Re: [PSES] Safety requirements in US

[Tyra, John]

Some states have legal requirements for electrical products to be NRTL approved

From: Richard Nute [mailto:ri...@ieee.org]
Sent: Sunday, July 24, 2016 8:26 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety requirements in US


Hi Scott:

For consumer and household products, compliance with CPSC requirements is 
required.

No.  Only products considered “substantial product hazards” such as hair dryers 
need comply with CPSC requirements.  However, any consumer product that injures 
someone is subject to CPSC recall order.

What about OSHA?

Electrical products that are used by employees are required to be NRTL 
certified.


Best regards,
Rich



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Re: [PSES] CB Philosophy Questions

[Tyra, John]

I know that for the Chinese CCC mark the CQC accredited labs will not accept a 
generic “various” description for their critical components lists.

What we have done in our CB reports to satisfy them is list a component as 
“Model XYZ or equivalent” in the CB critical components list.

The China lab will still insist on only listing the specific part #, like Model 
XYZ, in their critical components list but at least now they don’t hassle us 
over the descriptions in the CB report critical components list. They even 
required us to be specific about the pcb Mfg on the critical components list 
which is usually accepted as  being listed as “Various” by other countries.

From: Kevin Robinson [mailto:kevinrobinso...@gmail.com]
Sent: Thursday, April 30, 2015 10:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CB Philosophy Questions

All,

You may want to reach out to the National Committee in your Country, For the US 
National Committee (USNC), the best point of contact would be Joel Solis at 
NEMA who serves as the Secretary.  They might be able to bring this up at a 
future CB Scheme meeting and encourage all countries to establish similar 
guidelines for mentioning alternate components in CB reports.

Brian is correct about the NRTL Program removing component standards from its 
list of appropriate test standards.  The NRTL Program was never intended to 
include components as it only applies to end products used in the workplace, 
but over the years, some predominantly component standards were added to the 
list, and OSHA is in the process of removing those standards. That said, NRTLs 
will still be allowed to accept component certifications from others when 
evaluating end products.


Kevin Robinson
a.k.a The OSHA NRTL Director Guy :-)
robinson.ke...@dol.govmailto:robinson.ke...@dol.gov

On Thu, Apr 30, 2015 at 9:21 PM, Brian Oconnell 
oconne...@tamuracorp.commailto:oconne...@tamuracorp.com wrote:
Doug,

Thanks, will look for this stuff. The only stuff seen to date for component 
evaluation is in UL PAGs, CSA informs, and the IECEE CTL stuff. Are these 
component acceptance 'guides' part of the National Differences in a TRF, or 
regulatory law administered by the state?

According to the OSHA guy that is the NRTL program director, they are in 
process of removing component standards from their official listing (do a 
search on the EMC-PSTC listserv archives for his comments).

Do not understand Having a CB report is not a foregone guarantee that it will 
always be accepted. Do you mean that the TRF was rejected because of poor 
component descriptions, or that changes to the C/C table in the TRF was 
rejected, or something else?

Brian

-Original Message-
From: dougp01 [mailto:doug...@gmail.commailto:doug...@gmail.com]
Sent: Thursday, April 30, 2015 5:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CB Philosophy Questions

Brian

I suggest you reference the IECEE website and read through the component 
acceptance requirements for each target country, including the USA. I haven't 
checked but there may also be such a document for the -2-29 you mention.  These 
can be found in the same general area as the national differences documents. 
Both are interesting reading.   If you are not able to access these contact 
your certifying agency and they should be willing to supply copies.

As for what is typical in each country, I have learned that this is variable. 
In general the office tasked with reviewing and accepting your CB report‎ 
definitely feels they have the authority to do as they please. And to a large 
extent this is true.   Having a CB report is not a foregone guarantee that it 
will always be accepted.

‎Regards, - doug

Douglas Powell
http://www.linkedin.com/in/dougp01
  Original Message
From: Brian Oconnell‎
Sent: Thursday, April 30, 2015 6:39 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Reply To: Brian Oconnell
Subject: Re: [PSES] CB Philosophy Questions

In both procedural controls and scoped test standards, North America 
(NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar where 
state-enforced codes do not contradict the scoped standard.

It has been several years since the NRTLs and other test agencies have 
routinely accepted a blanket 'equivalent' in the C/C table of submitted reports 
for all components. Typically stuff such as components that not across mains, 
or are not bridging insulation or a safety boundary can be cited in general 
terms with no particular mfr name or part no.

The issue is that the agency assessment engineer cannot be certain which 
characteristics of a component are important to something on the C/C table. So 
they test your box with the assumption that the design team has verified 
performance only for the particular combination of stuff on the BoM and the 
board layout that was submitted for assessment.

The other issue is that there is no formal IEC or SCC or 

Re: [PSES] Safety standards versus safety engineering

[Tyra, John]

With all due respect I think this is a generalization as when I worked at TUV I 
assisted companies who were very safety conscience and it came down from the 
top. I am also lucky to currently work for a company where the upper management 
is very supportive of product safety.

That being said I also worked with companies when at TUV who wanted to do the 
minimum and in some cases argued against compliance with the standards or  who 
I felt tried to hide noncompliance's from me.

IMHO it really depends on the company and the culture of that company.



From: Richard Nute [mailto:ri...@ieee.org]
Sent: Friday, March 06, 2015 6:16 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering



I disagree.

The decision-makers leave the safety as well as the specific design to the 
experts.  The decision-makers look at the bigger picture as to the features of 
the product, how it fits into the product mix, and other high-level stuff.  
They don't engage in the specific design and they don't engage in the safety 
aspects.

Trying to raise safety to a decision-maker level is futile, and expecting them 
to champion safety is also futile.  Safety and EMC are things that must be 
applied to a product.  The decision-makers know and expect that.  The only 
thing that matters is if either causes a schedule delay.


Best regards,
Rich




From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Friday, March 06, 2015 1:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

And not so cordially either!

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: 06 March 2015 21:47
To: 'Bonsen, Robert'
Subject: RE: [PSES] Safety standards versus safety engineering

Robert

You have obviously been there!

I sympathise, completely - I have too!

John Allen
W. London, UK

From: Bonsen, Robert [mailto:robert.bon...@hp.com]
Sent: 06 March 2015 21:21
To: John Allen
Subject: RE: [PSES] Safety standards versus safety engineering

Good points, all, especially this one. Those not involved with larger companies 
often miss that safety is only a part of the bigger picture, unfortunately. 
Thus, the decision makers are rarely sufficiently educated, experienced or even 
interested in championing safety.

That is left to the guys at the bottom, who, when accused of making pro-safety 
calls against bigger business goals, are typically cordially invited to find 
employ elsewhere.

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Re: [PSES] Japan PSE Mark for external AD/DC adapter

[Tyra, John]

The Japan Denan law has two different levels of regulation


1.  Category A Specified products: These require accredited third party 
testing and certification. These types of product require to be marked with the 
PSE diamond mark. Wall/ Floor wart power supplies fall under this category

http://www.jet.or.jp/common/data/en/law/pse/list_of_items.pdf


2.  Category B Non-Specified Products: These types of products are a self 
declaration so you can use your UL/CB report which covers the Japanese National 
Deviations to self declare and mark your product with the (PS)E circle mark.

http://www.meti.go.jp/english/policy/economy/consumer/pse/index.html#press

http://www.jet.or.jp/en/law/pse/

Be aware that there is more to importing a power supply into Japan then just 
having the PSE diamond mark on the supply. You must have an registered 
importer, reporting supplier, who is willing to take responsibility for the 
power supply. The reporting supplier importer or Agent is required to obtain 
Certificates of Conformities form the PS vendor for all power supplies imported 
into Japan. The importer or Agent must get a an original signature copy of the 
PSE certificate from the power  supply vendor to keep on record.

METI will at some point audit the reporting supplier to be sure they are 
collecting the Certificates of Compliance from the PS Mfg. and that that they 
have copies of the original signature certificates on file.

I can send you a power point presentation which helps explain the process if 
interested.

Hope this helps.











From: Charlie Blackham [mailto:char...@sulisconsultants.com]
Sent: Friday, February 06, 2015 3:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Japan PSE Mark for external AD/DC adapter

All

Client is buying external wall-wart AC-DC power supply

*5V/2A output

*UL Listed

*IEC + CB report (+ TUV GS mark)

*Output is LPS (15VA measured)

Under Electrical Appliance and Material Safety Law - does this absolutely need 
a PSE mark for Japan or is manufacturer declaration supported by above also 
permitted?

If so, does anyone know someone who makes an external wall wart PSU that meets 
the above, but also has PSE, KCC and CCC certification (and a large label :) )

Regards
Charlie



Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
LinkedIn: 
uk.linkedin.com/in/charlieblackham/http://uk.linkedin.com/in/charlieblackham/
Web: www.sulisconsultants.comhttp://www.sulisconsultants.com/
Registered in England and Wales, number 05466247

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Re: [PSES] Japan PSE Mark for external AD/DC adapter

[Tyra, John]

Just one clarification as I noticed what I wrote may be unclear.

The power supply Mfg must create a CoC for each power supply to be imported 
into Japan. This means every time they build a power supply that you will 
import into Japan you must have a separate CoC for that supply. As part of the 
CoC there is a visual inspection, functional  and production line testing which 
must verified for each supply  and the results listed on the CoC. There does 
not seem to be any official CoC form so we created our own based on the 
required content.

One way to avoid creating individual CoC's for each power supply is to do a 
batch CoC where you reference a serial number run for a specified period of 
production.

We ask our vendors to do this on a monthly bases but for large volume 
production this may need to be done for a shorter period of time as the 
inspectors name must be on the CoC and if there were 100K power supplies built 
that month it would be impossible for one person to have tested each supply and 
METI may question this during their audit.

Some of the above was learned based on feedback from METI when our Japan 
facility was audited so I feel pretty confident it is accurate. If anyone has 
had a different experience I would be interested in hearing what you have found.



From: Tyra, John
Sent: Friday, February 06, 2015 9:48 AM
To: 'Charlie Blackham'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Japan PSE Mark for external AD/DC adapter

The Japan Denan law has two different levels of regulation


1.  Category A Specified products: These require accredited third party 
testing and certification. These types of product require to be marked with the 
PSE diamond mark. Wall/ Floor wart power supplies fall under this category

http://www.jet.or.jp/common/data/en/law/pse/list_of_items.pdf


2.  Category B Non-Specified Products: These types of products are a self 
declaration so you can use your UL/CB report which covers the Japanese National 
Deviations to self declare and mark your product with the (PS)E circle mark.

http://www.meti.go.jp/english/policy/economy/consumer/pse/index.html#press

http://www.jet.or.jp/en/law/pse/

Be aware that there is more to importing a power supply into Japan then just 
having the PSE diamond mark on the supply. You must have an registered 
importer, reporting supplier, who is willing to take responsibility for the 
power supply. The reporting supplier importer or Agent is required to obtain 
Certificates of Conformities form the PS vendor for all power supplies imported 
into Japan. The importer or Agent must get a an original signature copy of the 
PSE certificate from the power  supply vendor to keep on record.

METI will at some point audit the reporting supplier to be sure they are 
collecting the Certificates of Compliance from the PS Mfg. and that that they 
have copies of the original signature certificates on file.

I can send you a power point presentation which helps explain the process if 
interested.

Hope this helps.











From: Charlie Blackham [mailto:char...@sulisconsultants.com]
Sent: Friday, February 06, 2015 3:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Japan PSE Mark for external AD/DC adapter

All

Client is buying external wall-wart AC-DC power supply

*5V/2A output

*UL Listed

*IEC + CB report (+ TUV GS mark)

*Output is LPS (15VA measured)

Under Electrical Appliance and Material Safety Law - does this absolutely need 
a PSE mark for Japan or is manufacturer declaration supported by above also 
permitted?

If so, does anyone know someone who makes an external wall wart PSU that meets 
the above, but also has PSE, KCC and CCC certification (and a large label :) )

Regards
Charlie



Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
LinkedIn: 
uk.linkedin.com/in/charlieblackham/http://uk.linkedin.com/in/charlieblackham/
Web: www.sulisconsultants.comhttp://www.sulisconsultants.com/
Registered in England and Wales, number 05466247

-


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Re: [PSES] Symbols for CCC Approval

[Tyra, John]

I did a lot of research on the new CQC requirements when I first found out 
about them in early 2012 so some of the information, like drop dead date,  
below may have changed since then but here is a short version of what I learned.

I can only speak Audio/ Video Products  but this requirement was published in 
the 2011 version of GB8898 (IEC60065) December 30th 2011. The transition dates 
for implementation were published by CQC on April 11th 2012.

The drop dead date for meeting the new requirements and updating your CCC Mark 
certificates to the 2011 version of GB8898 was February 1, 2014 after which the 
certificate would be cancelled by CQC.

The short answer is there are two new requirements to consider


1.  Altitude: this requires meeting increased creepage requirements based 
on a max altitude of 5000m. Per IEC60664-1:2007 the clearance spacings increase 
by 1.48X the spacing for product for install below 2000M. As a result creepage 
distances will also increase as creepage cannot be less than clearance.


2.  Tropical Environment: In addition to testing the product for an ambient 
temperature of 45C the product must  meet reduced limits for Touch Current and 
for Hazardous Live parts.


If you cannot meet the new Altitude and /or Tropical Environment you can mark 
your product and put information in the user instructions.

Here is what I learned about the marking requirements. I can’t include the 
symbols due to list rules but the UL fact sheet Chuck posted the link for shows 
the symbols.

As an alternative to meeting the increased spacing requirements you can declare 
the  products are not meant for installation at altitudes above 2000m and add 
the following symbol and verbiage, in Chinese, to the product label.



(Symbol for Altitude placed here)

“Only suitable for use at areas with altitude less than 2000m”

“仅适用于2000m以下地区安全使用”
(Chinese translation)


If only the symbol is used on the product label, due to size constraints, it 
shall be explained in the user manual. The safety warning sentence shall use 
the language acceptable to the country where the apparatus is intended to be 
sold (simplified Chinese is acceptable).

For low voltage product with an external wall/floorwart power supply only the 
power supply will need be marked with the symbol or verbiage if noncompliant. 
The low voltage product is exempt from the marking requirement.

2. Tropical conditions

Products must now comply for use in Tropical conditions and ambient 
temperatures above 45°C. If the product  is evaluated for compliance for those 
conditions and is  found non-compliant the product must have the following 
symbol and verbiage on the label.



  (Symbol for Tropical 
conditions placed here)

“Only suitable for use at non-tropic climate areas”

“仅适用于非热带气候条件下安全使用”
(Chinese translation)


If only the symbol is used on the product label, due to size constraints, it 
shall be explained in the user manual.  The safety warning sentence shall use 
the language acceptable to the country where the apparatus is intended to be 
sold (simplified Chinese is acceptable).

For a system comprised of an external power supply and low voltage product both 
may need the markings if they don’t comply with all of the heating, reduced 
touch current and accessible hazardous voltage limits.

So you do have the choice of complying with the new requirements or marking 
your product and including information in the user’s manual.

Hope this helps and please feel free to correct anything you feel is not valid 
in my post.

Here is a link to the original CQC notice that started my research

http://www.cqc.com.cn/english/published/TechnicalStandards/InformationonNewVersionStandard/webinfo/2012/04/1333591221336637.htm





From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: Wednesday, October 01, 2014 8:30 AM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Symbols for CCC Approval

Are these symbols and text required for all EEE shipped to China or only ITE?  
This is the first I’ve heard of this.

The Other Brian

From: Mike Cantwell [mailto:mike.cantw...@outlook.com]
Sent: Tuesday, September 30, 2014 8:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Symbols for CCC Approval

Hi Scott,

This requirement comes from the National Differences published in the CB 
Bulletin. If the product is ITE, then clause 1.7.2.1 was modified. It is 
acceptable to provide the Chinese translation of the statements below as well 
as to use the icons. I can provide the translation if you email me directly. 
China doesn’t provide nice graphics for the symbol, you have to pull them right 
out of the CB report.

Add requirements of warning for equipment intended to be 

Re: [PSES] Battery certification issue

[Tyra, John]

Brian is 100% correct in that NRTL's are within their right to reject 
certifications and or test reports from other NRTL labs.

There is an NRTL here in the U.S. that has strict requirements about accepting 
component approvals from other NRTL's. They may accept other NRTL approvals but 
they have their own criteria on what is required in this case.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Wednesday, September 03, 2014 5:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Battery certification issue

In message
f0bbd00eaeb04a47b2cd56eace4fb...@blupr02mb116.namprd02.prod.outlook.com
, dated Wed, 3 Sep 2014, Brian Oconnell oconne...@tamuracorp.com
writes:

 There is no mutual recognition requirement among NRTLs,

That seems to be a recipe for chaos. Mutual recognition is a very strong 
requirement in Europe.
--
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] Battery certification issue

[Tyra, John]

NRTL's are like doctors. Just because someone has a medical degree does not 
mean they are good doctors. Same with NRTL's in my experience. Just because 
they are accredited does not mean they are good test labs. There are ones that 
do excellent jobs and others not so much.

When I was at TUV we went through the OSHA accreditation process and became an 
NRTL, for a small scope of standards at the time, and there is only so much 
they can check in a two day accreditation audit. They are also not experts in 
the standards they are accrediting a lab for. In our audit they checked for 
laboratory quality procedures, made sure we had the equipment to do the tests, 
and had us run a few tests to make sure we could do them but the auditors did 
not know the details of the standards they were auditing. Now maybe this has 
changed, as my experience is from 20+ years ago, but that is how it was back 
then.

Unfortunately NRTL's can impose additional requirements they feel are justified 
and  I doubt OSHA hears about these issues and I am not sure they could or 
would intervene in any case as IMHO the NRTL personnel generally know more 
about the requirements then OSHA does.

Personally I found the CB Scheme audits to be much more thorough as back 20+ 
years ago when I participated in one  the auditors were Engineers who were 
expert in the safety standards and did test us on our standard expertise. But 
even for the CB scheme audits are not all encompassing as I have found that 
NCB/CBTL expertise varies greatly depending on which lab you choose.



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Thursday, September 04, 2014 2:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Battery certification issue

In message
49b036a46b7543609a62f14804058...@bn1pr08mb059.namprd08.prod.outlook.com
, dated Wed, 3 Sep 2014, Nyffenegger, Dave 
dave.nyffeneg...@bhemail.com writes:

But the NRTLs are accredited and regularly reviewed/inspected by their 
accreditation bodies in order to  stay on OSHAs NRTL list as I am 
repeatedly reminded by the NRTLs otherwise their mark becomes worthless.

So the accreditation bodies tolerate arbitrary and unreasoning decisions by the 
NRTLs? Or do they just never get to hear about them?
--
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] Battery certification issue

[Tyra, John]

India is a member if the CB scheme yet they will not accept CB certifications 
and reports for the recent mandatory certification scheme that was rolled out 
in that country. They insist they must do complete retesting.

There was a recent IECEE vote to suspend their membership in the CB Scheme 
which I read recently failed so they are still a member so I am not so sure it 
is an issue for an NCB to reject another NCB members report.

http://www.google.com/url?sa=trct=jq=esrc=sfrm=1source=webcd=1ved=0CB4QFjAAurl=http%3A%2F%2Fnemko.com%2Fno%2Fprintpdf%2F1995ei=rsMIVKTcDM6BygSLnIKoBwusg=AFQjCNEzvrstbhagDtDQkLT1HmOlHk3zug

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Thursday, September 04, 2014 2:34 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Battery certification issue

In message 004e01cfc86b$6490a290$2db1e7b0$@pctestlab.com, dated Thu, 4 Sep 
2014, dward dw...@pctestlab.com writes:

But, if you go to one test house in one country and another test house 
in that same country, even in Europe, I am sure you will find that they 
do not all 'accept' each others data.

They would have a difficult job explaining why not.
--
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] Battery certification issue

[Tyra, John]

Thanks Kevin,

Appreciate the information as that clear up a lot of misconceptions on the NRTL 
program.

Please be sure I was not trying to criticize the OSHA NRTL program and as you 
said only sharing my experience from 20 years ago.

Sounds like OSHA has made great progress in the audit program to be sure there 
are subject matter experts as auditors who can better assess an applicant’s 
standard knowledge and expertise.

Regards,

John

From: Kevin Robinson [mailto:kevinrobinso...@gmail.com]
Sent: Thursday, September 04, 2014 3:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Battery certification issue

I do want to chime in here on a few issues to stop any misconceptions about the 
NRTL program.  First a disclaimer, in my former life, I worked for an NRTL, I 
now work for OSHA in the office that oversees the NRTL program.

The NRTL Program applies ONLY to end products used in the workplace.  It does 
not apply to component power supplies, plastic materials used to make 
enclosures, transformers, switches etc. that are used to make up end products.  
OSHA has no authority to regulate components (as they typically can't be used 
in the workplace alone), and as a result, components are not covered under the 
NRTL Program.  It is true that many organizations recognized by OSHA as NRTLs 
do issue certifications on components, however, they are doing so outside of 
their NRTL scope of recognition, and OSHA does not oversee the activities that 
an organization we recognize does with respect to components.  A common 
complaint that I hear is the policies of some NRTLs as to the acceptance of 
component recognitions.  As the NRTL program does not cover components, and 
OSHA has no authority to require one NRTL to accept component recognition from 
another NRTL (that authority lies with other Federal agencies if the policies 
are determined to be anti-competitive).

