
Direct line: +44 1298 873841
Mobile: +44 7793 770730
email: john.cot...@conformance.co.ukmailto:john.cot...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, 
www.conformance.co.ukhttp://www.conformance.co.uk/
Registered in England, Company No. 3478646



On 13 Mar 2015, at 14:43, John Woodgate 
j...@jmwa.demon.co.ukmailto:j...@jmwa.demon.co.uk wrote:


In message 
04cab9802ba27a409548dd47de1da7ef8d8c128...@slomailprd01.polycom.commailto:04cab9802ba27a409548dd47de1da7ef8d8c128...@slomailprd01.polycom.com,
 dated Fri, 13 Mar 2015, Pearson, John 
john.pear...@polycom.commailto:john.pear...@polycom.com writes:


Questions from the compliance side

The short answer to your questions is that these products have appeared very 
quickly on the market and the standards world simply hasn't had enough time to 
catch up.

Wall sockets, especially in UK, are subject to very different regulations and 
standards than plug-in products, and the relevant standards committees have, in 
the past, had little need to talk to each other.

ASTA may have taken a 'notified body' approach in view of the lack of specific 
standards, i.e. applied standards partially and safety principles in addition, 
to determine whether a product is safe.
--
OOO - Own Opinions Only. With best wishes. See 
www.jmwa.demon.co.ukhttp://www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Jim Bacher j.bac

[PSES] USB Mains Outlet sockets

[Pearson, John]

Here is a Friday discussion topic for you guys.

In the UK we are seeing a plethora of aftermarket 250v AC mains outlet sockets 
which are supplied for installation, it seems by the homeowner, (this has been 
a traditional practice over here.  In the US I understand that this happens 
less).  The advantage of these sockets is that they also give you 2 USB 
charging ports in the wall as well as two socket outlets.  I see large 
distributors (Screwfix, Amazon.co.uk and Ebuyer for e.g.) selling several 
https://www.google.co.uk/search?q=lap+mains+socketsourceid=ie7rls=com.microsoft:en-GB:IE-Addressie=oe=gfe_rd=crei=edoCVauNDquD8Qekq4HgBQgws_rd=ssl#rls=com.microsoft:en-GB:IE-Addresstbm=shopq=usb+mains+power+socket+outlet
.  Look out for an explosion of these items is my suspicion as the idea of 
getting rid of plug in USB chargers is very appealing, even to me!


Questions from the compliance side

Energy Efficiency
Single rail PSU's are subject to mandatory Energy Efficiency marking and 
performance.  All the units I have seen thus far do not mark or declare any 
performance figures.  The PSU being wired into the mains does not to my mind 
preclude these products from compliance with the Eco-design Directive and 
278/2009 specifically, or am I missing something?

Safety of USB port
All of the devices I have seen are stamped with EN 60950-1 on the back thus 
appear to be purporting compliance this std.  Not seen any DoC's.  I do not 
understand how they can meet the Disconnect Device requirements of CL 3.4 by 
design unless the mains switches are the disconnect device.  I see however that 
the switches only turn off the mains to the traditional BS1363 sockets.  Any 
thoughts?

Certification
Several of these items claim ASTA certification.  I wonder what ASTA certified 
them to.  I suspect not EN 60950-1.  Is that not misleading?

Insulation test
At least one of these devices states Do not Megger the device.  Apparently 
the USB charge circuitry cannot stand high voltage and would likely or possibly 
fail.  As it is recommend in the UK that home wiring be regularly checked for 
insulation issues is this product fit for purpose ?

CE marking
Several of these are not CE marked.  See this 
http://www.amazon.co.uk/Connekt-Gear-Power-Socket-Charging-white/dp/B00KO1KDN4

Rather bizarrely one supplier with a seemingly non CE marked product issued 
this http://www.groupgear.co.uk/catalogue/27-2000-Counterfeit-warning.pdf

Does outlet sockets require CE marking by the placer on the market and if they 
also incorporate a PSU for charging ITE product doesn't it become an ITE 
product itself subject to EMCD and LVD and thus require CE marking for that 
purpose also?