With that said, OSHA and the NRTL Program do recognize the importance that 
component recognitions play in product safety certifications, and we do allow 
NRTLs to accept component certifications from another NRTL provided they can 
demonstrate that they have reviewed the component certification documents to 
ensure that the component is being properly used, and that the organization 
that granted the certification had the specific standard in their NRTL scope.

As for mutual recognition of one NRTL's certification for an end product, 
again, OSHA does not have the authority to require one NRTL to accept 
certifications from another NRTL.  We do allow this, and we have established 
some guidelines if an NRTL does accept certifications from another NRTL, but we 
can not require an NRTL to do this.  Fortunately, it is very rare when an end 
product certified by NRTL #1 is then submitted to NRTL #2.


John Tyra was sharing his experiences when working a an NRTL 20 years ago.  I 
can say that times have changed.  20 years ago, the NRTL program was only 5 
years old, and the assessors were borrowed from other federal agencies.  The 
only guidance that OSHA or NRTLs had was what was written in the regulations 
(29 CFR 1910.7) which provides a very high level approach to the program.  The 
NRTL Program within OSHA is a very small group (we currently have a staff of 4 
people), 50% of whom are ex-NRTL employees, so we now have the expertise to dig 
deeper into the capabilities.  In the late 1990's, OSHA did publish additional 
guidance for the NRTLs, although, there has been only minor updates since that 
time.  I am very happy to say that we will soon (hopefully this week) be 
releasing portions of an updated draft directive (OSHA Policies and procedures) 
for the NRTL program that align our requirements with ISO 17025  17065.  On 
October 22, we will be holding a stakeholder meeting to discuss which direction 
to take the program in the future, and whether those changes will require rule 
making which can be a lengthy process.  Some of the topics presented in this 
thread will be discussed at this meeting.  While registration for the meeting 
has officially closed, we so still have space available for those who are 
interested in attending as an observer.  Details on the meeting are available 
here: http://www.regulations.gov/#!docketDetail;D=OSHA-2013-0028.  If you are 
interested in attending this meeting, please send an e-mail to 
nrtlprog...@dol.govmailto:nrtlprog...@dol.gov .  Future updates to the 
program, including the draft directive will be posted here: 
https://www.osha.gov/nrtlpi/index.html

If you have any questions, feel free to contact me.

Kevin Robinson
Electrical Engineer  Senior Assessor
OSHA NRTL Program
robinson.ke...@dol.govmailto:robinson.ke...@dol.gov
202-693-1911


On Thu, Sep 4, 2014 at 1:15 PM, 
jral...@productsafetyinc.commailto:jral...@productsafetyinc.com 
jral...@productsafetyinc.commailto:jral...@productsafetyinc.com wrote:
Hi Rich,

Yes, I would agree.  Not sure how or if we'll ever get there, but if an NRTL is 

Re: [PSES] Battery certification issue

[Tyra, John]

That may be true John, but from experience I have found NCB's not accepting 
data from another NCB has rarely been related to science and/or engineering 
reasons.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Thursday, September 04, 2014 4:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Battery certification issue

In message
c8bf8e4aa3b145658432b55fa8948...@bn1pr08mb202.namprd08.prod.outlook.com
, dated Thu, 4 Sep 2014, Tyra, John john_t...@bose.com writes:

India is a member if the CB scheme yet they will not accept CB 
certifications and reports for the recent mandatory certification 
scheme that was rolled out in that country. They insist they must do 
complete retesting.

There was a recent IECEE vote to suspend their membership in the CB 
Scheme which I read recently failed so they are still a member so I am 
not so sure it is an issue for an NCB to reject another NCB members 
report.

But this is politics at work, not science and engineering.
--
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] Definition of Declaration of Conformity

[Tyra, John]

In simplified terms you need to make sure your product meets all the applicable 
Directives and test to the standards that apply under those Directives if 
applicable. This could include but not limited to Safety, EMC RTTE, RoHs, 
Energy Efficiency etc. as applicable.

There are other options to show compliance but testing to established standards 
as listed under the applicable Directive is the easiest way to show compliance 
IMHO

You must also create  Technical Construction File (TCF) to support your DoC .

Be aware the CE Mark must be on your product unless it is too small which 
allows for marking of packaging and in your user instructions. The CE Mark has 
some minimum dimensions that must be adhered to. We recently had issues in one 
of the EU countries as our CE mark was slightly out of registration so some 
countries can be picky about this.

Be aware that this is general guidance and may not be applicable to your product


-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: Wednesday, June 25, 2014 9:54 AM
To: Tyra, John; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: Definition of Declaration of Conformity

Hi John,

The info is clear that DoC is required for CE marking.  When someone asks for 
DoC, that is to say a DoC for CE marking?  We do not need to put the compliance 
of other legal requirements.

Regards,

Scott


On 25/6/14 2:02 am, Tyra, John john_t...@bose.com wrote:

 There is a lot of guidance on the internet related to CE Marking and 
 DoC's
 
 https://www.gov.uk/ce-marking
 
 http://ec.europa.eu/enterprise/policies/single-market-goods/cemarking/
 
 http://www.ce-marking.org/what-is-ce-marking.html
 
 
 
 -Original Message-
 From: Scott Xe [mailto:scott...@gmail.com]
 Sent: Tuesday, June 24, 2014 12:30 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: [PSES] Definition of Declaration of Conformity
 
 In the field, lots of people such as customers, market surveillances, 
 customs, etc. are asking for a DoC on particular product and/or its variants 
 in Europe.
 What is the exact meaning of the DoC?  Is it the one to support the 
 compliance of CE mark?  Or the compliance of all legal requirements 
 (more than CE mark) relevant to the product.  Is there a uniform 
 format satisfying the essential requirements?  Who is the valid 
 issuer?  Do they need to be a company located in Europe?
 
 Thanks and regards,
 
 Scott
 
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 emc-pstc discussion list. To post a message to the list, send your 
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Re: [PSES] UL61010-1 CSDS Proposal for 6.5.2.4

[Tyra, John]

For IEC60065 Appendix N2.1  (informative) specifies a maximum production line 
dielectric trip current  limit of 100mA. This is considered a dielectric 
failure and looked at as the same as breakdown or flashover.

-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: Tuesday, June 24, 2014 12:45 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL61010-1 CSDS Proposal for 6.5.2.4

No. Nicht. Aon. It does NOT matter that current flows through the 'filters' and 
other stuff during AC hi-pot and 'trips' the instrument. This is a good thing - 
set limit levels on your test equipment to verify cap values and leakage paths. 
There is no inherent current limit for this test in the affected standards for 
di-electric withstand.

You do control the ramp and current levels in your factory hi-pot? No? Sit in 
the corner.

Brian

-Original Message-
From: Brian Oconnell
Sent: Monday, June 23, 2014 5:30 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: UL61010-1 CSDS Proposal for 6.5.2.4

This is excerpted from the latest UL61010-1 CSDS Proposal for 6.5.2.4 Impedance 
of PROTECTIVE BONDING of plug-connected equipment:

It was proposed that all hi-pot tests should be permitted to be performed with 
either ac or dc, particularly because OEM power supplies often fail when tested 
with ac, but pass when tested with dc.
This seems to be because IEC 60601-1 3rd edition, IEC 60950, and IEC 62368-1, 
to which most of these power supplies are tested, permit either ac or dc 
testing. The consensus of ISA 82 is that this change is appropriate. It is also 
recommended that this change be reflected in the US comments on Part 1 by the 
USTAG.

Ok, why are component power supplies failing AC, but passing the equivalent DC 
withstand test levels? If from reactance, just control dv/dt (many standards 
provide a min rate). And what does the protective bond test have to do with the 
test conditions for di-electric withstand? Or am I missing something obvious?

Brian

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Re: [PSES] Definition of Declaration of Conformity

[Tyra, John]

There is a lot of guidance on the internet related to CE Marking and DoC's

https://www.gov.uk/ce-marking

http://ec.europa.eu/enterprise/policies/single-market-goods/cemarking/

http://www.ce-marking.org/what-is-ce-marking.html



-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: Tuesday, June 24, 2014 12:30 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Definition of Declaration of Conformity

In the field, lots of people such as customers, market surveillances, customs, 
etc. are asking for a DoC on particular product and/or its variants in Europe.  
What is the exact meaning of the DoC?  Is it the one to support the compliance 
of CE mark?  Or the compliance of all legal requirements (more than CE mark) 
relevant to the product.  Is there a uniform format satisfying the essential 
requirements?  Who is the valid issuer?  Do they need to be a company located 
in Europe?

Thanks and regards,

Scott 

-

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Re: [PSES] UL61010-1 CSDS Proposal for 6.5.2.4

[Tyra, John]

I don't disagree Rich as I was only pointing out that IEC60065 does have some 
guidance regarding tester trip points logical or not.

-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Tuesday, June 24, 2014 2:49 PM
To: Tyra, John; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UL61010-1 CSDS Proposal for 6.5.2.4


On 6/24/2014 10:29 AM, Tyra, John wrote:
 For IEC60065 Appendix N2.1  (informative) specifies a maximum production line 
 dielectric trip current  limit of 100mA. This is considered a dielectric 
 failure and looked at as the same as breakdown or flashover.

Hi John:


IEC 60065 is dumb.  A breakdown is an arc, not 100 mA, although 100 mA (which 
is beyond many hi-pot testers) indicates something may be wrong, not 
necessarily an insulation breakdown.


Best regards,
Rich

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Re: [PSES] breakage of the fuse

[Tyra, John]

What is the breaking capacity of the fuse? Sounds like it may be a low breaking 
capacity fuse. If it is you should change it to a high breaking capacity fuse.

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Boštjan Glavic
Sent: Tuesday, August 06, 2013 12:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: breakage of the fuse

Dear safety experts,

During the abnormal tests in primary circuit, internal input fuse operates and 
glass breaks. However, fuse is inside the tubing and broken glass does not 
spread around.

Would you accept such construction?

Best regards,
Bostjan
SIQ
-


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Re: [PSES] India ITE approvals

[Tyra, John]

Can't comment on ITE equipment since we make Audio Video products but I have 
found this process to be very chaotic and time consuming for our products

There was a considerable amount of documentation required especially for the 
manufacturing facilities.

There are only a handful of  accredited labs in India and they are still trying 
to figure out what they need to do.

CB reports are not officially recognized but are helpful.

It took us close to 5 months to get our first report with a lot of back and 
forth with the test house and BIS and that was with local representation.

Just a suggestion based on our experience.

1. Study the regulations and don't just rely on the Indian test lab you pick as 
they are still trying to figure things out.

2. Don't be afraid to push back with the lab as they are not experts yet and 
rely on BIS for  direction.

3. Don't over think the forms you are required to complete. There is 
considerable documentation to be completed which  takes a lot of time.

4. Don't wait until the last minute as the lead time is very long.

Good luck.

Sent from my ASUS Pad

Gelfand, David david.gelf...@ca.kontron.com wrote:


As of July 3 there is are new mandatory approvals requiring in-country
safety testing.   Has there been any extension of this date?

Could anyone share their experience getting India approvals under this
new scheme?

Thanks,

David

David Gelfand
Compliance Specialist
Kontron Canada Inc



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Re: [PSES] 3D passive glasses

[Tyra, John]

Found this OSM decision while I was searching for other info.  I guess the 
question becomes is it considered a CHILD APPEALING product?


Standard:  
EN 60065:1998
EN 60065:2002   Sub clause: 
-   Sheet No.: 
02/1

Page 1 of 1
Subject: 
Child appealing Multimedia products Key words:
-
Meeting:
OSM/EE - 2002
Item No. 9.1

Question:  
Description of situation:
A manufacturer of LCD TVs wants to produce LCD TVs which must be designated as 
CHILD APPEALING product.
The LCD TVs will be supplied by an external power supply or a battery pack, 
internal higher voltages are generated.
These types of products are excluded from the scope of the Toy Directive.
The manufacturer wants the products to be certified to EN 60065

Is it acceptable to evaluate these products to EN 60065 only?


Decision:
Since the products are clearly Child Appealing we must bear in mind the normal 
behaviour of children.  Abusing a product is likely to occur; for example, 
dropping it on the floor, using it in a way that is not intended.
Beside the EN 60065 we also will cover applicable additional tests (in case 
they are more severe than EN 60065 or not covered by EN 60065) according the 
following standards:
EN 71 (toy directive)
EN 50088 (safety of electric toys)
The General Product Safety Directive 92/59EEC and the Liability Directive for 
defective products 85/374/EEC have also to be taken into account.
An annex to the test report shall show these additional assessments. 

Explanatory notes: 
A child-appealing-product is a product which is constructed to represent a 
model, person or animal such that due to the design and materials used it could 
be treated by a child as a toy.



-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Tuesday, April 16, 2013 10:35 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: 3D passive glasses

In message cd9372ee.1ac0b%scott...@gmail.com, dated Tue, 16 Apr 2013, Scott 
Xe scott...@gmail.com writes:

 Any comments on the product classification?  If not a toy, what is the 
product type should be.

I was asked about this more than a year ago, by one of the leading 
manufacturers. I said that it was a very grey area and they should probably 
take legal rather than technical advice. I guess that CE marking under the 
'toys Directive' is the result.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist 
burns unit - and made me learn 'To a haggis'.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] 3D passive glasses

[Tyra, John]

I agree completely very vague but all I can say is from experience if there was 
a pair of 3D glasses laying on the coffee table in my TV room my young 
daughters would be wearing and playing with them in a heartbeat.

-Original Message-
From: McInturff, Gary [mailto:gary.mcintu...@esterline.com] 
Sent: Wednesday, April 17, 2013 10:22 AM
To: Tyra, John; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: 3D passive glasses

Sounds logical - but good lord a kid finds dog poo appealing so that's kind of 
a broad category

Gary

-Original Message-
From: Tyra, John [mailto:john_t...@bose.com]
Sent: Wednesday, April 17, 2013 6:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 3D passive glasses

Found this OSM decision while I was searching for other info.  I guess the 
question becomes is it considered a CHILD APPEALING product?


Standard:  
EN 60065:1998
EN 60065:2002   Sub clause: 
-   Sheet No.: 
02/1

Page 1 of 1
Subject: 
Child appealing Multimedia products Key words:
-
Meeting:
OSM/EE - 2002
Item No. 9.1

Question:  
Description of situation:
A manufacturer of LCD TVs wants to produce LCD TVs which must be designated as 
CHILD APPEALING product.
The LCD TVs will be supplied by an external power supply or a battery pack, 
internal higher voltages are generated.
These types of products are excluded from the scope of the Toy Directive.
The manufacturer wants the products to be certified to EN 60065

Is it acceptable to evaluate these products to EN 60065 only?


Decision:
Since the products are clearly Child Appealing we must bear in mind the normal 
behaviour of children.  Abusing a product is likely to occur; for example, 
dropping it on the floor, using it in a way that is not intended.
Beside the EN 60065 we also will cover applicable additional tests (in case 
they are more severe than EN 60065 or not covered by EN 60065) according the 
following standards:
EN 71 (toy directive)
EN 50088 (safety of electric toys)
The General Product Safety Directive 92/59EEC and the Liability Directive for 
defective products 85/374/EEC have also to be taken into account.
An annex to the test report shall show these additional assessments. 

Explanatory notes: 
A child-appealing-product is a product which is constructed to represent a 
model, person or animal such that due to the design and materials used it could 
be treated by a child as a toy.



-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Tuesday, April 16, 2013 10:35 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: 3D passive glasses

In message cd9372ee.1ac0b%scott...@gmail.com, dated Tue, 16 Apr 2013, Scott 
Xe scott...@gmail.com writes:

 Any comments on the product classification?  If not a toy, what is the 
product type should be.

I was asked about this more than a year ago, by one of the leading 
manufacturers. I said that it was a very grey area and they should probably 
take legal rather than technical advice. I guess that CE marking under the 
'toys Directive' is the result.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist 
burns unit - and made me learn 'To a haggis'.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] USA Lab for Headphone Sound Pressure Level Test per EN 50332-1

[Tyra, John]

EN60065 AMD12 and EN60950 have new clauses for limits for headphones sold 
without players. Also EN50332-2 specifies measurement criteria for standalone 
headphones.

Also be aware that there are draft standards for EN50332-1 and -2 which are out 
for vote by the National Committees and are expected to be published soon.

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Friday, March 29, 2013 1:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: USA Lab for Headphone Sound Pressure Level Test per EN 50332-1

In message 00c301ce2c9f$447f03c0$cd7d0b40$@gmail.com, dated Fri, 29 Mar 2013, 
Carl Newton emcl...@gmail.com writes:

I'm walking on new ground with this one.  I have an automotive audio 
system with a wireless connection to portable headphones for use within 
the vehicle.  Because they are wireless, the headphones have their own 
internal speaker amplifiers and volume adjustment.  The sound source is 
external and not portable, but the headphones appear to qualify as 
portable.  What's your take on this?

It isn't a portable music player within the definition is EN 60065. One 
criterion is that you can *walk around* with the *player* and headphones on 
your person. Your player is fixed in the car, and I don't suppose you can walk 
around in the car!

Having said that, your system could be used for listening to music for long 
periods, so I recommend that you do restrict the maximum sound level to 100 dB 
SPL. A measurement using a 1 kHz sine wave and an IEC
60318-1 simulator should be sufficient.

EN 50332-1 is only a 'method of measurement' standard; the safety requirements 
are in EN 60065, and your system might not be able to support all of them (such 
as the automatic warnings).

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk Which Thunderbird will David 
Miliband pilot? Or will he drive Lady Penelope?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] USA Lab for Headphone Sound Pressure Level Test per EN 50332-1

[Tyra, John]

EN60065 subclause Zx.4.3 specifies requirements for wireless headphones and  
has the following note

NOTE An example of a wireless listening device is a Bluetooth headphone.

It also references EN50332-1 -2 for the measurement criteria.

I was on the TC committee which wrote the new sound pressure headphone 
requirements in EN60065 and 60950 and the new draft of EN50332-2 which has an 
informative annex on how to test wireless headphones.

The sound pressure requirements are also for standalone listening devices not 
sold with a specific portable player and not only for portable players and 
associated headphones.

Carl, If your headphones can only be used with the specified car sound system 
you may be exempt. I asked about our Bose Aviation headsets and it was advised 
that since they are not  sold at regular retail outlets they were exempt so you 
may not need to meet the requirements but I would try to get an official ruling.

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Friday, March 29, 2013 2:12 PM
To: emc-p...@listserv.ie
Subject: Re: USA Lab for Headphone Sound Pressure Level Test per EN 50332-1

In message 00c501ce2ca5$7fb0eb10$7f12c130$@gmail.com, dated Fri, 29 Mar 2013, 
Carl Newton emcl...@gmail.com writes:

I'm particularly concerned with the reference to Part 2.  The title 
does point at portable systems and this is not a portable system.
However, the authors likely didn't have wireless headphones with their 
own internal amps and volume control in mind when the standard was 
written.

No, they didn't, because you don't get wireless headphones with a portable 
music player.

Part 2 can't be applied to your wireless headphones, and it doesn't apply to 
headphones not intended to be used with portable music players, which yours 
inherently are not.

But you should limit the maximum sound pressure to 100 dB, as I advised.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk Which Thunderbird will David 
Miliband pilot? Or will he drive Lady Penelope?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] USA Lab for Headphone Sound Pressure Level Test per EN 50332-1

[Tyra, John]

As I stated in my previous e-mail, if the headphone is designed to be used only 
with the associated car system then I believe it is most likely exempt.

If, as you stated, it can be used to play music from any type of mobile player, 
like a phone over Bluetooth, then most likely must  comply.



-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Friday, March 29, 2013 3:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: USA Lab for Headphone Sound Pressure Level Test per EN 50332-1

In message
cb4d5768bea42049b063ebe16e819bf20ff3f...@bluprd0811mb414.namprd08.prod.o
utlook.com, dated Fri, 29 Mar 2013, Tyra, John john_t...@bose.com
writes:

The sound pressure requirements are also for standalone listening 
devices not sold with a specific portable player and not only for 
portable players and associated headphones.

How do you reconcile that with this explicit statement on the web page that was 
cited by Kazimier Gawrzyjal:

 This Part 2 of EN 50332 specifies methods of measuring the matching values for 
the use of personal music players and headphones/earphones defined for the use 
with those...

No way is a car audio system a 'personal music player'.

I would advise GREAT caution in attempting to widen the scope of the standards 
by inference, because we will get back to everything, including desktop 
computers, being considered 'portable music players'.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk Which Thunderbird will David 
Miliband pilot? Or will he drive Lady Penelope?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Ecma TR-106 available

[Tyra, John]

Thanks Rich,

Much appreciated.

Is there a similar dedicated document comparison for IEC60065 available?

Regards,

John

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Richard Nute
Sent: Monday, February 25, 2013 2:45 PM
To: EMC-PSTC
Cc: Thomas M Burke
Subject: Ecma TR-106 available

Posted on behalf of Tom Burke, UL:


More good news for those seeking to learn more about IEC 62368-1 as the ICT 
Industry prepares for the eventual transition from IEC 60950-1 (and IEC 60065) 
to IEC 62368-1. ECMA International, previously known as the European Computer 
Manufacturers Association, has just published its Technical Report TR/106, 
which provides guidance and comparison between
60950-1 and 62368-1. The report was published by ECMA's TC12 on Product Safety, 
and the effort to develop and publish the TR was very capably led by Mr. 
Richard Nute. Thank you Rich and members of ECMA TC12! ECMA has a strong 
interest in IEC 62368-1 since its industry standard,
ECMA-287 Safety of electronic equipment, which was developed and published in 
the 1990s and which first introduced hazard-based concepts, was the core 
material that IEC TC108 used when it began it project developing IEC 62368-1 in 
2002. It is believed that the availability of comparison documents like TR/106 
from a variety of sources helps industry prepare for the pending transition and 
also helps clear up some of the misconceptions about the new standard. As has 
been discussed in this group previously, IEC 62368-1 has many familiar elements 
from 60950-1, including allowance for prescriptive constructions that have 
proven safe in 60950-1 and that may be used as an alternative to some of the 
performance based requirements in 62368-1. Provided below are links to 
information on ECMA TC12 and the TR/106 (available free of charge).

http://www.ecma-international.org/memento/TC12.htm

http://www.ecma-international.org/publications/techreports/E-TR-106.htm;


Best regards,
Rich

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Re: [PSES] One DoC per manufactured Unit?!

[Tyra, John]

Thanks Lauren,

I appreciate your insight as it is always tricky business interpreting what the 
regulator's intended when they wrote the Directives.

Hopefully this is not what the powers that be intended because, as John pointed 
out, it is easier and less expensive to create paperwork then it is to produce 
a compliant product and I see no value added if this is indeed the approach we 
must comply with.

Regards,

John

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Crane, Lauren
Sent: Monday, January 14, 2013 11:56 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

Thanks John and all for your comments.

There is a persistent problem knitted into this issue regarding the meaning of 
'product'.

Most inquiries to the Commission tend to end up clarifying that 'product' means 
a particular unit and not a model line or type. This is particularly true when 
struggling with the grandfathering issue. The date for which a 'product' is 
placed on the market is the date on which that particular unit entered the EU. 
It is *not* the date when the model-line or type was first introduced to the EU.

The blue-guide states on page 18, Moreover, the concept of placing on the 
market refers to each individual product, not to a type of product, and whether 
it was manufactured as an individual unit or in series.

Therefore, Object of the declaration (and the other equivalent statements) 
required by various CE directives can well mean a model-line or type 
description (except, perhaps, the very unique language of the MD which 
references serial number). But the new add in NLF is the point 1 1. 
No...(unique identification of the product) and it hints to me of a per-unit 
identification number.

Why else would this new element be added by the NLF (New Legislative Framework) 
when object of the declaration has long been explained as 'model-line'? And 
why would parliamentarians be getting so tricky in their amendment proposals if 
it were not the Commissions intent to have this be a per-unit identifier?

Regards,
Lauren Crane
KLA-Tencor

From: Tyra, John [mailto:john_t...@bose.com]
Sent: Sunday, January 13, 2013 3:21 PM
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: One DoC per manufactured Unit?!

I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision 
768/2008 and I interpret it to mean you need a unique model number which can be 
cross referenced with the TCF reports for that model. I am not seeing where it 
requires each unit to have a unique ID# listed on the DoC which essentially 
means a unique DoC to be shipped with each product?

As long as the DoC has unique model numbers listed for the equipment you are 
declaring as compliant, and has the date of issue, the authorities can cross 
reference this for compliance by checking the products model number and DOM 
against the DoC which is required to be on the equipment being put onto the 
market in the EU. And of course your TCF reports must cross reference to the 
model number on the label.

Can you be more specific on which wording you are talking about?

What I found much more interesting was COM(2011) 773 final Annex IV seems to 
infer that you must (shall) include a color photo of the equipment on the DoC

4. Object of the declaration (identification of electrical equipment allowing 
traceability.
It shall include a colour image of sufficient clarity to enable the 
identification of the
electric equipment).

COM(2011) 773 final Annex IV references Annex III of NLF Council Decision 
768/2008  which list the photo as optional

4. Object of the declaration (identification of product allowing traceability. 
It may include a photograph, where
appropriate):

While this is not as onerous as having to have a unique DoC for each product it 
will still mean a lot of work for companies to modify their current DoC's to 
add the photos as I have never seen a DoC which included product photos.


From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of 
Crane, Lauren
Sent: Wednesday, January 09, 2013 5:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: One DoC per manufactured Unit?!

As many know, the LVD is in the process of being recast for alignment with the 
New Legislative Framework (NLF).

The Commission proposed text, (COM(2011) 773 final),  calls for what looks like 
a unique equipment identification number do be provided in the Declaration of 
Conformity (DoC). The same sort of language is used in the NLF Council Decision 
768/2008, and RoHS2 criteria for the DoC.

This seems to imply there must be a DoC provided with a unit that contains that 
unit's unique identification number (e.g., serial number), and that a DoC that 
references an entire model line would not be acceptable.

Hints that this is the case can be seen in the Parliament's proposed amendments

Re: [PSES] One DoC per manufactured Unit?!

[Tyra, John]

I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision 
768/2008 and I interpret it to mean you need a unique model number which can be 
cross referenced with the TCF reports for that model. I am not seeing where it 
requires each unit to have a unique ID# listed on the DoC which essentially 
means a unique DoC to be shipped with each product?

As long as the DoC has unique model numbers listed for the equipment you are 
declaring as compliant, and has the date of issue, the authorities can cross 
reference this for compliance by checking the products model number and DOM 
against the DoC which is required to be on the equipment being put onto the 
market in the EU. And of course your TCF reports must cross reference to the 
model number on the label.

Can you be more specific on which wording you are talking about?

What I found much more interesting was COM(2011) 773 final Annex IV seems to 
infer that you must (shall) include a color photo of the equipment on the DoC

4. Object of the declaration (identification of electrical equipment allowing 
traceability.
It shall include a colour image of sufficient clarity to enable the 
identification of the
electric equipment).

COM(2011) 773 final Annex IV references Annex III of NLF Council Decision 
768/2008  which list the photo as optional

4. Object of the declaration (identification of product allowing traceability. 
It may include a photograph, where
appropriate):
While this is not as onerous as having to have a unique DoC for each product it 
will still mean a lot of work for companies to modify their current DoC's to 
add the photos as I have never seen a DoC which included product photos.


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Crane, Lauren
Sent: Wednesday, January 09, 2013 5:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: One DoC per manufactured Unit?!

As many know, the LVD is in the process of being recast for alignment with the 
New Legislative Framework (NLF).

The Commission proposed text, (COM(2011) 773 final),  calls for what looks like 
a unique equipment identification number do be provided in the Declaration of 
Conformity (DoC). The same sort of language is used in the NLF Council Decision 
768/2008, and RoHS2 criteria for the DoC.

This seems to imply there must be a DoC provided with a unit that contains that 
unit's unique identification number (e.g., serial number), and that a DoC that 
references an entire model line would not be acceptable.

Hints that this is the case can be seen in the Parliament's proposed amendments 
to the Commission's text of the LVD, where they cleverly change the unique unit 
number into a unique DoC number (much easier to deal with).


Amendment 48 - Zuzana Roithová
Annex IV - point 1
Text proposed by the Commission  -- 1. No xx (unique identification of the 
electric equipment):
Amendment Proposed -- 1. No xx (unique identification of the declaration):


Also, the previous Draft version of the RoHS2 FAQ had a question 9.9 which 
said, in effect no, no, we meant a unique DoC number has been entirely 
withdrawn in the current version of the FAQ.

Does anyone reading have any additional perspective on this battle? Will a 
model line DoC be possible in the future?


Regards,
Lauren Crane
KLA-Tencor

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[PSES] Product Safety Job openings at Bose

[Tyra, John]

Hello Everyone,

The Bose Product Safety Group is growing again and I have openings for two 
positions in Framingham, MA. I have included a very brief description of the 
positions but you can view the complete job descriptions on the Bose Website 
using the above req#'s

https://www.bose.com/controller?event=VIEW_STATIC_PAGE_EVENTurl=/about/careers/search_jobs/index.jsp



1.  Product Safety Engineer req ID# 15759BR- this is a junior position so I 
am looking for a recent college graduate or someone who has been out of school 
less than two years. You can view the job description here under req ID# 
i57559BR

The Product Safety Group seeks an self-motivated and detail oriented engineer 
with a background in electrical/electronic engineering to support regulatory 
design evaluation and testing of Bose Consumer and Professional Audio/ Video 
products.



2.  Product Safety Engineer req #15794BR - This is a more senior oriented 
position is dedicated to evaluating customer field returns for possible safety 
issues. The candidate must have the ability to do deep dive analysis of 
circuits to determine the possible cause of the field issue.

Consider a career as a Product Safety Engineer with Bose's Product Safety 
Group. We are seeking a self-motivated and detail oriented engineer with an 
experienced background in electrical/electronic engineering and analog circuit 
design (ideally power circuitry) to support the evaluation and root cause 
diagnosis of customer returns for potential safety issues of Bose Consumer and 
Professional Audio/ Video products. In this role, you will provide support to 
the various Bose Product Divisions, International subsidiaries and Manufacturing

There is also a position in another one of the Design Compliance groups here 
some might have interest in


3.  International Certification Engineer req#15754BR

Bose Corporation is seeking a talented individual with experience and long-term 
interest in International Product Compliance. As part of the Design Compliance 
Engineering (DCE) group you will provide support to the various Bose Product 
Divisions, such as Home Entertainment, Professional Systems and Noise Reduction 
Technology, in obtaining and maintaining International Product Certifications 
required for worldwide sales.


These are new positions and not a replacement for people who have left Bose. 
Please be sure to apply officially through he Bose system so the recruiter will 
have a record of your interest and can begin the screening process.

Any questions please feel free to contact me.


John Tyra
Manager Product Safety Group
Bose Corporation
The Mountain, MS-450
Framingham, MA 01701-9168
phone: 508-766-1502
fax: 508-518-4137

john_t...@bose.com

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Re: [PSES] Proving UN38.3 certification of common batteries.

[Tyra, John]

Good guidance here

http://www.iata.org/SiteCollectionDocuments/Documents/GuidanceDocumentontheTransportofLiBatt_2010.pdf


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Re: [PSES] OSHA - NRTL audit question

[Tyra, John]

When I was at TUV the OSHA auditors for our NRTL accreditation were actually 
from the Department of Mines if I remember correctly but maybe it has changed 
in the last 12years?

For our CB accreditation CENELC did use auditors from other notified bodies 
like CSA and VDE.

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian Oconnell
Sent: Tuesday, July 03, 2012 12:55 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: OSHA - NRTL audit question

Was at an NRTL/CAB site yesterday. Noted a small group lurking - assessment
engineer said they were part of an OSHA audit team. I recognized one member
of the audit team from another NRTL down the road.

Does the U.S. OSHA use NRTLs to audit each other?

Brian

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Re: [PSES] Low voltage DC electrical wire and cables require CCC approval?

[Tyra, John]

For audio video products we were only required to have a CCC certified power 
cord. They did not seem to care about low voltage cables...



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Chuck McDowell
Sent: Friday, April 20, 2012 5:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Low voltage DC electrical wire and cables require CCC approval?

I am writing to ask for help in identifying if a cable carrying 48VDC at 2A 
maximum current will require a CCC certified cable.

The cable is used to interconnect a AC line to DC power supply to a 48VDC 
speaker.
The cable does not run inside a wall or other building construction.
The cable similar to a AC wall wart output supplying 48 VDC.

I understand CCC controls these 5 categories of Electrical wires and cables.
0101: Cord sets
0102: Flexible rubber-sheathed cables for mining purposes
0103: Insulated cables (wires) for railway vehicles of rated voltage up to and 
including 3kV
0104: Rubber insulated cables of rated voltages up to and including 450/750V
0105: Polyvinyl chloride insulated cables of rated voltages up to and including 
450/750V

I am failing to understand where the lower limit is for these types.

Do all current carrying conductors with a insulation surrounding in China 
require CCC approval?

Can you direct me to the document , GB standard or law that specifies the lower 
limits of the above electrical wires and cables or is this found in a clause of 
my GB 8988;2001 (IEC60065;1998) standard?

Thank you in advance,

Chuck McDowell



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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] Mandatory NRTL certification

[Tyra, John]

As I mentioned in my previous posts the laws in 16  States do not specify any 
exemptions for the type of equipment so based on that I believe that test, 
measurement and laboratory would need to comply... there are 4 other 
States which specifically specify consumer products so based on the
that I believe the type of equipment you mention may be exempt

From: Ron Wellman [mailto:rwell...@wellman.com]
Sent: Friday, January 06, 2012 2:46 PM
To: Tyra, John; peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

For Consumer products I see your point, but what about test, measurement, and 
laboratory equipment? These products are usually sold business to business and 
it's really up to the Customer to decide if NRTL is required for the sale.

Best regards,
Ron Wellman

From: Tyra, John [mailto:john_t...@bose.com]
Sent: Friday, January 06, 2012 8:50 AM
To: 'Ron Wellman'; peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

I don't see where companies really have much of a choice as this is a legal 
requirement in 20 States for Consumer products

From: Ron Wellman 
[mailto:rwell...@wellman.com]mailto:[mailto:rwell...@wellman.com]
Sent: Friday, January 06, 2012 10:27 AM
To: Tyra, John; peterh...@aol.commailto:peterh...@aol.com; 
EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

This question comes up about every two years and what it boils down to is a 
catch 22. Damned if you do, damned if you don't. In my opinion, it is better to 
do regardless of how unbalanced these requirements are within the United 
States. As long as you budget for it and your management understands the risks 
of not having NRTL listing, it will be easier to manage.

Best regards,
Ron  Wellman

From: Tyra, John [mailto:john_t...@bose.com]mailto:[mailto:john_t...@bose.com]
Sent: Friday, January 06, 2012 6:34 AM
To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: Mandatory NRTL certification

While there are no Federal laws requiring NRTL certification and marking of 
electronic products there are laws in 16 States which require an NRTL mark for 
mains connected electronic products...and laws in 4 other States which specify 
consumer products only. CEA commissioned a State survey, which was updated in 
2010, which outlines the legal requirement or lack of for all 50 
States...

From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of Ron 
Wellman
Sent: Thursday, January 05, 2012 11:49 PM
To: peterh...@aol.commailto:peterh...@aol.com; 
EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

NRTL certification/listing is not mandatory for product Manufacturers. This is 
a Customer driven requirement so your Customers can comply with local OSHA 
requirements. If you don't want to list or certify your product that's really a 
Marketing call. Also, it is my experience that most large Companies require 
third party approvals as a condition of sale. Therefore, unless you want to be 
reactive to Customer sales I would make sure your Marketing people understand 
the risk of losing a sale if your product is not certified/listed by an NRTL.

Best regards,
Ron Wellman

From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of 
peterh...@aol.commailto:peterh...@aol.com
Sent: Thursday, January 05, 2012 5:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Mandatory NRTL certification

Hello All,

Today a colleague asked me a question as to why do we need NRTL certification 
such as UL or CSA on any product in the US. I thought this was a good and 
logical question and the way I answered it was that to the best of my 
knowledge, OSHA requires that any products that is used in work place to be 
safe and to have been certified by one of the NRTL labs. Would you say that is 
a correct answer?

Thank you
Peter
-


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.orgmailto: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.netmailto:emcp...@radiusnorth.net
Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org

For policy questions, send

Re: [PSES] Mandatory NRTL certification

[Tyra, John]

Sorry Rich but I have to disagree as the CEA document I have shows State laws 
which specifically call out an NRTL being mandatory to distribute electronic 
equipment into those States...

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Richard Nute
Sent: Saturday, January 07, 2012 7:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Cc: peterh...@aol.com
Subject: RE: Mandatory NRTL certification


The way the term NRTL has been used here is
mostly wrong.  I want to clarify what the term
NRTL means.

In the U.S.A., NRTL certification is NOT
mandatory.  Safety certification is NOT
mandatory.

The U.S.A. has two sets of drivers for safety
certification of electrical products:

1)  The Occupational Safety and Health Act (OSHA);
2)  The local electrical code.

The U.S.A. OSHA law applies to employers.  The
electrical products used by employees in the
workplace must be certified for safety by a
NRTL.  (Employers have alternatives to NRTL
certified products, but that is not discussed
here.)

So, to comply with the OSHA law, employers
purchase electrical products that are certified
by a NRTL.

The term NRTL does not apply to any other
situation.

As has been mentioned, certification by a NRTL
is NOT a requirement for electrical equipment
manufacturers; it is a requirement for employers
and the workplace.

In the U.S.A., the local electrical code is
part of the local building code.  In most code
jurisdictions, the electrical code requires the
parts used for electrical construction and
installation be certified for safety.  The
accepted certifications are set by the local
Authority Having Jurisdiction (AHJ).

No relationship exists between OSHA and local
AHJs.  These are independent entities.

Therefore, NRTL certification does not
guarantee acceptance by an AHJ.

Having said that, some (but not all) AHJs defer
to the NRTL scheme for approval of labs that
can issue safety certifications that can be
accepted.

Most NRTLs are accepted by most AHJs.

As has been mentioned here, some retailers and
most medical facilities require electrical
equipment be certified for safety.  The labs
that can satisfy this requirement are specified
by the retailer or medical facility as a part
of their purchase order.  (Some retailers and
some medical facilities actually test the
equipment safety before accepting the equipment!)

Most NRTLs are accepted by most retailers and
most medical facilities.

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman
Sent: Thursday, January 05, 2012 8:49 PM
To: peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification
NRTL certification/listing is not mandatory for product Manufacturers. This is 
a Customer driven requirement so your Customers can comply with local OSHA 
requirements. If you don't want to list or certify your product that's really a 
Marketing call. Also, it is my experience that most large Companies require 
third party approvals as a condition of sale. Therefore, unless you want to be 
reactive to Customer sales I would make sure your Marketing people understand 
the risk of losing a sale if your product is not certified/listed by an NRTL.

Best regards,
Ron Wellman

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of 
peterh...@aol.com
Sent: Thursday, January 05, 2012 5:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Mandatory NRTL certification

Hello All,

Today a colleague asked me a question as to why do we need NRTL certification 
such as UL or CSA on any product in the US. I thought this was a good and 
logical question and the way I answered it was that to the best of my 
knowledge, OSHA requires that any products that is used in work place to be 
safe and to have been certified by one of the NRTL labs. Would you say that is 
a correct answer?

Thank you
Peter
-


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.orgmailto: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.netmailto:emcp...@radiusnorth.net
Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org

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


This message is from the IEEE Product Safety Engineering Society 

Re: [PSES] Mandatory NRTL certification

[Tyra, John]

In some of the States it specifies an NRTL or lab found to be acceptable by the 
State Authorities

-Original Message-
From: Lg [mailto:wdows...@yahoo.com] 
Sent: Sunday, January 08, 2012 12:46 PM
To: Tyra, John; 'ri...@ieee.org'; emc-pstc@listserv.ieee.org
Cc: peterh...@aol.com
Subject: RE: Mandatory NRTL certification

A number states have adopted OSHA rules as their own, often withs mods.
Sent from my MetroPCS Wireless Phone

Tyra, John john_t...@bose.com wrote:

Sorry Rich but I have to disagree as the CEA document I have shows State laws 
which specifically call out an NRTL being mandatory to distribute electronic 
equipment into those States...

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Richard Nute
Sent: Saturday, January 07, 2012 7:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Cc: peterh...@aol.com
Subject: RE: Mandatory NRTL certification


The way the term NRTL has been used here is
mostly wrong.  I want to clarify what the term
NRTL means.

In the U.S.A., NRTL certification is NOT
mandatory.  Safety certification is NOT
mandatory.

The U.S.A. has two sets of drivers for safety
certification of electrical products:

1)  The Occupational Safety and Health Act (OSHA);
2)  The local electrical code.

The U.S.A. OSHA law applies to employers.  The
electrical products used by employees in the
workplace must be certified for safety by a
NRTL.  (Employers have alternatives to NRTL
certified products, but that is not discussed
here.)

So, to comply with the OSHA law, employers
purchase electrical products that are certified
by a NRTL.

The term NRTL does not apply to any other
situation.

As has been mentioned, certification by a NRTL
is NOT a requirement for electrical equipment
manufacturers; it is a requirement for employers
and the workplace.

In the U.S.A., the local electrical code is
part of the local building code.  In most code
jurisdictions, the electrical code requires the
parts used for electrical construction and
installation be certified for safety.  The
accepted certifications are set by the local
Authority Having Jurisdiction (AHJ).

No relationship exists between OSHA and local
AHJs.  These are independent entities.

Therefore, NRTL certification does not
guarantee acceptance by an AHJ.

Having said that, some (but not all) AHJs defer
to the NRTL scheme for approval of labs that
can issue safety certifications that can be
accepted.

Most NRTLs are accepted by most AHJs.

As has been mentioned here, some retailers and
most medical facilities require electrical
equipment be certified for safety.  The labs
that can satisfy this requirement are specified
by the retailer or medical facility as a part
of their purchase order.  (Some retailers and
some medical facilities actually test the
equipment safety before accepting the equipment!)

Most NRTLs are accepted by most retailers and
most medical facilities.