All this said it seems that they are getting great reviews but likely from the 
user benefit rather than the above

Look forward to interesting responses.

John


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Re: [PSES] test errors

[Pearson, John]

I find it surprising that an accredited lab can have test standards listed on 
their scope undated.  How can certain accredited authorities do that?

John

John Pearson, Senior Director, Corporate Product Compliance
Polycom (UK) Ltd. | Singleton Court Business Centre Wonastow Road Ind. Est., 
Monmouth, NP255JA, United Kingdom  | T: +44 1753 723165 | M: +44 7968 064105


From: dward [mailto:dw...@pctestlab.com]
Sent: 18 December 2014 21:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] test errors

I don’t think the original discussion is or was centered on testing ‘black 
boxes’ or even the fact that a manufacturer should know his product and what it 
takes to get it in the market. The original discussion was that labs which are 
supposed to know what they are doing, because they have a standards listed on 
their scope of accreditation, may not actually know what they are doing.  It 
does not deal with off the wall testing specific to a particular manufacturer, 
it deals with common everyday expertise.
Any lab can test anything or anyway they want, but if they are saying the 
testing is to a specific standard and is in accordance with their scope, then 
they need to make sure it is.  If it is not, then the accreditations generally 
only say (paraphrased) ‘if you didn’t test it correctly to the std on the 
scope, then don’t say you did.  If you did test it according to your scope, 
then the results should clearly show you did.’
Thanks

​
Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and I sintended for the exclusive use of the 
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and/or legally privileged.  Any unauthorized use that may compromise that 
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or attachments(s) are free from computer virus or other defect.  Thank you.

From: Grasso, Charles [mailto:charles.gra...@echostar.com]
Sent: Thursday, December 18, 2014 1:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] test errors

Hello Brian – with regards to the “Top Secret” box. It is my understanding that 
the customer it responsible
for assuring that their product is tested to the correct standard and the test 
lab is responsible for testing
the delivered product  according to that standard. So I would say that yes – 
you did what the customer asked
so you tested the product correctly.

Best Regards
Charles Grasso
Compliance Engineer
Echostar Communications
(w) 303-706-5467
(c) 303-204-2974
(t) 3032042...@vtext.commailto:3032042...@vtext.com
(e) charles.gra...@echostar.commailto:charles.gra...@echostar.com
(e2) chasgra...@gmail.commailto:chasgra...@gmail.com

From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: Thursday, December 18, 2014 8:26 AM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] test errors

Well said. I’m really enjoying this topic.

Expecting customers to be Compliance Test experts would be nice, but a little 
like expecting people to have to be auto mechanics to be able to take their 
cars to the repair shop. But like auto repair shops, EMC and Safety test labs 
are all in it for the money. They have payroll to meet just like any business 
and they are not likely to turn away work because it is something they are not 
100% sure they know how to properly test until the customer arrives with it. 
And in those cases I’m sure they do the best they can.

We also expect test labs to be experts in hundreds of standards and how they 
apply to an infinite number of products, configurations, and supporting 
equipment; many of which they may know absolutely nothing about how it even 
works.  Such expectations are unrealistic.

I once tested a metal box with something moving inside. “Top Secret” according 
to the customer. Did we test it correctly? How would I know? We did what the 
customer wanted.

Yup, errors and mistakes are going to happen. That is part of life. Though I am 
not a fan of accreditation, one cannot expect anything more than an attempt to 
minimize the errors. I don’t think a stack of procedures in a file or book in 
the manager’s office is very affective at eliminating error, but it is better 
than nothing. And as test labs become more competitive, a long list of 
accreditations is like money in the bank.

Personally, I like the “Accountability Method” or as mentioned early the 
“looking over the shoulder” method. This is where the test setup and testing is 
overseen by a second person in the lab who can most often see problems the main 
tester cannot see right in front of his face. It is like having someone proof 
read your memos (I 

Re: [PSES] Certification of Unique Equipment

[Pearson, John]

Hi

I would suspect that someone supplying equipment, clearly designed for use by 
employees of a company, shpould meet the below requirements regadless as to 
supply equipment not meeting this would deem the product unsuitable for use.  
In such a suituation the user would likely have a claim against the supplier.
John


From: Scott Aldous [mailto:0220f70c299a-dmarc-requ...@ieee.org]
Sent: 15 December 2014 16:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Certification of Unique Equipment

Hi Kevin,

Thanks for the input. Does OSHA provide any guidance on what test data can be 
considered sufficient to demonstrate safety in order to satisfy item 3?