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman
Sent: Thursday, January 05, 2012 8:49 PM
To: peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification
NRTL certification/listing is not mandatory for product Manufacturers. This is 
a Customer driven requirement so your Customers can comply with local OSHA 
requirements. If you don't want to list or certify your product that's really 
a Marketing call. Also, it is my experience that most large Companies require 
third party approvals as a condition of sale. Therefore, unless you want to be 
reactive to Customer sales I would make sure your Marketing people understand 
the risk of losing a sale if your product is not certified/listed by an NRTL.

Best regards,
Ron Wellman

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of 
peterh...@aol.com
Sent: Thursday, January 05, 2012 5:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Mandatory NRTL certification

Hello All,

Today a colleague asked me a question as to why do we need NRTL certification 
such as UL or CSA on any product in the US. I thought this was a good and 
logical question and the way I answered it was that to the best of my 
knowledge, OSHA requires that any products that is used in work place to be 
safe and to have been certified by one of the NRTL labs. Would you say that is 
a correct answer?

Thank you
Peter
-


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.orgmailto: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

Re: [PSES] Mandatory NRTL certification

[Tyra, John]

It is a CEA members document so I cannot post it.

From: Ron Wellman [mailto:rwell...@wellman.com]
Sent: Sunday, January 08, 2012 12:59 PM
To: Tyra, John; ri...@ieee.org; 'emc-pstc@listserv.ieee.org'
Cc: peterh...@aol.com
Subject: RE: Mandatory NRTL certification

Post the document.

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Tyra, John
Sent: Sunday, January 08, 2012 9:31 AM
To: 'ri...@ieee.org'; emc-pstc@listserv.ieee.org
Cc: peterh...@aol.com
Subject: RE: Mandatory NRTL certification

Sorry Rich but I have to disagree as the CEA document I have shows State laws 
which specifically call out an NRTL being mandatory to distribute electronic 
equipment into those States...

From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of 
Richard Nute
Sent: Saturday, January 07, 2012 7:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Cc: peterh...@aol.commailto:peterh...@aol.com
Subject: RE: Mandatory NRTL certification


The way the term NRTL has been used here is
mostly wrong.  I want to clarify what the term
NRTL means.

In the U.S.A., NRTL certification is NOT
mandatory.  Safety certification is NOT
mandatory.

The U.S.A. has two sets of drivers for safety
certification of electrical products:

1)  The Occupational Safety and Health Act (OSHA);
2)  The local electrical code.

The U.S.A. OSHA law applies to employers.  The
electrical products used by employees in the
workplace must be certified for safety by a
NRTL.  (Employers have alternatives to NRTL
certified products, but that is not discussed
here.)

So, to comply with the OSHA law, employers
purchase electrical products that are certified
by a NRTL.

The term NRTL does not apply to any other
situation.

As has been mentioned, certification by a NRTL
is NOT a requirement for electrical equipment
manufacturers; it is a requirement for employers
and the workplace.

In the U.S.A., the local electrical code is
part of the local building code.  In most code
jurisdictions, the electrical code requires the
parts used for electrical construction and
installation be certified for safety.  The
accepted certifications are set by the local
Authority Having Jurisdiction (AHJ).

No relationship exists between OSHA and local
AHJs.  These are independent entities.

Therefore, NRTL certification does not
guarantee acceptance by an AHJ.

Having said that, some (but not all) AHJs defer
to the NRTL scheme for approval of labs that
can issue safety certifications that can be
accepted.

Most NRTLs are accepted by most AHJs.

As has been mentioned here, some retailers and
most medical facilities require electrical
equipment be certified for safety.  The labs
that can satisfy this requirement are specified
by the retailer or medical facility as a part
of their purchase order.  (Some retailers and
some medical facilities actually test the
equipment safety before accepting the equipment!)

Most NRTLs are accepted by most retailers and
most medical facilities.

-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 Ron 
Wellman
Sent: Thursday, January 05, 2012 8:49 PM
To: peterh...@aol.commailto:peterh...@aol.com; 
EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification
NRTL certification/listing is not mandatory for product Manufacturers. This is 
a Customer driven requirement so your Customers can comply with local OSHA 
requirements. If you don't want to list or certify your product that's really a 
Marketing call. Also, it is my experience that most large Companies require 
third party approvals as a condition of sale. Therefore, unless you want to be 
reactive to Customer sales I would make sure your Marketing people understand 
the risk of losing a sale if your product is not certified/listed by an NRTL.

Best regards,
Ron Wellman

From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of 
peterh...@aol.commailto:peterh...@aol.com
Sent: Thursday, January 05, 2012 5:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Mandatory NRTL certification

Hello All,

Today a colleague asked me a question as to why do we need NRTL certification 
such as UL or CSA on any product in the US. I thought this was a good and 
logical question and the way I answered it was that to the best of my 
knowledge, OSHA requires that any products that is used in work place to be 
safe and to have been certified by one of the NRTL labs. Would you say that is 
a correct answer?

Thank you
Peter
-


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.orgmailto:emc-p...@ieee.org

All emc-pstc postings

Re: [PSES] Mandatory NRTL certification

[Tyra, John]

 as 
determined by the list
maintained by the Division of Building Safety, Electrical Bureau. Such approval 
shall be obtained
prior to installation. If approval is denied, the particular reasons for denial 
shall be stated through
issuance of a notice of defects pursuant to Section 54-1004, Idaho Code.
IDAPA 07.01.10.000 (2006)
The Idaho Electrical Board is authorized under Sections 54-1001 and 54-1006(5), 
Idaho Code, to adopt


As other have mentioned there is another route you can go other than NRTL 
listing in that you can have a field evaluation of a product but that is only 
really financially feasible for high cost low production specialty equipment. 
It may work for certain laboratory equipment but again it would have to be 
something low volume and it is not inexpensive as I have looked into it before.






From: Ron Wellman [mailto:rwell...@wellman.com]
Sent: Sunday, January 08, 2012 12:58 PM
To: Tyra, John; peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

I refer you to what Rich Nute posted.

From: Tyra, John [mailto:john_t...@bose.com]
Sent: Sunday, January 08, 2012 9:24 AM
To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: Mandatory NRTL certification

As I mentioned in my previous posts the laws in 16  States do not specify any 
exemptions for the type of equipment so based on that I believe that test, 
measurement and laboratory would need to comply... there are 4 other 
States which specifically specify consumer products so based on the
that I believe the type of equipment you mention may be exempt

From: Ron Wellman 
[mailto:rwell...@wellman.com]mailto:[mailto:rwell...@wellman.com]
Sent: Friday, January 06, 2012 2:46 PM
To: Tyra, John; peterh...@aol.commailto:peterh...@aol.com; 
EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

For Consumer products I see your point, but what about test, measurement, and 
laboratory equipment? These products are usually sold business to business and 
it's really up to the Customer to decide if NRTL is required for the sale.

Best regards,
Ron Wellman

From: Tyra, John [mailto:john_t...@bose.com]mailto:[mailto:john_t...@bose.com]
Sent: Friday, January 06, 2012 8:50 AM
To: 'Ron Wellman'; peterh...@aol.commailto:peterh...@aol.com; 
EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

I don't see where companies really have much of a choice as this is a legal 
requirement in 20 States for Consumer products

From: Ron Wellman 
[mailto:rwell...@wellman.com]mailto:[mailto:rwell...@wellman.com]
Sent: Friday, January 06, 2012 10:27 AM
To: Tyra, John; peterh...@aol.commailto:peterh...@aol.com; 
EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

This question comes up about every two years and what it boils down to is a 
catch 22. Damned if you do, damned if you don't. In my opinion, it is better to 
do regardless of how unbalanced these requirements are within the United 
States. As long as you budget for it and your management understands the risks 
of not having NRTL listing, it will be easier to manage.

Best regards,
Ron  Wellman

From: Tyra, John [mailto:john_t...@bose.com]mailto:[mailto:john_t...@bose.com]
Sent: Friday, January 06, 2012 6:34 AM
To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: Mandatory NRTL certification

While there are no Federal laws requiring NRTL certification and marking of 
electronic products there are laws in 16 States which require an NRTL mark for 
mains connected electronic products...and laws in 4 other States which specify 
consumer products only. CEA commissioned a State survey, which was updated in 
2010, which outlines the legal requirement or lack of for all 50 
States...

From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of Ron 
Wellman
Sent: Thursday, January 05, 2012 11:49 PM
To: peterh...@aol.commailto:peterh...@aol.com; 
EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

NRTL certification/listing is not mandatory for product Manufacturers. This is 
a Customer driven requirement so your Customers can comply with local OSHA 
requirements. If you don't want to list or certify your product that's really a 
Marketing call. Also, it is my experience that most large Companies require 
third party approvals as a condition of sale. Therefore, unless you want to be 
reactive to Customer sales I would make sure your Marketing people understand 
the risk of losing a sale if your product is not certified/listed by an NRTL.

Best regards,
Ron Wellman

From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of 
peterh...@aol.commailto:peterh...@aol.com
Sent: Thursday, January 05

Re: [PSES] Mandatory NRTL certification

[Tyra, John]

O.K. Rich maybe we are saying the same thing? My point was an NRTL mark is 
basically required to sell electronic product in some states.

From: Richard Nute [mailto:ri...@ieee.org]
Sent: Sunday, January 08, 2012 2:36 PM
To: Tyra, John; EMC-PSTC@LISTSERV.IEEE.ORG
Cc: peterh...@aol.com
Subject: RE: Mandatory NRTL certification


Hi John:


I don't understand your comment.  Here is what
I said:

... some (but not all) AHJs defer
to the NRTL scheme for approval of labs that
can issue safety certifications that can be
accepted.


Most NRTLs are accepted by most AHJs.

Yes, some AHJs (not necessarily states) accept
certification by a NRTL.


Best regards,
Rich



-Original Message-
From: Tyra, John [mailto:john_t...@bose.com]
Sent: Sunday, January 08, 2012 9:31 AM
To: 'ri...@ieee.org'; EMC-PSTC@LISTSERV.IEEE.ORG
Cc: peterh...@aol.com
Subject: RE: Mandatory NRTL certification
Sorry Rich but I have to disagree as the CEA document I have shows State laws 
which specifically call out an NRTL being mandatory to distribute electronic 
equipment into those States...

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Richard Nute
Sent: Saturday, January 07, 2012 7:53 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Cc: peterh...@aol.com
Subject: RE: Mandatory NRTL certification


The way the term NRTL has been used here is
mostly wrong.  I want to clarify what the term
NRTL means.

In the U.S.A., NRTL certification is NOT
mandatory.  Safety certification is NOT
mandatory.

The U.S.A. has two sets of drivers for safety
certification of electrical products:

1)  The Occupational Safety and Health Act (OSHA);
2)  The local electrical code.

The U.S.A. OSHA law applies to employers.  The
electrical products used by employees in the
workplace must be certified for safety by a
NRTL.  (Employers have alternatives to NRTL
certified products, but that is not discussed
here.)

So, to comply with the OSHA law, employers
purchase electrical products that are certified
by a NRTL.

The term NRTL does not apply to any other
situation.

As has been mentioned, certification by a NRTL
is NOT a requirement for electrical equipment
manufacturers; it is a requirement for employers
and the workplace.

In the U.S.A., the local electrical code is
part of the local building code.  In most code
jurisdictions, the electrical code requires the
parts used for electrical construction and
installation be certified for safety.  The
accepted certifications are set by the local
Authority Having Jurisdiction (AHJ).

No relationship exists between OSHA and local
AHJs.  These are independent entities.

Therefore, NRTL certification does not
guarantee acceptance by an AHJ.

Having said that, some (but not all) AHJs defer
to the NRTL scheme for approval of labs that
can issue safety certifications that can be
accepted.

Most NRTLs are accepted by most AHJs.

As has been mentioned here, some retailers and
most medical facilities require electrical
equipment be certified for safety.  The labs
that can satisfy this requirement are specified
by the retailer or medical facility as a part
of their purchase order.  (Some retailers and
some medical facilities actually test the
equipment safety before accepting the equipment!)

Most NRTLs are accepted by most retailers and
most medical facilities.

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman
Sent: Thursday, January 05, 2012 8:49 PM
To: peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification
NRTL certification/listing is not mandatory for product Manufacturers. This is 
a Customer driven requirement so your Customers can comply with local OSHA 
requirements. If you don't want to list or certify your product that's really a 
Marketing call. Also, it is my experience that most large Companies require 
third party approvals as a condition of sale. Therefore, unless you want to be 
reactive to Customer sales I would make sure your Marketing people understand 
the risk of losing a sale if your product is not certified/listed by an NRTL.

Best regards,
Ron Wellman

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of 
peterh...@aol.com
Sent: Thursday, January 05, 2012 5:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Mandatory NRTL certification

Hello All,

Today a colleague asked me a question as to why do we need NRTL certification 
such as UL or CSA on any product in the US. I thought this was a good and 
logical question and the way I answered it was that to the best of my 
knowledge, OSHA requires that any products that is used in work place to be 
safe and to have been certified by one of the NRTL labs. Would you say that is 
a correct answer?

Thank you
Peter
-


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.orgmailto:emc-p...@ieee.org

Re: [PSES] Mandatory NRTL certification

[Tyra, John]

While there are no Federal laws requiring NRTL certification and marking of 
electronic products there are laws in 16 States which require an NRTL mark for 
mains connected electronic products...and laws in 4 other States which specify 
consumer products only. CEA commissioned a State survey, which was updated in 
2010, which outlines the legal requirement or lack of for all 50 
States...

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron Wellman
Sent: Thursday, January 05, 2012 11:49 PM
To: peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

NRTL certification/listing is not mandatory for product Manufacturers. This is 
a Customer driven requirement so your Customers can comply with local OSHA 
requirements. If you don't want to list or certify your product that's really a 
Marketing call. Also, it is my experience that most large Companies require 
third party approvals as a condition of sale. Therefore, unless you want to be 
reactive to Customer sales I would make sure your Marketing people understand 
the risk of losing a sale if your product is not certified/listed by an NRTL.

Best regards,
Ron Wellman

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of 
peterh...@aol.com
Sent: Thursday, January 05, 2012 5:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Mandatory NRTL certification

Hello All,

Today a colleague asked me a question as to why do we need NRTL certification 
such as UL or CSA on any product in the US. I thought this was a good and 
logical question and the way I answered it was that to the best of my 
knowledge, OSHA requires that any products that is used in work place to be 
safe and to have been certified by one of the NRTL labs. Would you say that is 
a correct answer?

Thank you
Peter
-


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discussion list. To post a message to the list, send your e-mail to 
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David Heald dhe...@gmail.commailto:dhe...@gmail.com
-


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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 
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Website:  http://www.ieee-pses.org/
Instructions:  http://listserv.ieee.org/request/user-guide.html
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[PSES] International Certification Engineer Job Opening at Bose Corporation

[Tyra, John]

This position is for International Certification Engineer at the Framingham, 
Massachusetts facility.

The position was created to help coordinate the Worldwide Certification 
submittals for Bose Products.

If interested please apply at the links below

Bose.com
14348BR - 001191: Engineer III, Electrical View 
detailshttps://jobs.brassring.com/1033/asp/tg/cim_jobdetail.asp?jobId=591651PartnerId=3SiteId=58type=mailJobReqLang=1recordstart=1JobSiteId=58JobSiteInfo=591651_58gqid=0

LinkedIn
http://www.linkedin.com/jobs?viewJob=jobId=2325090trk=jobs_biz_nprem


John Tyra
Manager Product Safety Group
Bose Corporation
The Mountain, MS-450
Framingham, MA 01701-9168
phone: 508-766-1502
fax: 508-518-4137

john_t...@bose.com

CONFIDENTIALITY NOTICE: This e-mail and any attachments relate to the official 
business of Bose Corporation and are proprietary to Bose.  This e-mail and any 
attachments may contain information which is confidential, proprietary, 
privileged or otherwise protected by law. The information is solely intended 
for the named addressee (or a person responsible for delivering it to the 
addressee). If you are not the intended recipient of this message, you are not 
authorized to read, print, retain, copy or disseminate this message or any part 
of it. If you have received this e-mail in error, please notify the sender 
immediately by return e-mail and delete it from your computer.





-

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] Mandatory NRTL certification

[Tyra, John]

I don't see where companies really have much of a choice as this is a legal 
requirement in 20 States for Consumer products

From: Ron Wellman [mailto:rwell...@wellman.com]
Sent: Friday, January 06, 2012 10:27 AM
To: Tyra, John; peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

This question comes up about every two years and what it boils down to is a 
catch 22. Damned if you do, damned if you don't. In my opinion, it is better to 
do regardless of how unbalanced these requirements are within the United 
States. As long as you budget for it and your management understands the risks 
of not having NRTL listing, it will be easier to manage.

Best regards,
Ron  Wellman

From: Tyra, John [mailto:john_t...@bose.com]
Sent: Friday, January 06, 2012 6:34 AM
To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: Mandatory NRTL certification

While there are no Federal laws requiring NRTL certification and marking of 
electronic products there are laws in 16 States which require an NRTL mark for 
mains connected electronic products...and laws in 4 other States which specify 
consumer products only. CEA commissioned a State survey, which was updated in 
2010, which outlines the legal requirement or lack of for all 50 
States...

From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of Ron 
Wellman
Sent: Thursday, January 05, 2012 11:49 PM
To: peterh...@aol.commailto:peterh...@aol.com; 
EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Mandatory NRTL certification

NRTL certification/listing is not mandatory for product Manufacturers. This is 
a Customer driven requirement so your Customers can comply with local OSHA 
requirements. If you don't want to list or certify your product that's really a 
Marketing call. Also, it is my experience that most large Companies require 
third party approvals as a condition of sale. Therefore, unless you want to be 
reactive to Customer sales I would make sure your Marketing people understand 
the risk of losing a sale if your product is not certified/listed by an NRTL.

Best regards,
Ron Wellman

From: emc-p...@ieee.orgmailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of 
peterh...@aol.commailto:peterh...@aol.com
Sent: Thursday, January 05, 2012 5:41 PM
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Mandatory NRTL certification

Hello All,

Today a colleague asked me a question as to why do we need NRTL certification 
such as UL or CSA on any product in the US. I thought this was a good and 
logical question and the way I answered it was that to the best of my 
knowledge, OSHA requires that any products that is used in work place to be 
safe and to have been certified by one of the NRTL labs. Would you say that is 
a correct answer?

Thank you
Peter
-


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discussion list. To post a message to the list, send your e-mail to 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Instructions: http://listserv.ieee.org/request/user-guide.html
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David Heald dhe...@gmail.commailto:dhe...@gmail.com
-


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Attachments are not permitted but the IEEE PSES Online Communities site at 
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RE: Cell and Battery Designation in IEC 61960

[Tyra, John]

 Hello Grace, If it is a Lithium battery then it does require a (PS)E mark by
November 10th what type of battery do you have?

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: Friday, October 24, 2008 2:05 PM
To: emc-p...@ieee.org
Subject: Re: Cell and Battery Designation in IEC 61960

 


Thank you, Jody.

 

Do you know if PSE mark is required per Japan for the battery?
 

On 10/24/08, Leber Jody-G19980 jody.le...@motorola.com wrote: 

Grace,

 

N5 represents the number of parallel connected cells indicating it belongs to
the battery designation.

 

Best Regards, 

Jody Leber 
Program Manager 

jody.le...@motorola.com 
http://www.motorola.com/producttesting 

Motorola Product Testing Services 
1700 Belle Meade Court 
Lawrenceville, GA 30043 

770.338.3581  P 
404.387.1224  C 
847.761.3145  F 

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace 
Lin
Sent: Friday, October 24, 2008 10:21 AM
To: emc-p...@ieee.org
Subject: Cell and Battery Designation in IEC 61960

 

Dear Members,

 

Can someone confirm the following Cell and battery designation under 
5.1 of
IEC 61960: 2003?

 

Battery shall be designated with the following form: 

N

1 A1 A2 A3 N2 / N3 / N4 – N5 

Cells shall be designated with the following form: 

A

1 A2 A3 N2 / N3 / N4 



 

The Japanes JIS C8711: 2006 standard has the following designation:  

Battery shall be designated with the following form: 

A1 A2 A3 N2 / N3 / N4

Cells shall be designated with the following form: 

N1 A1 A2 A3 N2 / N3 / N4 –N5



 

Do I miss any amendment or correction to either standard?

 

Thank you and look forward to your help.

Best regards,

Grace

-


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emc-pstc
discussion list. Website: http://www.ieee-pses.org/ 

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

 

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RE: Cell and Battery Designation in IEC 61960

[Tyra, John]

Hello Grace,

 

You are correct in that Lithium Batteries are now regulated in Japan and
require the (PS)E circle mark not the PSE diamond mark.

 

Here is a summary of what I know

 

Japan's Ministry of Economy, Trade and Industry (METI) has added Lithium
batteries: into a list of regulated DENAN products. The new requirements for
Lithium batteries will be implemented on November 20, 2008. 

Scope: Lithium batteries with its internal energy of 400Wh/L or higher are
regulated by DENAN as Non-Specified Product (NSP). NSP requires a PSE Mark
(PSE in a circle). Compliance with DENAN Technical Requirements Appendix 9 may
be confirmed by a third party testing or manufacturer's own testing. Test
reports (and/or certificates) may be required upon request from METI. Lithium
batteries physically detached from an end product in a package are covered by
DENAN. Replacement Lithium batteries are covered by DENAN. 

Exclusion: 
- Lithium batteries physically attached to an end product in a package are
excluded. Replacement batteries would need to be compliant
- Lithium batteries for automotive 
- Lithium batteries for medical equipment used in hospital or clinic 
- Lithium batteries for Industrial Machinery (for examples, commercial
measuring instrument, commercial radio, portable terminals used by delivery
companies, devices used for satellite or aerospace,  equipment for
police/fire department/self-defense military.) 
- Lithium batteries which are exported outside of Japan 
- Lithium batteries imported/manufactured before November 20, 2008 
- Replacement batteries for end-products whose production would be completed
before November 20, 2008. (My need special marking) 

Standards: 
- DENAN Technical Requirements Appendix 9: which are equivalent to JIS C8712
and C8714 
- Compliance with Overcharge Test and Drop Test will be required after
November 20, 2011. 

 

Here are links to the Appendix 9 translations

 

http://www.meti.go.jp/policy/consumer/seian/denan/lithium/080703/law.pdf 
http://www.meti.go.jp/policy/consumer/s
ian/denan/lithium/080703/cabinet_order.pdf 
http://www.meti.go.jp/policy/consumer/s
ian/denan/lithium/080703/ministerial_ordinance.pdf 
http://www.meti.go.jp/policy/consumer/s
ian/denan/lithium/080703/technical_requirements.pdf

 

I am not sure about other types of batteries and would be interested if anyone
has additional info on other chemistries.

 

Hope this helps.

 

Regards,

 

John

 

 

John Tyra

Manager Product Safety Group

Bose Corporation

The Mountain, MS-450

Framingham, MA 01701-9168

phone: 508-766-1502

fax: 508-766-1145

 

 

 

 






 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: Monday, October 27, 2008 3:18 PM
To: emc-p...@ieee.org
Subject: Re: Cell and Battery Designation in IEC 61960

 

Hi John,

 

Thank you very much.  We have several different types of batteries.  Lithium
battery is one of them.  I believe the Japanese requirement starting November
20, 2008 is for the lithium battery.

 

I assume the PSE mark required is the diamond one (not circle one).  Please
confirm.

 

Best regards,

Grace 

 

On 10/27/08, Tyra, John john_t...@bose.com wrote: 

 Hello Grace, If it is a Lithium battery then it does require a (PS)E mark by
November 10th what type of battery do you have?

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin
Sent: Friday, October 24, 2008 2:05 PM
To: emc-p...@ieee.org
Subject: Re: Cell and Battery Designation in IEC 61960

 


Thank you, Jody.

 

Do you know if PSE mark is required per Japan for the battery?
 

On 10/24/08, Leber Jody-G19980 jody.le...@motorola.com wrote: 

Grace,

 

N5 represents the number of parallel connected cells indicating it belongs to
the battery designation.

 

Best Regards, 

Jody Leber 
Program Manager 

jody.le...@motorola.com 
http://www.motorola.com/producttesting 

Motorola Product Testing Services 
1700 Belle Meade Court 
Lawrenceville, GA 30043 

770.338.3581  P 
404.387.1224  C 
847.761.3145  F 

 



From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace 
Lin
Sent: Friday, October 24, 2008 10:21 AM
To: emc-p...@ieee.org
Subject: Cell and Battery Designation in IEC 61960

 

Dear Members,

 

Can someone confirm the following Cell and battery designation under 
5.1 of
IEC 61960: 2003?

 

Battery shall be designated with the following form: 

N

1 A1 A2 A3 N2 / N3 / N4 – N5 

Cells shall be designated with the following form: 

A

1 A2 A3 N2 / N3 / N4 



 

The Japanes JIS C8711: 2006 standard has the following designation:  

Battery shall be designated with the following form: 

A1 A2 A3 N2 / N3 / N4

Cells shall be designated with the following form: 

N1 A1 A2 A3 N2 / N3 / N4 –N5

Formaldehyde Emission Testing for particleboard and MDF

[Tyra, John]

Hello everyone,

 

I am helping out our Environmental group to try to locate a lab which can
perform Formaldehyde Emission Testing for particleboard and MDF.

 

Any leads or suggestions would be appreciated.

 

Regards,

 

John

 

John Tyra

Bose Corporation

The Mountain, MS-450

Framingham, MA 01701-9168

phone: 508-476-7741

fax: 508-766-1145

 

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RE: Formaldehyde Emission Testing for particleboard and MDF

[Tyra, John]

Thanks John, I have to assume the Environmental group already tried that and 
did not find what they were looking for. I was hoping for a recommendation from 
someone who has experience with a specific lab.


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Friday, July 25, 2008 11:28 AM
To: emc-p...@ieee.org
Subject: Re: Formaldehyde Emission Testing for particleboard and MDF

In message 
3c6137471f17424280d9b2ceaefd7f8501488...@usmafrexmb01.bose.com, dated 
Fri, 25 Jul 2008, Tyra, John john_t...@bose.com writes:


I am helping out our Environmental group to try to locate a lab which 
can perform Formaldehyde Emission Testing for particleboard and MDF.

 

Any leads or suggestions would be appreciated.

Lots of hits on Gogle.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Either we are causing global warming, in which case we may be able to stop it,
or natural variation is causing it, and we probably can't stop it. You choose!
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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RE: UL 2054 testing for lithium batteries

[Tyra, John]

Also be aware that the DENAN law in Japan has been amended so that some
Lithium Ion Batteries are now regulated.

Japan's Ministry of Economy, Trade and Industry (METI) has added
Lithium batteries: into a list of regulated DENAN products. The new
requirements for Lithium batteries will be implemented on November 20,
2008. 

Scope: Lithium batteries with its internal energy of 400Wh/L or higher
are regulated by DENAN as Non-Specified Product (NSP). NSP requires a
PSE Mark (PSE in a circle). Compliance with DENAN Technical Requirements
Appendix 9 may be confirmed by a third party testing or manufacturer's
own testing. Test reports (and/or certificates) may be required upon
request from METI. Lithium batteries physically detached from an end
product in a package are covered by DENAN. Replacement Lithium batteries
are covered by DENAN.

Applicable standards are JIS C8712 and C8714 which are similar, but not
identical to IEC 62133 Standard (or UL1642). Due to METI's concern about
recent accidents from Lithium batteries, JIS Standards include several
additional tests such as forced internal short circuit test. Therefore,
batteries which comply with UL Standard or IEC Standard need additional
tests to satisfy DENAN. I contacted METI on this issue and they
commented that English version of the requirements will be released this
month sometime


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Scott B.
Lacey
Sent: Monday, July 07, 2008 11:41 AM
To: Scott Xe
Cc: emc-p...@ieee.org
Subject: RE: UL 2054 testing for lithium batteries

Richard and Scott,

Interestingly, some years ago I worked on a 
project involving a reaction calorimeter. One 
use (for some customers) was to test battery 
chemistries for just this type of runaway 
condition.

The materials being tested were heated in a 
containment vessel until an exothermic 
reaction occurred. Temperature and pressure 
were both tracked throughout. The idea was 
to determine the conditions preceding a 
runaway reaction so that protection could be 
added to battery packs to keep them below 
the critical temperature and pressure.

I suspect the Li-ion failures involve a flaw in 
the protection scheme  implementation rather 
than a lack of understanding the mechanism 
of failure. In the meantime I would advise 
anyone using Lithium-ion batteries to avoid 
recharging heavily discharged ones until they 
have cooled for a while. The same goes for 
drawing high current immediately after a 
charge.

Scott B. Lacey

On 7 Jul 2008 at 22:29, Scott Xe wrote:

 Richard,
 
 If you want to prevent the battery pack from explosion/fire,
compliance of
 those standards might not accomplish it for the time being.  UL 2054,
UL
 1642 and UL 60950-1 were prepared and published before Sony's battery
 recall.  All the standards are being revised to address the issue.
After a
 large scale of Sony's battery recall, the Li-ion battery pack
continues to
 explode and catch fire in a smaller scale.  The users are awaiting the
new
 replacement of battery pack or a firm solution to the probable
explosion of
 existing Li-ion battery pack.
 
 Regards.
 
 Scott
 
 -Original Message-
 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of
 kazimier_gawrzy...@dell.com
 Sent: Thursday, July 03, 2008 12:24 AM
 To: rpick...@rpqconsulting.com; oconne...@tamuracorp.com;
emc-p...@ieee.org
 Subject: RE: UL 2054 testing for lithium batteries
 
 Also.For end use systems seeking compliance with UL 60950-1, see
 Annex P.1 with reference to cl. 4.3.8
 
 Kaz
 kazimier_gawrzy...@dell.com
 
 
 -Original Message-
 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ron
 Pickard, RPQ
 Sent: Wednesday, July 02, 2008 11:07 AM
 To: 'Brian O'Connell'; 'emc-p...@ieee.org'
 Subject: RE: UL 2054 testing for lithium batteries
 
 Richard,
 
  
 
 IMHO, if the lithium batteries are user replaceable (such as a
removable
 battery pack), then they would need to be separately approved to UL
 2054. I
 say that because in my experience, UL has required it in past Listing
 efforts of products with them. And, if this is a cell phone
application,
 please note that the CTIA has recently imposed requirements for
lithium
 batteries.
 
 Supporting this, from UL2054's scope:
 
  
 
 - These requirements cover portable primary (nonrechargeable) and
 secondary
 (rechargeable) batteries for use as power sources in products. These
 batteries consist of either a single electrochemical cell or two or
more
 cells connected in series, parallel, or both, that convert chemical
 energy
 into electrical energy by chemical reaction.
 
 - These requirements are intended to reduce the risk of fire or
 explosion
 when batteries are used in a product. The proper use of these
batteries
 in a
 particular application is dependent on their use in a complete product
 that
 complies with the requirements applicable to such a product.
 
 - These requirements are intended to cover batteries for general 

EUP Legislation

[Tyra, John]

Hello everyone,

 

Can anyone suggest a consultant in Europe who is plugged into the evolving
Energy Using Products  legislation machinery in the EU who would be able to
keep us up to date on things they evolve??

 

We have resources here in the States and are involved in things developing
here but need someone in the EU to be our eyes and ears……..

 

Please e-mail me privately……

 

Regards,

 

John Tyra

Bose Corporation

The Mountain, MS-450

Framingham, MA 01701-9168

phone: 508-476-7741

fax: 508-766-1145

 

-  This
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Job Opening at Bose

[Tyra, John]

Hello everyone,

 

Bose has an immediate opening for a Product Safety Engineer to support the
development of Store fixtures/Kiosks/Displays.

 

Go to the following website and type 11508BR into the Requisition ID# search
field and the job description should come up.

 

https://www.bose.com/controller?event=V
EW_STATIC_PAGE_EVENTurl=/about/careers/search_jobs/index.jspck=0

 

This is a new position and not a replacement for someone who has left.

 

Please send me a copy of your resume if interested at the address below.

 

Regards,

 

John Tyra

Bose Corporation

The Mountain, MS-450

Framingham, MA 01701-9168

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RE: ENEC european complaince

[Tyra, John]

While not mandatory the ENEC Mark can be useful on components as some Agencies 
will accept this Mark as showing compliance to the applicable component 
standards. I have found this useful when getting a CB report for a product 
which incorporates an ENEC Marked safety critical component.




From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Thursday, June 19, 2008 3:32 PM
To: emc-p...@ieee.org
Subject: Re: ENEC european complaince


In message 949938.62703...@web65406.mail.ac4.yahoo.com, dated Thu, 19 
Jun 2008, sudhakar wasnik saloni95...@yahoo.com writes:


 
Is  ENEC mark mandatory for electrical products?
 

No, absolutely not. Compliance with the legal requirements of the Low 
Voltage Directive effectively makes such schemes irrelevant.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Either we 
are causing global warming, in which case we may be able to stop it, or natural 
variation is causing it, and we probably can't stop it. You choose! John 
Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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RE: Fw: resend environmental quotation.

[Tyra, John]

In these types of debates both sides can usually present their data to
make a strong case that they are correct on an issue. For the average
individual it comes down to what you want to believe which decides which
side you support...

We are seeing this currently with the arm wrestling that is going on
over the proposed change in flammability requirements for fire
enclosures for EDP and Audio Video products. I have followed this with
great interest as it affects our products and both sides have presented
data which defends their position IMHO.Each side arguments has it's
own merit..




From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John
Woodgate
Sent: Tuesday, May 06, 2008 10:21 AM
To: emc-p...@ieee.org
Subject: Re: Fw: resend environmental quotation.


In message
of5d189f68.412bb4e0-on85257441.0044356c-85257441.004c0...@lexmark.com,

dated Tue, 6 May 2008, oover...@lexmark.com writes:

A quote from the article:
   And she has a quality scientists try to cultivate: she is
skeptical.
   Has someone made a claim? She wants to see the data.

Yes, it's an easy demand to make. But collecting the data in a 
statistically rigorous way may be a USD 1 billion project. Especially 
this one - global warming.

I think it's widely accepted that Gore was misled. Government ministers 
are encouraged to think that they can deal with any subject, whether 
they have any significant background in it or not, simply because they 
are intelligent (well, most of them) and know how to distinguish fact 
from fiction. But they CAN'T do that with complex scientific subjects, 
especially when the scientists themselves violently disagree. The Royal 
Navy found that out - there were agonies over realizing that a ship's 
captain simply could not have total authority over the technical 
departments of the ship.

Nevertheless, it IS getting warmer. Either we are causing it, and can do

something about it, or it's happening without us and we almost certainly

can't stop it. You choose.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Murphy's Law has now been officially re-named The Certainty Principle
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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RE: UL approvals

[Tyra, John]

Carl wrote: 2. A manufacturer certified to perform their own UL
compliance subject to verification by UL, can the manufacturer build
systems while waiting for final approvals; and would it be possible for
the manufacturer to build and ship such a product without applying the
UL mark?

Same rules as if you submitted the product to UL for certification,
Technically you are not allowed to mark product with the UL mark which
was built before you received the UL approval letter allowing the
marking...You can however build and mark product once UL issues you
a certification letter (NOA letter) and don't have to wait for the UL
descriptive report to be issued as this can take 3-4 weeks to make it
through the UL system.You can always ship with out the UL
Mark but as mentioned there are a number of States in the U.S. which
legally require a Nationally Recognized Test Lab (NTRL) Mark on the
product to sell introduce it into the State..

Does this answer the question??


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of
Richards, Carl
Sent: Monday, April 10, 2006 2:12 PM
To: Jim Bacher; emc-p...@ieee.org
Subject: RE: UL approvals


Jim and All who responded,

Many thanks for all the input, most of which confirmed what I thought I
knew. The current un-answered question is regard to the UL/Manufacturer
compliancy scheme, hopefully someone will read this who can answer it.

All the best

Carl 


Carl Richards, 
Regulatory Compliance Manager, 
Aspect Software 
2, The Square
Stockley Park, Uxbridge, UB11 1AD, 
United Kingdom
 
 
+44 (0)208 589 1461 Office
+44 (0)870 460 1950 Fax
+44 (0)7875 27 1461  Mobile
www.aspect.com


From: Jim Bacher [mailto:jim.bac...@paxar.com] 
Sent: 10 April 2006 18:27
To: Richards, Carl; emc-p...@ieee.org
Subject: RE: UL approvals

Carl, others have answered your question about marking, but keep in mind
that there are state laws and federal regulations in the USA that
require that all products have a NRTL listing. So if you are talking
about prototypes, no big deal.  However, if you are talking about
production products, you could run into issues. 

Ref: OSHA: 29 CFR 1910, NEC 110-2 and Oregon law : 479.610
http://landru.leg.state.or.us/ors/479.html

Jim 

Jim Bacher
Senior Engineer
Paxar Americas, Inc.
170 Monarch Lane
Miamisburg, Ohio 45342
Voice: 937-865-2020
Fax: 937-865-2048
email: jim.bac...@paxar.com

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LVD Voltage Limits

[Tyra, John]

I want to thank everyone for the excellent responses and links...great stuff!! 

LVD voltage limits

[Tyra, John]

Hello Everyone, 

I have read on this list and have been told by TUV that the lower limits for
the voltages of products which fall under the Low Voltage Directive may be
eliminated so that low voltage products would now fall under that directive.

On the Europa website I read an LVD Working Document, dated 7/13/01, that
there were two proposals: 
  
1. Delete the lower limit and introduce risk assessment similar to the
Machinery Directive 
2. Leave the limits as is but add an annex to include certain low voltage
products, lighting system, household appliances, TV/Radio etc

I found a Working Guide for the LVD dated 3/7/02 which  showed that there are
countries which favor one or the other proposal while the UK favored no
change..

Does anyone have any new information or can point me in the direction which
would give me a more recent an update of this proposal? I am very interested
in where this proposal is heading..

Thanks in advance for your help.. 

Regards, 


John Tyra 
Product Safety and Regulatory Compliance Manager 

Bose Corporation 
The Mountain, MS-450 
Framingham, MA 01701-9168 
Phone: 508-766-1502 
Fax: 508-766-1145 
john_t...@bose.com 

RE: Class 1 AC/DC adapter

[Tyra, John]

Great answers Rich!

I do have one question for the group just for my own knowledge...back in my
TUV days I worked almost exclusively with IEC60950 and seem to remember that
a class II product can have a functional earth connection provided Primary
and other hazardous voltages are insulated from earth by reinforced
insulation. In this scenario even thought the product has an earth
connection would it still be considered class II with regards to the
IEC60950 standard and have to be marked as such?
Maybe it is semantics as you reference protective earth so it must be
class I as opposed to functional earth which is not relied upon for
safety.

I have not worked with IEC60950 for some 5 years now and do not have a copy
on hand as our products are UL/IEC60065 based so I apologize for the waste
of bandwidth if this is an easy lookup in 950

Look forward to all answers...

Regards,

John Tyra
Product Safety and Regulatory Compliance Manager

Bose Corporation
The Mountain, MS-450
Framingham, MA 01701-9168
Phone: 508-766-1502
Fax: 508-766-1145
john_t...@bose.com



From: Rich Nute [mailto:ri...@sdd.hp.com] 
Sent: Monday, November 03, 2003 5:16 PM
To: raymond...@omnisourceasia.com.hk
Cc: emc-p...@ieee.org
Subject: Re: Class 1 AC/DC adapter






Hi Raymond:


Any product with a PE (ground) connection is, by
definition, a Class I product.  The common adapters
you describe, despite being encased in plastic, are
Class I products.

   1.   Function of the grounding plate
   The primary and the secondary is reinforced insulation and withstands
over 
   3000Vac.  Is this plate to change the whole safety protection system
from 
   class 2 to class 1?  Or the plate is primarily for EMC suppression?

The single-sided ground-plane PCB you describe is
used to control EMC emissions.  It may also be used,
as you describe, to electrically ground the dc output.  
The ground plane has no safety function, per se.

While the safety standards require a product to be
Class I or Class II, it is physically impossible to
build a purely Class I product.  Every Class I product necessarily includes
Class II construction.  You have accurately described the adapter Class II
construction (reinforced insulation, primary-to-secondary).

In other words, the adapter has both Class I construction
and Class II construction.  

Safety standards ignore this physical true-ism.  Any
product with a PE is Class I, and is evaluated only to
the Class I requirements.

   2.   Earth continuity test
   After the unit is completely assembled, should we conduct the test
between 
   the earth terminal of the mains plug and the earth of DC output 
 plug?

Yes.

The earth continuity test is required for any accessible
metal part that is susceptible of becoming live in the
event of a fault of basic insulation.

Within the adapter, the Class I part of the construction
has basic insulation between the mains and grounded 
conductors.  Such grounded conductors must be subject to
the earth continuity test.  

Because the dc output is connected to the grounded 
conductor, the dc output could become live in the event 
of a fault of basic insulation.

So, an earth continuity test must be conducted between 
the dc ground and the PE terminal of the mains connector (because the unit
is sealed, the test cannot be made directly to the conductors where the
fault would occur).

   3.  Hipot test
   As the unit is classified as class 1, 1,500 Vac is applied between the 
   earth terminal of the mains female connector and the earth of the DC 
   output plug.  Actually, the primary and secondary can withstand 3000
Vac. 
   Is it correct test voltage to apply after the unit is completely 
   assembled?

Because the unit is Class I, the hi-pot test voltage is 
1500 V rms.

The hi-pot test is always performed on a fully-assembled
unit.

You are correct that the primary-secondary reinforced insulation must
withstand 3000 V rms.  Note also that the primary-foil (wrapped about the
outside of the
adapter) must also withstand 3000 V rms (because the
plastic comprises reinforced insulation to accessible surfaces).

While the unit will probably withstand 3000 V rms, you
should not production-line test to 3000 V rms because 
this may overstress the primary-ground insulation.


Best regards,
Rich






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RE: India Compliance

[Tyra, John]

I asked someone in India, the organization name escapes me, about cert
requirements for Audio products about a year ago and was told there were no
mandatory cert requirements for Safety or EMC...As Doug mentioned the
individual directed me to the BIS website for a list of regulated products
 
 http://www.bis.org.in/   

From: Doug Massey [mailto:dmas...@acstestlab.com] 
Sent: Tuesday, October 28, 2003 4:26 PM
To: 'Stone, Richard'; 'EMC PSTC'
Subject: RE: India Compliance



Hi Richard-

 

To my knowledge, India has no compulsory requirements for EMI/EMC or product
safety for information technology gear.