On Sun, Dec 14, 2014 at 7:06 PM, Kevin Robinson 
kevinrobinso...@gmail.commailto:kevinrobinso...@gmail.com wrote:
Hi Rick,

I work in the office that administer's OSHA's NRTL Program, so my answer will 
be focused exclusively on product safety of equipment intended for use in a 
U.S. workplace.

OSHA only has regulatory authority over employers, so from OSHA's perspective, 
you as an equipment manufacturer have no legal requirement to have your 
equipment tested or certified.  The employer (your customers) have the legal 
requirement to demonstrate to OSHA that the equipment is Acceptable as 
defined in 29 CFR 1910.399 
http://www.gpo.gov/fdsys/pkg/CFR-2014-title29-vol5/pdf/CFR-2014-title29-vol5-sec1910-399.pdf
 which reads:

Acceptable. An installation or equipment is acceptable to the Assistant 
Secretary of Labor, and approved within the meaning of this subpart S:
(1) If it is accepted, or certified, or listed, or labeled, or otherwise 
determined to be safe by a nationally recognized testing laboratory recognized 
pursuant to §1910.7; or
(2) With respect to an installation or equipment of a kind that no nationally 
recognized testing laboratory accepts, certifies, lists, labels, or determines 
to be safe, if it is inspected or tested by
another Federal agency, or by a State, municipal, or other local authority 
responsible for enforcing occupational safety provisions of the National 
Electrical Code, and found in compliance
with the provisions of the National Electrical Code as applied in this subpart;
or
(3) With respect to custom-made equipment or related installations that are 
designed, fabricated for, and intended for use by a particular customer, if it 
is determined to be safe for its intended use by its manufacturer on the basis 
of test data which the employer keeps and makes available for inspection to the 
Assistant Secretary and his authorized representatives.


However, as you are likely aware, most manufacturers take on the burden of 
having their products certified to minimize liability, to minimize problems 
with local inspectors, and as a selling point to their clients.

One of a kind equipment would fall under item 3 above.  To be acceptable (to 
OSHA), you as the manufacturer must evaluate and test the equipment and provide 
the data to your customer so they can provide it to OSHA if asked.  While there 
has been no official interpretation, the general feeling within OSHA is if you 
make 1 product, you are fine with option 3 above.  If you make 2, you now must 
comply with option 1 above (certified by an NRTL).

Of course, the requirements imposed by a local AHJ may be different, and my 
responses do not consider any liability risks.

If you have nay further questions, feel free to contact me at my OSHA account:

Kevin Robinson
OSHA NRTL Program
robinson.ke...@dol.govmailto:robinson.ke...@dol.gov
202-693-1911tel:202-693-1911

On Sun, Dec 14, 2014 at 3:32 PM, Rick Busche 
rick.bus...@qnergy.commailto:rick.bus...@qnergy.com wrote:
It is always my desire to provide products that are CE Marked for Europe and 
NRTL listed for North America. That said, I continue to find products delivered 
for our own production environment that carry no safety marking that I can 
identify. I have discussed this concern with other engineers who worked in 
previous companies who indicated that they NEVER were required to have 
certification on their products.

As I understand it I could deliver a one of a kind system to a unique customer 
without certification in North America. At what point is certification 
required? Is it based on the quantity of systems, the customer, the AHJ, OSHA 
or marketing?  Is it allowable to ship a unique, prototype system to a 
specialized customer, without NRTL?

Thanks

Rick

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Re: [PSES] Test facility insurance

[Pearson, John]

An oft missed but important issue for manufacturers using 3rd party safety test 
labs is the indemnity liability clause in the agreement.  Manufacturers need to 
be careful that indemnity is sufficient in the event of a faulty test issue 
that results in a recall or incident.

Cost and competence are not the sole considerations.

John
From: Charlie Blackham [mailto:char...@sulisconsultants.com]
Sent: 25 September 2013 15:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Test facility insurance

Scott

I recall a conversation on another email reflector which noted that a very 
large NRTL had re-written it's client agreement and, in the event of an error, 
their liability was limited to the cost of re-testing that particular clause!

On a wider note, consequential losses are typically excluded from many 
contractual agreements and liability limitations for UK consultants and test 
labs seem to be limited to 100% or 125% of order value.

Regards
Charlie

From: Scott Xe [mailto:scott...@gmail.com]
Sent: 25 September 2013 14:36
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Test facility insurance

It is very interesting subject.  From time to time, we appoint 3rd party 
laboratories for the testing work.  In case there is an error regardless of 
interpretation or careless mistake, it may result in rework cost of several 
million dollars.  I do not believe any 3rd party testing laboratory to cover 
this loss.  Is there any insurance or infrastructure to cover it.

Thanks and regards,

Scott

On 24/9/13 5:47 AM, Ken MacGrath khcmacgr...@aol.com wrote:
Hello Group,

I'm the owner of an EMC/Product Safety/Reliability/Environmental test facility 
in New Hampshire and would greatly appreciate your input on insurance. What 
would you suggest for coverage, and should test engineers have professional 
liability insurance?

Thank you!

Ken MacGrath
Core Compliance Testing Services, LLC
79 River Road (Route 3A)
Hudson, NH 03051
603.889.5545

www.corecompliancetesting.comhttp://www.corecompliancetesting.com

-


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Re: [PSES] Smart Batteries

[Pearson, John]

Hi Bob

I don't know what's applicable to these products personally but the official 
answer is to go through the EMCD OJ listing for harmonized stds 
http://ec.europa.eu/enterprise/policies/european-standards/harmonised-standards/electromagnetic-compatibility/index_en.htm
 and decide based upon the applicable scope of each listed std.  You may end up 
with a set of requirements rather than just one.  If nothing is applicable use 
a generic std EN 61000-6- whatever.

MiLStd 461 is not a harmonized std.

best

John

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of rehel...@mmm.com
Sent: 24 August 2012 12:48
To: John Woodgate
Cc: emc-p...@ieee.org; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Smart Batteries

But what standards apply in order to carry a CE mark in its own right for EMC?

From what I understand, a smart battery is tested to the EMC standard that 
covers the equipment that it is installed in. What I am not clear on is the 
EMC standards that apply to testing smart batteries on their own (evidently 
MilStd 461 is one though).

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




From:John Woodgate j...@jmwa.demon.co.ukmailto:j...@jmwa.demon.co.uk
To:EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Date:08/23/2012 03:31 PM
Subject:Re: [PSES] Smart Batteries
Sent by:emc-p...@ieee.orgmailto:emc-p...@ieee.org




In message 
cc5bf2b9.2b66e%ken.ja...@emccompliance.commailto:cc5bf2b9.2b66e%25ken.ja...@emccompliance.com,
 dated Thu, 23
Aug 2012, Ken Javor 
ken.ja...@emccompliance.commailto:ken.ja...@emccompliance.com writes:

And that is what my post addressed by stating that the battery during
test is performing its intrinsic function of storing and dispensing
electrical energy.

OK, all that means is that in Europe it has to carry a CE mark in its
own right for EMC as well as for any other applicable Directives.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Instead of saying that the government is doing too little, too late or too
much, too early, say they've got is exactly right, thus throwing them into
total confusion.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] Light Bulb provokquium

[Pearson, John]

Hi

Any opinions on this?

http://www.mnn.com/earth-matters/energy/blogs/skirting-eu-law-the-rebranding-of-incandescent-bulbs-as-heat-balls

Do the members feel that the legislation is working or is it counterproductive 
in respect of ecological aims not just from energy saving from cradle to grave 
(including manufacture and hazardous material).  And what about the claim that 
the lost heat in colder climes needs to be replaced with other sources.