 

India is a member of the CB Scheme. htt
://www.cbscheme.org/cbscheme/NCB/IN-BIS.htm A certification mark from the BIS
should be available, if desired, by submitting a CB report and certificate to
BIS; however, there are some pretty steep fees involved.

 

There are certain electrical products that require compliance to Indian
standards, and certification and marking by the BIS. Check the list at
http://www.bis.org.in/cert/man.htm. Mostly household appliances and electrical
stuff.

 

In my experience, a product that carries other regulatory compliance marks,
such as FCC, CE, UL, etc., is acceptable in India. If you've done your work
for North America and the EU, you should be fine for India.

 

Not sure about RF products and telco infrastructure gear.

 

You may want to contact the Government of India, Telecommunication Engineering
Center. Type approval for some types of equipment is required.
http://wwwdel.vsnl.net.in/tec/

 

Hope this helped.

 

Doug Massey

Product Safety Engineer

Advanced Compliance Solutions

Ph. (770) 831-8048

FAX (770) 831-8598

Visit our web home at http://www.acstestlab.com http://www.acstestlab.com/ 

 


From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of Stone, Richard
Sent: Tuesday, October 28, 2003 1:19 PM
To: Georgerian, Richard; EMC PSTC
Subject: India Compliance

 

hello group,

2 questions in one day,

does this fulfill my allowance?

 

What are the India reuqirements for:

EMC-EMI

Safety

Telecom

Other?

 

do they reference other standards such 

as UL, EN and FCC type requirements...

 

thank you for taking a few minutes on this..

Richard,

 

Richard A. Stone 
Excel Switching Corporation 
Compliance 
75 Perseverance Way 
Hyannis, MA. 02601 
508 862 3311 ph. 
508 862 3020 fax 
rst...@xl.com 

This email message and any attachments to it contain confidential information
that is intended only for the person or entity to which it is addressed.  Any
review, retransmission, dissemination, printing, or other use of, or taking of
any action in reliance upon, this information by persons or entities other
than the intended recipient is prohibited.  If you received this in error,
please delete it or inform the sender.









From: Georgerian, Richard [mailto:rgeorger...@carrieraccess.com]
Sent: Tuesday, October 28, 2003 10:06 AM
To: 'EMC PSTC'
Subject: RE: NARTE questions

Greetings All,

 

Only time will tell if being a NARTE certified product safety engineer will
have an impact in the profession. I just got my certificate yesterday. In the
long run, I think it'll help, but we have to start somewhere. Hopefully,
having this type of program will start a process to which people expect a
certain level of knowledge on product safety. Something analogous to someone
having a bachelors, masters or Ph.D. There is a certain level of knowledge
that one expects when someone has these degrees. (It is only a general
statement and I am sure there are plenty of knowledgeable people who do not
have degrees, that a smarter than those who do.) 

 

Good luck to all those who apply.

 

Richard

=

Richard Georgerian

Compliance Engineer 

Carrier Access Corporation

5395 Pearl Parkway

Boulder, CO 80301

USA

Tele: 303-218-5748 Fax: 303-218-5503 mailto:rgeorger...@carrieraccess.com

 


From: Brian O'Connell [mailto:boconn...@t-yuden.com]
Sent: Monday, October 27, 2003 3:58 PM
To: 'EMC PSTC'
Subject: NARTE questions

Good People 

I have downloaded the Product Safety Certification Application package from
NARTE. 

Is this a certification that hiring managers recognize? Is it anticipated that
managers and/or hiring speacilists will come to recognized this certification
as significant?

Also, is there any relationship between NARTE and the IECEE? 

Thanks much for advice and opinion. 

R/S, 
Brian O'Connell 
Taiyo Yuden (USA), Inc 



*
This e-mail transmission, and any documents, files, or previous
e-mail messages attached to it may contain information that is 
confidential or legally privileged. If you are not the intended 
recipient, or a person responsible for delivering it to the 
intended recipient, you are hereby notified that you must not 
read this transmission and that any disclosure, copying, printing,
distribution, or use of any of the information 

RE: Fault condition test UL 60950

[Tyra, John]

If I understand Lou's intent for many standards he  is technically correct
If you read UL/IEC60065 sub-clause 4.3, the standard states that if a circuit
is less then 35Vp a.c. or d.c., not generating voltages above that value, and
is not supplied by a circuit which can source 0.2A into any load for more then
2 minutes then fault conditions are not required. Whether you want to do
faults in any case is certainly up to you and may be desirable as 7 watts can
still heat up a low power component in a short time.
 
 
 
 
 
 
 From: richwo...@tycoint.com [mailto:richwo...@tycoint.com] 
Sent: Thursday, October 23, 2003 3:39 PM
To: emc-p...@ieee.org
Subject: RE: Fault condition test UL 60950



Lou, I have to take exception to your last paragraph. We often have to perform
fault testing in low voltage circuits to verify conformity to SELV
requirements at the output ports. We also perform fault testing to determine
comformity to the limits for limited power circuits.
 
Richard Woods 
Sensormatic Electronics 
Tyco International 

 


From: aiken [mailto:ai...@gulftel.com]
Sent: Thursday, October 23, 2003 2:04 PM
To: Van Compernolle, Eric; emc-p...@ieee.org
Subject: Re: Fault condition test UL 60950


Eric.  There are places in a circuit where film resistors are required by UL,
such as where they bridge insulation.  Ordinary carbon resistors are
unacceptable in these cases - at least in the categories I usually work in. 
So film resistors are not considered to fault in a shorted state.
 
As for caps and diodes you must make that decision based upon what the result
of the fault will be.
 
If an unlikely fault (short or open) will be something that can result in a
hazard - within the meaning of the applicable standard - then it should be
considered and provision made in the design to prevent the unacceptable
increased risk.
 
Sorry this is not such a clear cut answer but diodes and capacitors can fail
in both shorted and open states, so a certain amount of circuit analysis is
necessary
 
Approved X, Y, Antenna coupling caps,  Antenna bypass caps are not shorted
during fault testing - at least in the categories I ordinarily work with.
 
Components in low voltage circuits are not investigated (for safety) when the
available power is below certain limits.  Those limits will be given in the
standard applicable to the product.
 
 
Regards,
 
Lou Aiken, LaMer LLC 
27109 Palmetto Drive
Orange Beach, AL
36561 USA
 
tel ++ 1 251 981 6786
fax ++ 1 251 981 3054
Cell ++ 1 251 979 4648

 

RE: Regulatory Plan

[Tyra, John]

Not sure why you feel this way Derek but I have found that for our audio
products, anyway,  a CB report is the most cost effective and valuable tool in
getting certification in non-EU countries, which have mandatory certification
requirements. This allows certification  without having to completely retest
product which would increase costs and lead-times incredibly. Armed with a CB
certifications and report we are now able to get certs in China, Singapore,
Korea, Argentina, S. Africa, Poland ( still required until May 2004), Russia 
and even in non CB member countries Mexico and Taiwan..
 
Without a CB certification I can easily see the certification costs exceeding
$50K with an additional 3-6 months lead-time not to mention the internal
engineering time and samples costs to support the individual country
certifications.For Bose, at least, this is the best $3K  per
product investment we could ever make
 
CB will not work for every product category but for products where it is
available I would recommend highly that it be investigated as a certification
option...
 
 -Original Message-
From: lfresea...@aol.com [mailto:lfresea...@aol.com] 
Sent: Wednesday, October 22, 2003 2:47 PM
To: Tyra, John; santo.mazz...@baesystems.com; marti...@appliedbiosystems.com;
emc-p...@majordomo.ieee.org
Subject: Re: Regulatory Plan



In a message dated 10/22/2003 1:42:02 PM Central Daylight Time,
john_t...@bose.com writes:


I don't know what type of product you are trying to put a plan together for
but I would highly recommend you get a CB certification and report for the
products especially if you are planning to sell in the Far East. The CB
certification will help you with Singapore, Korea, China approvals and limit
the amount of retesting

I would have to disagree with the involvement of a CB unless there was a
REQUIREMENT to do so..
 
Instead, invest your resources in understanding and complying with the
harmonised standards aplicable to your Product.
 
Derek N. Walton
Owner, L F Research EMI Design and Test Facility
Poplar Grove,
IL 61065

RE: Regulatory Plan

[Tyra, John]

I don't know what type of product you are trying to put a plan together for
but I would highly recommend you get a CB certification and report for the
products especially if you are planning to sell in the Far East. The CB
certification will help you with Singapore, Korea, China approvals and limit
the amount of retesting


From: Mazzola, Santo [mailto:santo.mazz...@baesystems.com] 
Sent: Wednesday, October 22, 2003 10:41 AM
To: marti...@appliedbiosystems.com; emc-p...@majordomo.ieee.org
Subject: RE: Regulatory Plan





The first aspect of a regulatory plan would be to get a planned list of all
the countries that they wish to sell the product into.  After that the next
stewp would be to determine what standards are applicable and need to be
tested to.  Next would be to determine what approvals if any are necessary
and a plan of action to obtain them. After the standards and approvals
questions are answered the necessary markings would have to be determined
and planned for.

Sandy Mazzola
BAE Systems Inc



From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Wednesday, October 22, 2003 8:26 AM
To: marti...@appliedbiosystems.com; emc-p...@majordomo.ieee.org
Subject: RE: Regulatory Plan



I like to keep it simple, so I list the standards that will be applied and
the licenses/marks that will be obtained. I found that no one outside the
compliance group really cares what is in the document as long as the list of
project deliverables has a check mark by this one. Yep, its been delivered.

Richard Woods
Sensormatic Electronics
Tyco International




From: Joe P Martin [mailto:marti...@appliedbiosystems.com]
Sent: Tuesday, October 21, 2003 4:27 PM
To: emc-p...@majordomo.ieee.org
Subject: Regulatory Plan







Greetings,

I have been asked to put together a regulatory plan for one of our company's
products.  I am trying to get as many opinions as possible as to the
elements of such a plan. Please share with me your elements of such a plan
and, if possible, send me a copy of a plan to use as an example.

Your assistance is greatly appreciated.

Regards

Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com



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RE: metallic coatings

[Tyra, John]

Related to the question ...UL 746C sub-clause 47 specifies testing for
adhesion of   metallized coatings for EMC purposes. They reference test
criteria in 
ASTMD 3359..If you are submitting to UL and you want to use an EMC
metallized coating in a product, where if the coating was to flake spacings
would be compromised, UL will require you pass these testsWhen
I investigated this in the past Europe did not have any similar tests so an
Engineer from TUV in Germany told me he would accept the UL
results.Although this may have changed..Anyone
know of any similar requirements for adhesion testing for Europe??
 
 


From: Ilan Cohen [mailto:ico...@itl.co.il] 
Sent: Monday, October 20, 2003 1:53 PM
To: 'Ken Javor'; emc-p...@majordomo.ieee.org
Subject: RE: metallic coatings



Hi Ken 

From a safety point of view I typically recommend not to use coating on
Plastics. The results can be destructive and dangerous. After  some time you
may end up with metallic coating parts falling on electronics and the results
can be fire or electric hazard.

UL has evaluated plastics and conductive coating for the plastics that matches
and stays safe. Consult with UL people for the correct combination.

Ilan 


-- 
Ilan Cohen 
Technical Director, Safety  Telecom Divisions 
I.T.L (PRODUCT TESTING) Ltd. 
26 Hacharoshet St, POB 211, Or Yehuda, Israel. 
Tel 972-3-5339022, Fax 972-3-5339019 
ico...@itl.co.il, website: http://www.itl.co.il 
 

 
I-SPEC: The best place on the internet to learn about safety !! 
http://www.i-spec.com/ 
(I-Spec is provided free of charge as a service by ITL to the compliance
community) 

- 


-Original Message- 
From: Ken Javor [ mailto:ken.ja...@emccompliance.com] 
Sent: Friday, October 17, 2003 4:03 AM 
To: emc-p...@majordomo.ieee.org 
Subject: metallic coatings 



Does anyone have any suggestions for a metallic coating that can be 
deposited on the interior of a plastic box that would need to meet military 
environmental conditions?  Suggestions for other metallization techniques 
are also welcome. 

Thank you. 


--- 
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RE: Job Opportunity - Maryland

[Tyra, John]

I thought asking a persons age on a job application for employment is
illegalyes


From: Mike Cantwell [mailto:mcantw...@leapfroginet.com] 
Sent: Wednesday, October 15, 2003 12:22 PM
To: Emc-Pstc
Cc: Bryan Axmear
Subject: Job Opportunity - Maryland



I received the following job opportunity from this recruiter:
 
 mailto:bryan_axm...@oxfordcorp.com bryan_axm...@oxfordcorp.com
 
He has helped others on this list find employment in the past so if anyone is
interested in this position or knows of someone interested in this position
either contact him directly or you can contact me and I'll help them get
through.
 
Looks like the emphasis is on design and analysis and not on testing. For
whatever reason, age seems to matter, I'm sure to reflect salary versus
experience. Good luck to those interested.
 
Job Description:
 
I need a emi/emc ANALYSIS/DESIGN (opposed to a straight test) guy that
graduated from college between the years of  1988-1992. Job in maryland. 
Emi analysis, pspice, mathcad, RF work of any kind.
 
t1) a graduate that didnt graduate any earlier than 1986
2) the candidate knows that my manager may want to make him an offer after 9
months for perm placment
3) it is emc/emi analysis and design instead of straight emi/emc testing
 
 
 

Fire and Evac standards requirments for Japan

[Tyra, John]

Hello everyone,
 
Would anyone happen to know if there are any fire and evac regualroty
requirments for passive speaker in Japan? I have checked on the METI website
and was not able to find any information. I also called JETRO who pointed me
to METI
 
For the U.S we are certified to UL1480 and for Europe each country seems to
have their own regulations with the EN54 family of standards possibly being
harmonized but I cannot seem to find any info for Japan.
 
Any info anyone might have is appreciated.
 
regards,
 
John

Job opening Product Safety Engineer

[Tyra, John]

I have a job opening for a Product Safety Engineer here at Bose...minimum
3- 5 years product safety experience preferred, must have thorough knowledge
of  IEC/UL60065 or similar standards 950, 1010 etc, have handled Agency
submittals, and be willing to get your hands dirty doing testingif 
anyone  interested I can send you a job description off list. Please feel free
to contact me if you have any questions..

Regards, 

John Tyra 
Product Safety and Regulatory Compliance Manager 

Bose Corporation 
The Mountain, MS-450 
Framingham, MA 01701-9168 
Phone: 508-766-1502 
Fax: 508-766-1145 
john_t...@bose.com 


  

RE: Japanese labeling requirements

[Tyra, John]

We just went through this exercise recently and, yes that is correct,
someone in Japan must take the responsibility as the Reporting Supplier
(Importer) of the product. If you do not have an importer in place, or a
subsidiary in Japan, who can take on the responsibility then your customer
must take on this task. The reporting suppliers name must appear under the
applicable PSE Mark on your product label. In addition there are other
reporting responsibilities the Reporting Supplier must perform and these
vary somewhat depending on which PSE Mark you must have on your product the
Diamond or Circle Mark.

Take a look at these links as they may help you understand the reporting and
labeling requirements.

http://www.jetro.go.jp/se/e/standards_regulation/index.html
 
http://www.vcci.or.jp/vcci_e/index.html 
 
http://www.jate.or.jp/index-e.html

The Jetro site is excellent and has a guide to understanding the regulations
which you can download

Hope this helps...
 


From: Gerald Tammi [mailto:gera...@zoom.com] 
Sent: Monday, July 28, 2003 2:03 PM
To: 'emc-pstc'
Subject: Japanese labeling requirements



I have an opportunity for shipments to a Japanese customer.  I have been
told that the Japanese METI (Ministry of Economy, Trade and Industry) has a
regulation that the importers name or logo must be on the product.  Has
anyone had experience with this requirement.  Or can point me to where I can
find the information.

Thank you in advance.

Gerald Tammi
Zoom Telephonics,
617-753-0584



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RE: More Odd Standards (To me anyway)

[Tyra, John]

IP ratings are described in IEC60529  Degrees of protection provided by
enclosures (IP code)...

The first characteristic numeral, 5, denotes protection against access to
hazardous parts and/or protection against entry of solid bodies. In this
case you must protect against access by a 1.0mm probe and the product is
tested for dust protection. Dust is allowed to enter the product but it must
not interfere with satisfactory operation of the product or impair
safety...

The second numeral, 5, denotes protection against ingress of water. In this
case your product is to be tested for protection against water jets. Pass
fail criteria can include dielectric testing, determination if creepage and
clearance distances have been compromised, etc..

The pass fail criteria for the contact with hazardous parts is cut and dried
while for the dust and water ingress are somewhat subjective.

The tests are well defined in the standard and require specialized equipment
in most cases...

Hope this helps.


From: Chris Maxwell [mailto:chris.maxw...@nettest.com] 
Sent: Tuesday, July 15, 2003 8:09 AM
To: EMC-PSTC Internet Forum
Subject: More Odd Standards (To me anyway)



Hello all,

It seems that I have been getting some odd requests from our customer
support people.

We recently have been asked about compliance to IP55 and an EMC standard
numbered G.692.   IP55 sounds like an ingress protection level to me.
I'm drawing a complete blank on G.692.

Is anybody familiar with these?

Thanks,

Chris Maxwell | Design Engineer - Optical Division
email chris.maxw...@nettest.com | dir +1 315 266 5128 | fax +1 315 797 8024

NetTest | 6 Rhoads Drive, Utica, NY 13502 | USA
web www.nettest.com | tel +1 315 797 4449 | 






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RE: CE without LVD?

[Tyra, John]

I also heard the future incarnation of the LVD will start at
0V


From: Cereceres, David [mailto:dcerece...@pelco.com] 
Sent: Friday, June 27, 2003 1:27 PM
To: 'Rich Nute'; david.gelf...@memotec.com
Cc: emc-p...@majordomo.ieee.org
Subject: RE: CE without LVD?



Mr. Nute, 
In regards to your suggestions below, would it not be wise to take into
consideration the future plans of the LVD?  My understanding is that the LVD
will soon be called the EPSD.  Part of this change will encompass what is
referred as  No Risk / Low Risk equipment.  Would it be safe to say that
the current definition of equipment designed for use with a voltage rating
of 50-1000 V ac will change to equipment for use with a voltage rating of
0-1000V ac?

the opinions of this group are always appreciated,

David Cereceres
Safety Engineer
Pelco 

 -Original Message-
From:   Rich Nute [mailto:ri...@sdd.hp.com] 
Sent:   Friday, June 27, 2003 9:00 AM
To: david.gelf...@memotec.com
Cc: emc-p...@majordomo.ieee.org
Subject:Re: CE without LVD?






Hi David:


   It is being suggested that this product does not need safety testing and
   does not need to include the reference to EN 60950 and the LVD in the CE
   DoC, since it is SELV circuits only.

The LVD applies to products with voltage ratings
between 50 and 1000 V ac and between 75 and 1500
V dc.

SELV does not exceed 30 V ac and 60 V dc.

Therefore, the LVD does not apply to a product
that operates from a SELV source of supply.  (We 
may be able to say that the LVD does not apply 
to a Class III product.)

However, it is appropriate to indicate in the DoC
that the LVD does not apply to the product because
the product voltage is below the lower limits of
the LVD.  

HOWEVER... EN 60950 applies to products powered
from a SELV source of supply.  The electric shock
requirements do not apply to such products, but
the other EN 60950 requirements do apply to such
products.  These other requirements include the 
so-called energy hazard requirements, mechanical 
requirements, and fire requirements.

So, the product does indeed require safety testing,
but not with respect to the LVD.  The DoC should 
indicate compliance with EN 60950.  

Pragmatically, since you must test for compliance 
to EN 60950 for these other requirements, it is 
just as easy to indicate compliance to the LVD via 
EN 60950 and thereby avoid any future argument 
whether the LVD applies or not.

Most of our inkjet printer products are powered
by an external SELV source of supply.  We test
to EN 60950 and declare compliance with the LVD.


Best regards,
Rich


 


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RE: AC outlet max current

[Tyra, John]

At what duty cycle


From: Robert Johnson [mailto:john...@itesafety.com] 
Sent: Monday, May 05, 2003 10:48 AM
To: 'JP Hare'; emc-p...@majordomo.ieee.org
Subject: RE: AC outlet max current



A noncontinuous load is permitted to use 100% of the circuit rating. Only
continuous loads need the derating.

Bob Johnson
ITE Safety
 


From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of JP Hare
Sent: Thursday, May 01, 2003 12:20 PM
To: Gonzalez, Kenneth P (Rocky); emc-p...@majordomo.ieee.org
Subject: RE: AC outlet max current


Hi Rocky,

Article 210 of the NEC lists the requirements for branch circuits and
associated receptacles.  Table 210.21(B)(2) shows the receptacle load limits
and section 210.23 discusses the permissible loads in more detail.

On a related topic, I recently had a discussion with a colleague regarding
the plug for a certain North American hand-held hair dryer.  The ratings on
it are 1875 watts, 125 volts.  That puts it right at a 15 amps.  However the
plug is an ungrounded polarized NEMA 1-15 type with a built in GFIC.  This
allows it to be plugged into any standard 15 amp receptacle that you find in
the US.  Knowing the 80% requirement for cord-and-plug-connected loads, I
questioned how an NRTL could list this device.  It would seem that a 5-20
plug (perpendicular blades) would be necessary so that a 20 amp receptacle
would have to be used.