John

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Re: [PSES] Light Bulb provokquium

[Pearson, John]

Hi John

Thanks

My thinking is it isn't just price $'wise but also price to the environment in 
both material and energy?

JohnP

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: 24 August 2012 16:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Light Bulb provokquium

In message
CAByvTVPDdQ343GbF8=AxXZSgajd7cvH1Q=P2zp98Q+QHAD-=c...@mail.gmail.com,
dated Fri, 24 Aug 2012, Doug Powell doug...@gmail.com writes:

Make the alternative bulbs economically competitive and dump the 
legislation.

Chicken and egg; the industry wouldn't have spend a lot of RD $$$ on CFLs and 
LED lamps if the ban hadn't been introduced. Prices are coming down, but not 
equal yet.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead 
of saying that the government is doing too little, too late or too much, too 
early, say they've got is exactly right, thus throwing them into total 
confusion.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] CE Marking Provoqium

[Pearson, John]

Hi

For the sake of discussion, I would like to open up for debate the suggestion 
the EU process is one of the most unreasonably excessive in the world.

With the exception of China and Brazil this is the one major region that 
imposes retrospective recertification costs due to the introduction of new 
Safety and EMC standards on an existing design.  I would like to suggest that 
the dates of cessation of conformity impose a requirement to reassess (test if 
necessary depending on the variance to the old standard) which achieves little 
and costs manufacturers unnecessarily.

Can we discuss?

Thanks

John


John Pearson, Senior Director, Corporate Product Compliance
Polycom | Singleton Court Business Centre, Wonastow Road Ind. Est., Monmouth, 
UK, NP25 5JA | T: +44-(0)1753-723165 | M: +44-(0)7968-064105


This communication (including any attachments) may contain privileged or 
confidential informa­tion of Polycom and is intended for a
specific individual.  If you are not the intended recipient, you should delete 
this communication, including any attachments without
reading or saving them in any manner and you are hereby notified that any 
disclosure, copying, or distribution of this communication,
or the taking of any action based on it, is strictly prohibited.



-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sykes, Bob
Sent: 17 August 2012 14:11
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EC vs EU suffix

CE = Check Everything or Compliance Expensive

...It's Friday

-Bob

-Original Message-
From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of 
Sundstrom, Michael
Sent: Friday, August 17, 2012 8:45 AM
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] EC vs EU suffix

And here all these years I thought it meant: Compliance Extraordinary...


 Michael Sundstrom
OHD TREQ Dallas
Electronic Lab Analyst EMC Lead
(214) 579 6312  office
(940) 390 3644  cell
KB5UKT

-Original Message-
From: Crane, Lauren 
[mailto:lauren.cr...@kla-tencor.com]mailto:[mailto:lauren.cr...@kla-tencor.com]
Sent: Thursday, August 16, 2012 4:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EC vs EU suffix

The CE marking remains the same.

The meaning is 'Caveat Emptor'   ;-)

Regards,
Lauren Crane
KLA-Tencor
-Original Message-
From: Brian Oconnell 
[mailto:oconne...@tamuracorp.com]mailto:[mailto:oconne...@tamuracorp.com]
Sent: Thursday, August 16, 2012 2:44 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EC vs EU suffix

Conformité Européenne

-Original Message-
From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org]On Behalf Of Doug 
Powell
Sent: Thursday, August 16, 2012 2:30 PM
To: peter_kelle...@dell.commailto:peter_kelle...@dell.com
Cc: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EC vs EU suffix


And the CE mark, what happens to it?

CE = Communauté Européenne

--
Thanks, -doug

Douglas E Powell
doug...@gmail.commailto:doug...@gmail.com
http://www.linkedin.com/in/dougp01



On 8/16/12, peter_kelle...@dell.commailto:peter_kelle...@dell.com 
peter_kelle...@dell.commailto:peter_kelle...@dell.com wrote:
 EU = European Union
 EC = European Community

 The Treaty of Lisbon  which came into force in in December 2009
 provided
for
 the absorption of the entity known as the European Community  by the
 European Union.

 Regards

 Peter.