Our thoughts ranged from the cynical money talks theory to a more
logically based engineering justification.  (The code says that bathroom
receptacles must be on their own 20 amp branch with no other receptacles.)
But we never came to a final conclusion on why an NRTL would allow a 15 amp
plug-and-cord load to be plugged into a 15 amp receptacle.

Maybe our peers on the EMC-PSTC listserv have some ideas?

Regards,
J.P. Hare





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EU Language requirements for Manuals

[Tyra, John]

Hello everyone, 

I was hoping someone out there could help me determine what are the language
requirements for translation of manuals for the CE-Mark.

As I am sure most of you know Bose makes Audio/Video products. Our products 
fall under the LVD, EMC, and for wireless remotes the RTTE Directives.

I have read each of these Directives and associated standards, IEC60065 etc.,
and could only find reference that the Safety Related instructions must be
translated into the language acceptable in the country of sale.

We have had some of our European contacts claim that there are Local laws in
some EU countries which require the complete users and possibly service
manuals to be translated into the appropriate language for the country of sale.

Can any one advise me: 

1. If any EU country requires the complete manual to be translated into the
acceptable language 
2. If there are such requirements in some of the EU countries does anyone know
which countries impose these extra requirements?

3. Anyone know of a resource where this information is available?? 

Thanks in advance for your help. 

Best regards, 

John 

John Tyra 
Product Safety and Regulatory Compliance Manager 

Bose Corporation 
The Mountain, MS-450 
Framingham, MA 01701-9168 
Phone: 508-766-1502 
Fax: 508-766-1145 
john_t...@bose.com 
  

RE: Importing Bluetooth product into Egypt and Saudi Arabia

[Tyra, John]

Kurt,

Try contacting this gentlemen. I think he can help you

Nabil Bill Bekdash
+1 978 635-8650/1/2/3 (Phone)
+1 978 635-1620 (Fax)
Email address: nbekd...@etlsemko.com
RLC-Americas Department E-mail address: r...@etlsemko.com
Kuwait PAI ICCP web site address: www.pai-iccp.com
SASO ICCP web site address: www.iccp.com

RLC-Americas Mailing address:
ITS-ICCP RLC-Americas
70 Codman Hill Road
Boxborough, MA 01719
USA

regards,

John


From: Kurt Fischer [mailto:kurt.fisc...@hyperinterop.com]
Sent: Tuesday, March 18, 2003 11:29 AM
To: emc-p...@majordomo.ieee.org
Cc: Diana Eberhard
Subject: Importing Bluetooth product into Egypt and Saudi Arabia



Hello colleagues,

I was wondering if anyone has any information on importing a Bluetooth
portable product into Egypt and Saudi Arabia.

Bluetooth is low-powered (less than +4 dBm)wireless technology. The device
operates in the 2.4 GHz ISM band and uses FHSS technology. The product would
already be approved to FCC and EU/ETSI test requirements.

The info needed is:
1. What is the process? (how long in time? cost in dollars?)
2. Is in-country testing required?
3. Must there be a local agent?

Thank you in advance for any information that you can provide.

Regards to all,
Kurt 




Kurt B. Fischer
Hyper Corporation
1279 Quarry Lane, Suite B
Pleasanton, CA  94566-8499

Business:   +1 (925) 462-9105 x 205
Business Fax:   +1 (925) 280-7751
mailto:kurt.fisc...@hyperinterop.com



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RE: Comment re: RE: SV: NRTL in the U.S.

[Tyra, John]

No offense taken Bill

I will remember this in the future and offer an attachment to those who are
interested instead of wasting everyone's bandwidth and internet connection
time..I apologize to those this inconvenienced...

regards,

John


From: b...@lyons.demon.co.uk [mailto:b...@lyons.demon.co.uk]
Sent: Saturday, January 18, 2003 6:19 AM
To: Tyra, John; emc-p...@majordomo.ieee.org
Subject: Comment re: RE: SV: NRTL in the U.S.


In message 418fbd441c22d5118d860003470d43160543f...@cupid.bose.com
   Tyra, John writes:

 Attached is an article from the Conformity 2002 Annual Guide titled Know
 When You Need To List Your Product And When You Don't written by John
 Curtis of Curtis- Strauss LLC. It gives some great information. For those
 who, rightfully, fear attachments, I ran this through a dedicated scanner
 and our outgoing e-mails are virus scanned so I hope that gives you some
 confidence as to the integrity of the attachment..Hope this
 helps...

[all previous snipped]

Dear John,

No, I don't necessarily fear attachments, but they are a terrific 
nuisance to those on a dial-up connection, as I am, and annoying to 
those who don't need them, e.g. in this instance those who are not 
involved in the U.S. market for example.  

I was horrified when my connection seemed to be hanging and when the 
connection at last closed found that there was a mail of no less than 
839,820 bytes, and which took a helluva time, and added quite a bit to 
my phone bill, to download.  

Please may I suggest that if you had emailed your full response to 
those directly involved and posted a note to EMC-PSTC saying how much 
you valued the article and from where it could be downloaded (or that 
you would mail it on request), this would have been equally helpful 
and saved a lot of bandwidth for everyone else.  

Apologies both to you, as I know you meant well, and to the list 
administrators who may think I am infringing on their prerogative, but 
not everyone on this list is on a broadband connection and I thought 
it right to explain this.  (Actually, I think the list standing 
guidelines deprecate the posting of binaries/attachments.)

Incidentally, I'm sure Conformity will be delighted at the free 
publicity, but there can be copright issues in posting articles or 
other third party documents to mailing lists or newsgroups.

Again my apologies for any unintemded offense.

With best wishes

Bill

-- 
Bill Lyons - b...@lyons.demon.co.uk / w.ly...@ieee.org




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RE: SV: NRTL in the U.S.

[Tyra, John]

This is a multi-part message in MIME format.
Attached is an article from the Conformity 2002 Annual Guide titled  Know
When You Need To List Your Product And When You Don't written by John
Curtis of Curtis- Strauss LLC. It gives some great information. For those
who, rightfully, fear attachments, I ran this through a dedicated scanner
and our outgoing e-mails are virus scanned so I hope that gives you some
confidence as to the integrity of the attachment..Hope this
helps...

 


From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Friday, January 17, 2003 2:25 PM
To: emc-p...@majordomo.ieee.org
Subject: SV: SV: NRTL in the U.S.



I would never dare to declare U.S. compliance without testing and certify
via a NRTL. But what I am struggling with, is to gain knowledge about the
basic electrical safety laws in U.S. Maybe I do not need legally to go
through a NRTL, but that does not mean I would, even if I could.

The electrical safety legislation seems to be a bit more complicated in U.S.
compared to EU.

Best regards
Amund Westin, Oslo / Norway



 -Opprinnelig melding-
 Fra: owner-emc-p...@majordomo.ieee.org
 [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av John Woodgate
 Sendt: 17. januar 2003 13:25
 Til: emc-p...@majordomo.ieee.org
 Emne: Re: SV: NRTL in the U.S.



 I read in !emc-pstc that Amund Westin am...@westin-emission.no wrote
 (in lfenjlpmmjbmhpeibnilaeapckaa.am...@westin-emission.no) about 'SV:
 NRTL in the U.S.' on Fri, 17 Jan 2003:

 Just for a few seconds forget the customers requirements, is it
 therefore a
 correct interpretation that electrical equipment (ITE, household
 appliances,
 radio transmitters, etc) must be certified in order to follow
 the U.S. laws

 I think you really already had the strictly correct answer, but it's
 over-complicated.

 The practical answer is that it's much better to have certification than
 not to have it, unless the cost of certification would make your product
 uncompetitive against other, uncertified products in competition with
 yours.
 --
 Regards, John Woodgate, OOO - Own Opinions Only.
http://www.jmwa.demon.co.uk
Interested in professional sound reinforcement and distribution? Then go to
http://www.isce.org.uk
PLEASE do NOT copy news posts to me by E-MAIL!


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Click on browse and then emc-pstc mailing list



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Title: RE: SV: NRTL in the U.S.






Attached is an article from the Conformity 2002 Annual Guide titled  Know

When You Need To List Your Product And When You Don't written by John

Curtis of Curtis- Strauss LLC. It gives some great information. For those

who, rightfully, fear attachments, I ran this through a dedicated scanner

and our outgoing e-mails are virus scanned so I hope that gives you some

confidence as to the integrity of the attachment..Hope this

helps...





-Original Message-

From: Amund Westin [mailto:am...@westin-emission.no]

Sent: Friday, January 17, 2003 2:25 PM

To: emc-p...@majordomo.ieee.org

Subject: SV: SV: NRTL in the U.S.




I would never dare to declare U.S. compliance without testing and certify

via a NRTL. But what I am struggling with, is to gain knowledge about the

basic electrical safety laws in U.S. Maybe I do not need legally to go

through a NRTL, but that does not mean I would, even if I could.


The electrical safety legislation seems to be a bit more complicated in U.S.

compared to EU.


Best regards

Amund Westin, Oslo / Norway




 -Opprinnelig melding-

 Fra: owner-emc-p...@majordomo.ieee.org

 [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av John 

RE: SV: NRTL in the U.S.

[Tyra, John]

This is partially true in that while the there are some EU standards
harmonized with UL standards, they are not completely harmonized and you
still have to consider the U.S. National Deviations to be totally complaint
a good example is component approvals. The UL standard will usually require
a component to be compliant to a UL component standard while the IEC/EN
standards reference the IEC/EN component standards.

Another good example where this will kill you if you only consider the IEC/
EN requirements is for UL6500...The IEC/EN 60065 standard only requires a
fire enclosure to be rated 94-HB, in most cases, while the UL standard has a
U.S. deviation which requires 94-V2 plastic.so beware and check for all
National Deviations..


From: drcuthbert [mailto:drcuthb...@micron.com]
Sent: Friday, January 17, 2003 4:31 PM
To: 'Amund Westin'; emc-p...@majordomo.ieee.org
Subject: RE: SV: NRTL in the U.S.



Amund,

Several EU standards have been harmonized with the United States UL
standards. A list can be found at
http://ulstandardsinfonet.ul.com/catalog/stdscatframe.html

For example, UL 60950 the same as EN 60950. So, I'm thinking that if your
device meets EU safety requirements it will make it through UL as long it
has been designed to a harmonized standard. Does this sound reasonable to
anyone or am I off the mark?

  Dave Cuthbert


From: Amund Westin [mailto:am...@westin-emission.no]
Sent: Friday, January 17, 2003 12:25 PM
To: emc-p...@majordomo.ieee.org
Subject: SV: SV: NRTL in the U.S.



I would never dare to declare U.S. compliance without testing and certify
via a NRTL. But what I am struggling with, is to gain knowledge about the
basic electrical safety laws in U.S. Maybe I do not need legally to go
through a NRTL, but that does not mean I would, even if I could.

The electrical safety legislation seems to be a bit more complicated in U.S.
compared to EU.

Best regards
Amund Westin, Oslo / Norway



 -Opprinnelig melding-
 Fra: owner-emc-p...@majordomo.ieee.org
 [mailto:owner-emc-p...@majordomo.ieee.org]På vegne av John Woodgate
 Sendt: 17. januar 2003 13:25
 Til: emc-p...@majordomo.ieee.org
 Emne: Re: SV: NRTL in the U.S.



 I read in !emc-pstc that Amund Westin am...@westin-emission.no wrote
 (in lfenjlpmmjbmhpeibnilaeapckaa.am...@westin-emission.no) about 'SV:
 NRTL in the U.S.' on Fri, 17 Jan 2003:

 Just for a few seconds forget the customers requirements, is it
 therefore a
 correct interpretation that electrical equipment (ITE, household
 appliances,
 radio transmitters, etc) must be certified in order to follow
 the U.S. laws

 I think you really already had the strictly correct answer, but it's
 over-complicated.

 The practical answer is that it's much better to have certification than
 not to have it, unless the cost of certification would make your product
 uncompetitive against other, uncertified products in competition with
 yours.
 --
 Regards, John Woodgate, OOO - Own Opinions Only.
http://www.jmwa.demon.co.uk
Interested in professional sound reinforcement and distribution? Then go to
http://www.isce.org.uk
PLEASE do NOT copy news posts to me by E-MAIL!


This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

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http://ieeepstc.mindcruiser.com/
Click on browse and then emc-pstc mailing list



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 Dave 

RE: Saudi Arabian PC EMC/Safety Requirements

[Tyra, John]

This is a multi-part message in MIME format.
Hello Rod:
 
The Saudi Agency SASO has an office at Intertek in Boxborough MA.
 
Here is the contact info:
 
SASO ICCP
70 Codman Hill Road
Boxborough, MA 01719
p: 978-635-8651
f: 978-635-1620
 
The Managers name is Bill Bekdash and he probably can help you with the
regulations. We have dealt with him quite a bit for Audio equipment and have
SASO Approval for an increasing number of our products. Bill is a very
helpful person and has e-mailed us pdf copies of the regulations. He is the
road often so you will have to be persistent when trying to contact him.
 
Hope this helps..
 
regards,
 
John
 
 
 
 

From: Andre, Pierre-Marie [mailto:pierre-marie.an...@intel.com]
Sent: Wednesday, January 15, 2003 4:24 AM
To: Rod Munro; emc-p...@majordomo.ieee.org
Subject: RE: Saudi Arabian PC EMC/Safety Requirements



Here is the contact address that I have (source
http://www.mediabrains.com/client/telecomweb) :

 


Ministry of Post, Telegraph and Telephone 

 



Address:
Director General
Riyadh
2
SAUDI ARABIA 



Phone:
+966 1 452 2 333


Fax:
+966 1 450 4 382

 

Good luck

Pierre-Marie Andre
 


From: Rod Munro [mailto:rmu...@spectrumti.com] 
Sent: mercredi 15 janvier 2003 09:46
To: emc-p...@majordomo.ieee.org
Subject: Saudi Arabian PC EMC/Safety Requirements

 

Hello EMC-PSTC User Group,

I am looking for advice or web site recommendation to determine the EMC and
any Safety test requirements necessary to market Laptop PC's operating under
2 GHz in Saudi Arabia.  The device currently has been tested for: EN55022
Class B, EN55024, FCC Part 15 Class B, IEC 60950 Safety,  Part 68, CS03  for
a Modem and TBR-21 European Pre Approved.   Thank you for your time and
input, your advice will be appreciated.

Best Regards,

Rod Munro


image001.gif

RE: When CE doesn't pass

[Tyra, John]

For large systems which cannot logistically either fit into chambers or
would cost a small fortune to ship to a lab I believe you can have a
notified body do modified EMC on site. I know TUV Rheinland in Newtown CT
has a very nice Mobile EMC lab where they will come to your facility and do
testing and issue you a TCF certificate. Of course this cannot be done  if
your system can be tested in a chamber.. Certainly it cost more to have this
on site testing done but in the long run it saves a ton of money in shipping
alone!!.Go to TUV.com for more details..
 
 
 
 
-Original Message-
From: Leslie Bai [mailto:leslie_...@yahoo.com]
Sent: Friday, November 22, 2002 5:05 PM
To: EMC-PSTC
Subject: RE: When CE doesn't pass



It was about five years ago, I did an EMC job to meet the CE mark
requirement for a Semiconductor equipment manufacturer by the approach of
TCF (Technical Construction File). The whole system was real giant and there
was no way to bring the system to the lab fitting in the chamber. 


Many sub-systems were OEM parts and most of them had been CE marked.
However, during the site testing at customer's premises, a walky-talky made
the system shut-down. 


It was quite straight-forward to find the cause of the failure and that was
the CE marked UPS system. 


When we looked at the detail information of the CE Marked UPS system, it was
truely CE marked, however the test report shows that this UPS system is a
Class B device and that manufacturer declared CE compliance at Class B. 


Nobody was wrong, but the Semiconductor system must meet Class A
environment. The advice to the semicondutor equipment manufacturer was to
either fix the UPS immunity problem or change another UPS system. 


So CE marked - what does that mean? It is a manufacturer's self declaration.
As a result of this when you shop around for CE marked sub-systems or OEM
parts, make sure that CE mark is what you want. 


Regards, 


Leslie 



 




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RE: Question regarding something slightly unusual ...

[Tyra, John]

While a mouse cannot function by itself, as it  needs to be connected to
something, it is a complete product in the sense that it should comply with
the Safety and EMC standards and does not require any special safety related
install or usage instructions. It therefore is able to bear the GS
Mark...This is similar to a mains connected printer or monitor which cannot
function until connected to a driver device but may be compliant with the
LVD and EMC Directives and specified standards and therefore is eligible for
a GS MarkAgain I am going back
to my TUV days with this so things could have changed in the last two
years.I am new to the UL process but sounds like has a
different slant when it comes to what is considered a finished product and
what is a component.
 
 
 
 
-Original Message-
From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Wednesday, October 09, 2002 2:56 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: Question regarding something slightly unusual ... 


Well that process doesn't seem to work that well either. I have a mouse and
keyboard that both have a UL Recognition mark. The mouse has a GS mark and
the keyboard has a Bauart mark. Of course, the reason the keyboard has the
Bauart mark rather than the GS mark is that it does not comply with the GS
requirements for a German keyboard. But that does not explain the marks on
the mouse.
 
Richard Woods 
Sensormatic Electronics 
Tyco International 

-Original Message-
From: Clement Dave-LDC009 [mailto:dave.clem...@motorola.com]
Sent: Wednesday, October 09, 2002 1:00 PM
To: 'soundsu...@aol.com'; emc-p...@majordomo.ieee.org
Subject: RE: Question regarding something slightly unusual ... 


TUV does have a mechanism, they issues the GS mark for products and the
Bauart mark for components. 
 
Dave Clement 
Motorola Inc. 
Test Lab Services 
Homologation Engineering 
20 Cabot Blvd. 
Mansfield, MA 02048 

P:508-851-8259 
F:508-851-8512 
C:508-725-9689 
mailto:dave.clem...@motorola.com mailto:dave.clem...@motorola.com  
http://www.motorola.com/globalcompliance/
http://www.motorola.com/globalcompliance/  

-Original Message-
From: soundsu...@aol.com [mailto:soundsu...@aol.com]
Sent: Wednesday, October 09, 2002 12:43 PM
To: emc-p...@majordomo.ieee.org
Subject: Question regarding something slightly unusual ... 


From Doug McKean: 

In 20 years, I've never seen this before but that's not saying much.


Why would a mfr get a UL recognition approval for a commercial 
ITE style single phase 155-230vac computer style product but for 
that same product get the TUV GS mark?  

Mfr is a stateside company. 

Product to be used in restricted areas with trained personnel only. 
But, one that essentially anyone could buy. 

What's the advantage of getting such a mixed set of approvals? 
 

It's not really a mixed set of approvals.  UL must have considered the
device to be incomplete in some way (does it have an enclosure?), therefore
they Recognized it as a component as opposed to Listing it as a finished
product.  The GS Mark has no mechanism for delineating between components
and finished products - both can receive GS approval.  Hence the TUV GS
mark.  

That's my guess, based on the limited information you gave. 

Greg Galluccio
www.productapprovals.com 


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RE: Question regarding something slightly unusual ...

[Tyra, John]

Greg Galluccio wrote:

 The GS Mark has no mechanism for delineating between components and
finished products - both can receive GS approval.  Hence the TUV GS mark.  
 
Unless something has changed in the in the last two years, when I was
employed at TUV,   this is actually not quite correct. The GS Mark is only
for finished ready to use products which do not require any special
installation considerations to make them safe. It cannot be issued for
incomplete unfinished products which require an enclosure, for instance, to
make them  compliant with the standards. For components TUV would issue the
Bauart Mark which is  their equivalent to the UL recognition mark.A Bauart
Mark usually contains conditions of acceptability such as special
installation considerations while it was not allowed to have conditions of
acceptability on a GS License. If I remember correctly Bauart Mark
and is not regulated by the German Government as the GS Mark is

 
 
 -Original Message-
From: soundsu...@aol.com [mailto:soundsu...@aol.com]
Sent: Wednesday, October 09, 2002 12:43 PM
To: emc-p...@majordomo.ieee.org
Subject: Question regarding something slightly unusual ... 


From Doug McKean: 

In 20 years, I've never seen this before but that's not saying much.


Why would a mfr get a UL recognition approval for a commercial 
ITE style single phase 155-230vac computer style product but for 
that same product get the TUV GS mark?  

Mfr is a stateside company. 

Product to be used in restricted areas with trained personnel only. 
But, one that essentially anyone could buy. 

What's the advantage of getting such a mixed set of approvals? 
 

It's not really a mixed set of approvals.  UL must have considered the
device to be incomplete in some way (does it have an enclosure?), therefore
they Recognized it as a component as opposed to Listing it as a finished
product.  The GS Mark has no mechanism for delineating between components
and finished products - both can receive GS approval.  Hence the TUV GS
mark.  

That's my guess, based on the limited information you gave. 

Greg Galluccio
www.productapprovals.com 

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RE: CE Marking for Passive speakers

[Tyra, John]

Gee thanks John, wonder why I didn't think of
that?

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Monday, September 23, 2002 12:31 PM
To: emc-p...@majordomo.ieee.org
Subject: Re: CE Marking for Passive speakers



I read in !emc-pstc that Tyra, John john_t...@bose.com wrote (in
418fbd441c22d5118d860003470d43160543e...@cupid.bose.com) about 'CE
Marking for Passive speakers' on Mon, 23 Sep 2002:
Still cost money! Every page you print has a cost associated with it even
if
it is in the already existing instruction booklet..It may only be a
fraction
of a cent but it adds up fast!

Include it as part of an existing printed page. If your printer charges
you extra for that, get another printer.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk

Interested in professional sound reinforcement and distribution? Then go to 
http://www.isce.org.uk
PLEASE do NOT copy news posts to me by E-MAIL!

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RE: EN60065 mains switches

[Tyra, John]

Here is another issue where you will get conflicting opinions but I believe
that just because it is notified in the OJ does not mean every country
will adopt it at the same time. You need to be careful as there are some
countries still working with the 5th edition so if you have a CB certificate
and report done by a NCB it may not be accepted in a country which has not
adopted that particular version of the standard..This is
a particular concern with countries outside the EU, i.e. AsiaAny other
opinions?

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Wednesday, September 18, 2002 4:49 PM
To: emc-p...@majordomo.ieee.org
Subject: Re: EN60065 mains switches



I read in !emc-pstc that Tyra, John john_t...@bose.com wrote (in
418fbd441c22d5118d860003470d43160543e...@cupid.bose.com) about
'EN60065 mains switches' on Wed, 18 Sep 2002:

Also be aware that the published 7th edition of IEC60065 eliminates the
need
for a switch which is in line with the current edition of UL6500.
Unfortunately it will probably be several years before all the countries
adopt this edition of the standard

It is already adopted as EN 60065:2002. If it hasn't already been
'notified' in the Official Journal, it soon will be.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk

Interested in professional sound reinforcement and distribution? Then go to 
http://www.isce.org.uk
PLEASE do NOT copy news posts to me by E-MAIL!

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RE: CE Marking for Passive speakers

[Tyra, John]

I wish to thank everyone for taking the time to consider my questions. There
were a many good points brought up and it gave me some new issues to
consider, i.e. immunity testing for intense. As I expected the opinion was
split and I have to admit that I am still not convinced that CE Marking is
required for these type of products. In order to avoid the possibility of
being questioned upon import into the EU I am going to recommend that we CE
Mark our products until told otherwise and continue to pursue further
clarification from the authorities. I will be happy to share any info I
receive.

John, the added cost in our case is the fact that we include a copy of the
DoC with every product. Not required I know but done here as a matter of
policy this adds a couple of pennies to each product which adds up in the
long run.

Best regards,

John

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Thursday, September 19, 2002 7:04 AM
To: emc-p...@majordomo.ieee.org
Subject: Re: CE Marking for Passive speakers



I read in !emc-pstc that Gordon,Ian ian.gor...@edwards.boc.com wrote
(in E1BA0362B28ED211A1E80008C71EA306018190AE@EXC_EAS01) about 'CE
Marking for Passive speakers' on Thu, 19 Sep 2002:
By the wider issue I was referring to your assertion that The EMC
Guidelines document explains that having no active components is NOT
grounds
for exemption from the EMC Directive.
If this were the case then it would have far reaching implications for many
industries since all Electromagnetically Benign equipment might require
testing.
Furthermore I imagine this would have legal implications for the UK
Government appointed Competent Body which advised my company that benign
equipment is exempt. This Competent Body helped us compile a list of
products within our range to which this exclusion applied. 

'Benign' is NOT the same as 'passive', which is what was asserted. A
torch/flashlight with an incandescent lamp is benign, because it is
inconceivable that it would either emit anything or suffer from lack of
immunity. But even just a *junction box* for high-speed data cable can
both emit stuff and let external disturbances into the cabling. 

I showed how a loudspeaker can both emit and be disturbed by and
external emission. 
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk

Interested in professional sound reinforcement and distribution? Then go to 
http://www.isce.org.uk
PLEASE do NOT copy news posts to me by E-MAIL!

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RE: EN60065 mains switches

[Tyra, John]

Hello Chris,

We are going through the same issue here at Bose...A while back we received
a ruling that this type of design did meet the intent of the standard from
TUV and UL. CSA was a little more stringent in their interpretation.

Based on my correspondence with CSA here is my take:

1. You do not need a switch if your product is switched off automatically
either by a timer function or by an external signal provided your amp
outputs are actually switched off and the product is not simply in standby
mode.
2. Your product must not consume more then 15W when in the off mode (see the
CSA excerpt below) under normal conditions and after a single fault
condition. So if you use a single semiconductor to switch off your amp you
would not meet the intent of the standard if your product draws more than
15W with the semiconductor shorted. This point is also clarified in the
IEC60065 6th CENELEC OSM decisions from 7/2001 in sub-clause 14.6.2. 

Here is a short excerpt concerning IEC60065 sub-clause 14.6.2 I got from CSA
on this issue:

Irrespective of their power consumption means power consumption in the
ON mode. If there is no manual OFF switch, it is permitted to have the
product switched OFF automatically using a signal.
Mute is not really OFF, but a STANDBY mode.   The intent of the standard
is reduce fire hazard by disconnecting the supply voltage from the circuitry
in the OFF mode.   Mute with Supply Voltage still connected to the output
stage does not really satisfy this intent.

Some other designs have used electronic switching of the MAINS or Secondary
Supply to satisfy the OFF condition. Even if AUTOMATICALLY SWITCHED, the
second paragraph of 14.6.2 applies to the OFF condition.(Less than 15W with
single fault)

Contact me if you want a copy of the OSM decisions. Please note that these
decisions are only guidelines which were agreed upon by the various CENELC
member Notified Bodies and do not legally change the Standard. I have no
verification that these decisions would be accepted outside the EU, i.e. in
Asia...etc...

Also be aware that the published 7th edition of IEC60065 eliminates the need
for a switch which is in line with the current edition of UL6500.
Unfortunately it will probably be several years before all the countries
adopt this edition of the standard

Hope this helps as this is a tricky area to interpret

regards,

John Tyra
Design Assurance Engineering,
Product Safety  Regulatory Manager

Bose Corporation
The Mountain, M.S.-450
Framingham, MA 01701-9168
508-766-1502 Phone
508-766-1145 Fax
john_t...@bose.com 


-Original Message-
From: Colgan, Chris [mailto:chris.col...@tagmclaren.com]
Sent: Wednesday, September 18, 2002 4:48 AM
To: 'Emc-Pstc' (E-mail)
Subject: EN60065 mains switches



Hello

I know that engineers familiar with EN60065 are rarer than hen's teeth but
maybe someone out there can help me...

Clause 14.6.2 allows for no mains switch to be fitted if the product can be
switched on or off or both automatically.  Do you think that an audio
amplifier that utilises an input signal detect circuit to automatically
switch on fulfils the requirements of this clause?

Thanks for any input

Chris Colgan
Compliance Engineer
TAG McLaren Audio Ltd
The Summit, Latham Road
Huntingdon, Cambs, PE29 6ZU
*Tel: +44 (0)1480 415 627
*Fax: +44 (0)1480 52159
* Mailto:chris.col...@tagmclaren.com
* http://www.tagmclaren.com



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CE Marking for Passive speakers

[Tyra, John]

Hello everyone,

I was wondering if anyone out there can provide me with help in determining
whether passive speakers and headphones are required to be CE-Marked for
entry into the EU?

We have an old document from BAPT in Germany which implies that passive
speakers are required to be CE Marked but this does not seem to make sense
to me since there are no active components in the products and we would be
declaring compliance by default. I have the same concern for Headphones. 

Also does anyone have a good contact person in the EU possibly with the
European Commission they could share I would like to try to get some kind of
official ruling on this issue.

While it would be simple to CE-Mark our passive speaker products there are
costs involved so I would prefer not to do it if it is not required.

Thanks in advance for any help you can provide.

Best regards,

John

John Tyra
Design Assurance Engineering,
Product Safety  Regulatory Manager

Bose Corporation
The Mountain, M.S.-450
Framingham, MA 01701-9168
508-766-1502 Phone
508-766-1145 Fax
john_t...@bose.com


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RE: Acousic Noise from ITE

[Tyra, John]

Richard,

I would contact Steven Kraemer @ TUV Rheinland in the Toronto office. He is
very knowledgeable in the area of Noise requirements in the EU.

regards,

John

-Original Message-
From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Monday, September 16, 2002 11:44 AM
To: emc-p...@majordomo.ieee.org
Subject: Acousic Noise from ITE



Are there any EU or national (e.g. GS) normative requirements to comply with
any of the following standards or any other acoustic standards for ITE?

 EN27779 Acoustic measurement of airborn noise emitted by computer and
 business equipment.
 EN29295 Acoustic measurement of high frequency noise emitted by computer
 and business equipment.
 ISO 9296 Acoustics declared noise emission values of emitted by computer
 and business equipment.
 
 
Richard Woods
Sensormatic Electronics
Tyco International


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RE: electric strength test

[Tyra, John]

I agree with Peter, per the standard, and most IEC product standards, you
need two levels of protection from electric shock. In your case the y-caps
provide one level (basic insulation) and the earth connection provides the
second. As long as your earth path, between primary and secondary (I am
assuming your secondary is connected or coupled to earth), will pass the
Earth continuity test then it is unreasonable for the agency engineer to
enforce reinforced dielectric requirements on the basic insulation Y-caps
and you should be allowed to lift them during the test. You need to politely
ask him to check with his superior on this one!

I have not worked with 950 in many years now but I do remember that the
Nordic agencies were requiring reinforced spacing and insulation between
primary and earth for the reasons Peter cited. If you plan on selling in
this region you should check all of the National deviations and maybe
contact DEMKO (part of UL now) to see if this is still required for the
Nordic countries

-Original Message-
From: Peter Merguerian [mailto:pmerguer...@itl.co.il]
Sent: Thursday, August 22, 2002 1:09 PM
To: 'Brian O'Connell'; emc-p...@majordomo.ieee.org
Subject: RE: electric strength test



Brian,

Your interpretation of the standard and application of the test between
pri-sec is acceptable. You need to speak to a higher level person in the
agency who is an expert!

Please be advised that some countries do not have a reliable earthing
system. Many end-product manufacturers design their equipment such that the
power supply has double insulation or reinforced insulation between
pri-earth. Norway is a good example. 
You may come across some distributors in Norway asking for DI or RI between
pri-sec, even for Class 1 power supplies.

Good luck at the agency!

This e-mail message may contain privileged or confidential information. If
you are not the intended recipient, you may not disclose, use, disseminate,
distribute, copy or rely upon this message or attachment in any way. If you
received this e-mail message in error, please return by forwarding the
message and its attachments to the sender.



PETER S. MERGUERIAN
Technical Director
I.T.L. (Product Testing) Ltd.
26 Hacharoshet St., POB 211
Or Yehuda 60251, Israel
Tel: + 972-(0)3-5339022  Fax: + 972-(0)3-5339019
Mobile: + 972-(0)54-838175
http://www.itl.co.il
http://www.i-spec.com





-Original Message-
From: Brian O'Connell [mailto:boconn...@t-yuden.com]
Sent: Thursday, August 22, 2002 3:57 PM
To: emc-p...@majordomo.ieee.org
Subject: electric strength test



Good People of PSTC:

I am attempting to comply with both the letter and spirit of 60950:2000, cl
5.2. Note that 5.2.2 allows for separate testing, according the type of
insulation required. When testing a (class 1) power supply, the withstand
level for primary to chassis is Basic; and for primary to secondary is
Reinforced. Typically, I will apply approx 2500vdc for Basic and 4300vdc for
reinforced. But to pass primary to secondary test, 60950 says that I can
allow for following: 

care is taken that the voltage applied to the reinforced insulation does
not overstress basic 

Also

to avoid damage to components or insulation which are not involved in the
test, disconnection of ICs or the like and the use of equipotential bonding
are permitted.

For Pri/Sec testing, the screw connecting the Y-caps to the chassis is
removed, insulation is inserted between the screw insert and chassis.

A (new) agency engineer says that inserting a piece of insulator defeats the
purpose of the test. For class 1 construction, it is just not possible for
me to pass 4300vdc test levels without inserting my little piece of valox,
unless I physically remove all Y-caps (and the unit will not operate
reliably with y-caps). I have inspected units from several other companies
and have determined that it was not possible to have ever passed pri-sec
test levels without isolating these circuits.

What test technique generally accepted by your agency engineers? TIA.

R/S,
Brian O'Connell
Taiyo Yuden (USA), Inc.


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RE: Are There Any Standards that Apply to Digital Cameras

[Tyra, John]

Hello Oscar,

FYI The 6th ed of IEC60065 does not include battery powered product in the
scope but the recently published 7th 2001 ed does now include battery
powered product...I would stick with the 6th edition as the 7th has not
been adopted by many countries yet.I agree with Sam in that if your
product connects to a mains connected battery charger then IEC60065 would
definitely apply Even if the product does not use a charger and if there
are no specific standards for battery powered digital cameras (don't believe
there are) you can still use IEC60065 6th ed as it is not excluded in the
scope.


I would still want to verify safety compliance of my product if I were you.
As far as I remember if your product is less than 75Vdc, as outlined in
Article 1, your product should not have to legally comply with the LVD in
any case and you should be able to legally mark your product based solely on
compliance with the EMC Directive.I'd be interested in
any information anyone has to the contrary on this subject.

regards,

John

-Original Message-
From: Sam Davis [mailto:sda...@ptitest.com]
Sent: Thursday, August 08, 2002 2:29 PM
To: oover...@lexmark.com
Cc: Emc-Pstc
Subject: RE: Are There Any Standards that Apply to Digital Cameras



UL 6500 - Audio/Video and Musical Apparatus for Household, Commercial, and
Similar Use.

IEC 60065 - Audio, Video, and Similar electronic Apparatus - Safety
Requirements.
The UL Standard is based on this, with of course, deviations.  I don't have
a copy of it at my desk, so I cannot verify that battery-operated audio and
video products are listed in the scope, as they are in the UL Standard.

If the IEC Standard does not specify battery-operated, but still has the
line designed to be fed from the mains or from a SUPLY APPARATUS, supply
apparatus being defined as apparatus which takes power from the mains and
from which one or more other apparatus are fed, then the camera, if it has
a power supply adapter, would fall into the scope.

-Original Message-
From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of
oover...@lexmark.com
Sent: Thursday, August 08, 2002 7:17 AM
To: emc-p...@majordomo.ieee.org
Subject: Are There Any Standards that Apply to Digital Cameras





Everyone,

Does anyone know of any product safety standards that apply to digital
cameras?
The simple, personal, AA battery powered type of digital cameras.

Thank you.

Oscar Overton
Ph: 859-232-2284





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RE: Online Standards EN61010-1

[Tyra, John]

Hello Doug,

Bose buys many of our standards from ILI in Great Britain (I believe)
http://www.ili-info.com/us/ and we have received some in electronic format.
These sites also seems to offer standards in PDF form and also gives you a
simple free search engine to help you identify and find standards for your
application which is helpful  http://www.cssinfo.com/perinorm.html and
http://www.techstreet.com/  Hope this is helpful.

regards,

John Tyra
Design Assurance Engineering,
Product Safety  Regulatory Manager

Bose Corporation
The Mountain, M.S.-450
Framingham, MA 01701-9168
508-766-1502 Phone
508-766-1145 Fax
john_t...@bose.com



-Original Message-
From: POWELL, DOUG [mailto:doug.pow...@aei.com]
Sent: Wednesday, August 07, 2002 1:15 PM
To: EMC-PSTC (E-mail)
Subject: Online Standards EN61010-1



Hello all,

I have been searching for a document service that has electronic format
standards (PDF) for EN61010-1:2001 with fully functional text search.  IHS
Global and TechStreet have hardcopy only.  BSI offers electronic but it's
only a converted TIFF format.  I thought about using the IEC but I am not
sure if there are any national deviations in the European Norm.

Any help you can provide is appreciated.


-doug

---
Douglas E. Powell, Compliance Engineer
Advanced Energy Industries, Inc.
Ft. Collins, CO 80525
mailto:doug.pow...@aei.com
---




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strictly prohibited without the express written consent of 
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RE: Suffocation hazard

[Tyra, John]

Hello Nick,

Yes I would like to take you up on your kind offer. Please e-mail to my
address. I am particularly interested in the perforations you recommend.

I have found that California does have regulations as part of their BUSINESS
AND PROFESSIONS CODE. Here is a link:

http://www.leginfo.ca.gov/cgi-bin/displaycode?section=bpcgroup=22001-23000;
file=22200-22205

They require a warning statement if a bag is less than 0.001 inches
(0.0254mm) thick. I also received information from the U.S. Consumer Product
Safety Commission which informed me that there are no Federal Regulations on
this subject.

I am still researching and will be happy to share my future findings.

Best regards,

John


-Original Message-
From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: Tuesday, July 30, 2002 3:50 PM
To: Tyra, John
Cc: emc-p...@ieee.org
Subject: Re: Suffocation hazard



I've looked into this in the past, and there appears to be no 
legislation. There is a guide to appropriate wording in BS 1133 
section 21:1991 but, frankly, this falls far short of a useable 
specification for safety markings on bags. Most retailers also want 
to see perforations, and some specify a minimum thickness for film 
used for bags for toys and child appealing products.

In the end we drafted our own spec. based on our experience with 
major UK retailers and I'd be happy to mail you a copy (PDF, 20kb) if 
you'd like.

Rgds

Nick.




At 12:41 -0400 30/7/02, Tyra, John wrote:
Hello all,

I am in the process of reviewing the plastic bags we use to package our
products and have a old 100th generation copy of an excerpt from a
California Business and Professions Code which implies that plastic bags
less than a mil thick need to have a warning marking.

Does anyone have more info on this issue or know of any other regulations
concerning plastic bag regulations?

Thanks in advance for your help...

regards,

John Tyra
Design Assurance Engineering,
Product Safety  Regulatory Manager

Bose Corporation
The Mountain, M.S.-450
Framingham, MA 01701-9168
508-766-1502 Phone
508-766-1145 Fax
john_t...@bose.com


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Suffocation hazard

[Tyra, John]

Hello all,

I am in the process of reviewing the plastic bags we use to package our
products and have a old 100th generation copy of an excerpt from a
California Business and Professions Code which implies that plastic bags
less than a mil thick need to have a warning marking.

Does anyone have more info on this issue or know of any other regulations
concerning plastic bag regulations?

Thanks in advance for your help...

regards,

John Tyra
Design Assurance Engineering,
Product Safety  Regulatory Manager

Bose Corporation
The Mountain, M.S.-450
Framingham, MA 01701-9168
508-766-1502 Phone
508-766-1145 Fax
john_t...@bose.com


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RE: Regulatory requirements for Taiwan

[Tyra, John]

Just noticed, and others have pointed out, that I have Taiwan in the subject
field and Thailand in the body of the e-mail... I am interested in the new
Thailand certification requirements...Taiwan has had mandatory requirements
in place for a while now but that is another story! Sorry for the
confusion..

 -Original Message-
 From: Tyra, John 
 Sent: Wednesday, July 24, 2002 2:29 PM
 To:   emc-p...@majordomo.ieee.org
 Subject:  Regulatory requirements for Taiwan
 
 Hello Everyone,
 
 I just received an e-mail from our distributor in Thailand that starting
 August 31st our home audio product are subject to a new certification
 scheme which will require test verification and licensing in order to be
 imported into the country.
 
 Does anyone have any additional information regarding the new requirements
 for Thailand or can point me in the direction as to  where I can
 additional info.
 
 Thanks for your help.
 
 regards,
 
 John Tyra
 Design Assurance Engineering,
 Product Safety  Regulatory Manager
 
 Bose Corporation
 The Mountain, M.S.-450
 Framingham, MA 01701-9168
 508-766-1502 Phone
 508-766-1145 Fax
 john_t...@bose.com
 

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Regulatory requirements for Taiwan

[Tyra, John]

Hello Everyone,

I just received an e-mail from our distributor in Thailand that starting
August 31st our home audio product are subject to a new certification scheme
which will require test verification and licensing in order to be imported
into the country.

Does anyone have any additional information regarding the new requirements
for Thailand or can point me in the direction as to  where I can additional
info.

Thanks for your help.

regards,

John Tyra
Design Assurance Engineering,
Product Safety  Regulatory Manager

Bose Corporation
The Mountain, M.S.-450
Framingham, MA 01701-9168
508-766-1502 Phone
508-766-1145 Fax
john_t...@bose.com


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Formaldehyde requirements for Europe

[Tyra, John]

Hello Everyone,

I am new to the list and was hoping that someone could help me with the
following question. I have been tasked with researching  Formaldehyde out
gasssing regulations for products utilizing composite ( particle board)
material. Our speaker cabinets utilize this material.

I have recently received some information concerning German regulations
which seems to indicate that our speakers must be subjected to testing by a
recognized authority in Germany.

Does anyone have any information on this subject or have any sources they
can direct me too?

I am happy to share the limited info I have so if you are interested please
e-mail me privately.

Thanks in advance for your help.

regards,


John Tyra
Design Assurance Engineering,
Product Safety  Regulatory Manager

Bose Corporation
The Mountain, M.S.-450
Framingham, MA 01701-9168
508-766-1502 Phone
508-766-1145 Fax
john_t...@bose.com


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