 From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
 [mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of 
 Scott
 Xe
 Sent: 16 August 2012 15:37
 To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: EC vs EU suffix

 The EU regulations/decisions/directives published after 2010 have a
 suffix of EU rather than EC.  Is there any particular reason for this change?

 Scott

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Jim Bacher:  

RE: EN 300386 - RE: New Official Journal list of EMC standards

[Pearson, John]

There is equipment that is both



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier
Kristiaan
Sent: 06 November 2008 13:00
To: Barker, Neil; SYKES WILLIAM T-WRQ876; emc-p...@ieee.org
Subject: RE: EN 300386 - RE: New Official Journal list of EMC standards



Neil,

This question has been raised a few times in the past years: 300386 excludes
terminal equipment beyond the NTP (ref. scope)

 

Kind regards,

 

Kris Carpentier

Regulatory  Approvals

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Barker, Neil
Sent: donderdag 6 november 2008 12:04
To: 'SYKES WILLIAM T-WRQ876'; emc-p...@ieee.org
Subject: RE: EN 300386 - RE: New Official Journal list of EMC standards

 

William

 

I would expect that this standard is listed under the RTTE Directive, not the
EMC Directive, even though it is an EMC standard; it is primarily an RTTE
standard.

 

Neil Barker

Manager

Central Quality

 

e2v

106 Waterhouse Lane, Chelmsford, Essex, CM1 2QU, England

Tel: +44 (0)1245 453616

Mobile:   +44 (0)7801 723735

Fax:+44 (0)1245 453571

 www.e2v.com http://www.e2v.com/ 

 

P Consider the environment: do you really need to print this e mail?

 

 



From: SYKES WILLIAM T-WRQ876 [mailto:william.t.sy...@motorola.com] 
Sent: 05 November 2008 18:36
To: emc-p...@ieee.org
Subject: EN 300386 - RE: New Official Journal list of EMC standards

All:

EN 300 386 V1.4.1 (04-2008) Electromagnetic compatibility and radio spectrum
matters (ERM) — Telecommunication network equipment — Electromagnetic
compatibility (EMC) requirements is missing from the list.  

This ETSI standard list the following dates (I hope this copied table passes
without corruption!):

 

National transposition dates 

Date of adoption of this EN: 

11 April 2008 

Date of latest announcement of this EN (doa): 

31 July 2008 

Date of latest publication of new National Standard 

 

or endorsement of this EN (dop/e): 

31 January 2009 

Date of withdrawal of any conflicting National Standard (dow): 

31 July 2011 

Based on the dates above, should this one have been listed, eventually
superseding v1.2.1, v1.3.1, v1.3.2, and v1.3.3 (all supposedly still
simultaneously valid)?

Is EN 300 386 V1.4.1 usable as a Harmonized Standard giving a presumption of
conformity, or wait until published?

William T. Sykes

Compliance Engineer

Motorola Home  Networks Mobility

101 Tournament Drive

Horsham, PA 19044

215-323-2619

william.t.sy...@motorola.com 

 

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ralph McDiarmid
Sent: Wednesday, November 05, 2008 1:13 PM
To: emc-p...@ieee.org
Subject: FW: New Official Journal list of EMC standards

 

 EN50178:1997 is missing from this list.  Has it been superseded,  or is it
now a rogue standard?

Ralph McDiarmid, AScT 
Compliance Engineering Group 
Xantrex Technology Inc. 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian Jones
Sent: Wednesday, November 05, 2008 1:23 AM
To: emc-p...@ieee.org
Subject: New Official Journal list of EMC standards

 

Everyone

 

A new list of harmonised standards for 2004/108/EC was published in the OJ on
4 November.  It may be downloaded from here

http://eur-lex.europa.eu/LexUriServ/Lex
riServ.do?uri=OJ:C:2008:280:0014:0032:EN:PDF 

 

You will see that A1 to EN 55022:2006 has been listed.  It may be used now,
but does not have to be applied until 1 October 2010.

 

Best wishes

 

Brian  

 

Brian Jones

EMC Consultant

 

http://www.ieeecommunities.org/emc-pstc 


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