RE: Add-On Printed Circuit

2002-09-17 Thread Peter Merguerian

Warren,

John stated that Products A and B are sold independent of each other. Only
product A has Listing Marks and is the one that gets inspected by the
Follow-Up inspector. Follow-up inspector never sees Product B unless he's
very smart and gathers from the Product A's manual that it is an optional
board. Remember that follow-up inspectors are taught to inspect only
products that have the NRTL mark.

However, the problem is in the field. Someone who opens up Product A in the
field and adds a non-Listed accessory board has violated the Listing Mark on
that product.

Product A's Listing is not valid unless the NRTL has evaluated the
combination of Product A and Product B together and has covered both under
their Listing program. 

Some examples of products that are accessory Listed are: optional cards that
can be fitted on the equipment; optional fan tray, optional mouse, etc.




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: Warren Birmingham [mailto:war...@comfortjets.com]
Sent: Monday, September 16, 2002 10:21 PM
To: John Juhasz
Cc: emc-p...@ieee.org
Subject: Re: Add-On Printed Circuit



You don't say to which standard UL has investigated the Product A 
device or whether is is a listed product or a Recognized Component.

The listed product A must conform to the was it was built by the 
manufacturer.  Changes/options to it must be shown in the Followup 
Services Books, otherwise the product is not covered and UL may force 
the shipments to be held for conformance or the listing mark removed.

RCs are evaluated for use in the end product according to UL's 
conditions.

Warren Birmingham
Epsilon-Mu Consultants

On Monday, Sep 16, 2002, at 08:25 US/Pacific, John Juhasz wrote:


 Colleagues,

 I am seeking your input.

 Manufacturer A sells a complete, fully approved  (CE, FCC Part 15, UL, 
 etc)
 product (product A)
 Manufacturer B makes a device (product B) that will plug into a 
 connector in
 product A
 (actually inside product A's enclosure - like a 'daughter' module) as a
 value added feature.
 There are no external interfaces on product B, and it is not accessible
 unless product A is totally dismantled. Product B is intended/sold 
 only for
 use with product A,
 and is otherwise useless.
 The two products are sold independent of each other by the 
 manufacturers to
 'dealer/installers'.
 When the dealer/installer sells/installs product A, he can offer 
 product B
 as an option.

 What are the regulatory requirements/manufacturer's responsibilities 
 for
 product B?
 (est. 2-3 inches square, UL 94V-0 printed circuit board, tens of mA 
 12V DC,
 no external interfaces.
 On-board clock).

 Thoughts?

 John A. Juhasz

 GE Interlogix
 Fiber Options Div.
 Bohemia, NY


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RE: Add-On Printed Circuit

2002-09-17 Thread Peter Merguerian

John,

Since product B is an accessory for use with UL Listed Product A, then I
would submit product B to UL for accessory Listing for use with Product A.
This is a very wise thing to do, especially if there were any questions by
local inspectors or by the judge in case of a product liabilility lawsuit. 

Accessory Listing product B should be no problem at all. UL might ask you to
throw in an instruction leaflet on how to install accessory B properly and
that this must be done by qualified personnel. 

In regards to the UL Listing Mark, it is the same as the one you have on the
product A except for the element ACCESSORY LISTED instead of LISTED adjacent
to the UL logo. Being a small unit, UL also allows you to put all the
required markings and UL logo on the packaging rather than on the product.


Regards,


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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: John Juhasz [mailto:john.juh...@ge-interlogix.com]
Sent: Monday, September 16, 2002 5:25 PM
To: 'emc-p...@ieee.org'
Subject: Add-On Printed Circuit



Colleagues,

I am seeking your input.

Manufacturer A sells a complete, fully approved  (CE, FCC Part 15, UL, etc)
product (product A)
Manufacturer B makes a device (product B) that will plug into a connector in
product A
(actually inside product A's enclosure - like a 'daughter' module) as a
value added feature. 
There are no external interfaces on product B, and it is not accessible
unless product A is totally dismantled. Product B is intended/sold only for
use with product A,
and is otherwise useless.
The two products are sold independent of each other by the manufacturers to
'dealer/installers'. 
When the dealer/installer sells/installs product A, he can offer product B
as an option.

What are the regulatory requirements/manufacturer's responsibilities for
product B?
(est. 2-3 inches square, UL 94V-0 printed circuit board, tens of mA 12V DC,
no external interfaces.
On-board clock). 

Thoughts?

John A. Juhasz

GE Interlogix
Fiber Options Div.
Bohemia, NY 


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Re: Add-On Printed Circuit

2002-09-16 Thread Warren Birmingham


You don't say to which standard UL has investigated the Product A 
device or whether is is a listed product or a Recognized Component.


The listed product A must conform to the was it was built by the 
manufacturer.  Changes/options to it must be shown in the Followup 
Services Books, otherwise the product is not covered and UL may force 
the shipments to be held for conformance or the listing mark removed.


RCs are evaluated for use in the end product according to UL's 
conditions.


Warren Birmingham
Epsilon-Mu Consultants

On Monday, Sep 16, 2002, at 08:25 US/Pacific, John Juhasz wrote:



Colleagues,

I am seeking your input.

Manufacturer A sells a complete, fully approved  (CE, FCC Part 15, UL, 
etc)

product (product A)
Manufacturer B makes a device (product B) that will plug into a 
connector in

product A
(actually inside product A's enclosure - like a 'daughter' module) as a
value added feature.
There are no external interfaces on product B, and it is not accessible
unless product A is totally dismantled. Product B is intended/sold 
only for

use with product A,
and is otherwise useless.
The two products are sold independent of each other by the 
manufacturers to

'dealer/installers'.
When the dealer/installer sells/installs product A, he can offer 
product B

as an option.

What are the regulatory requirements/manufacturer's responsibilities 
for

product B?
(est. 2-3 inches square, UL 94V-0 printed circuit board, tens of mA 
12V DC,

no external interfaces.
On-board clock).

Thoughts?

John A. Juhasz

GE Interlogix
Fiber Options Div.
Bohemia, NY


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Re: Add-On Printed Circuit

2002-09-16 Thread John Woodgate

I read in !emc-pstc that John Juhasz john.juh...@ge-interlogix.com
wrote (in 2a1845f4cde8d511b4400090279c703bfb6...@bctexc10.ilx.indsys.ge
.com) about 'Add-On Printed Circuit' on Mon, 16 Sep 2002:
What are the regulatory requirements/manufacturer's responsibilities for
product B?
(est. 2-3 inches square, UL 94V-0 printed circuit board, tens of mA 12V DC,
no external interfaces.
On-board clock). 

For Europe, the complete product, A+B, must meet the applicable safety
and EMC requirements. Since B is not exposed for retail sale, it does
not have to be CE marked, but it is not illegal to do so. 

The Declaration of Conformity for B must (if you want a quite life!)
explain what you explained, about it being embodied in A and ONLY in A. 
-- 
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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Add-On Printed Circuit

2002-09-16 Thread John Juhasz

Colleagues,

I am seeking your input.

Manufacturer A sells a complete, fully approved  (CE, FCC Part 15, UL, etc)
product (product A)
Manufacturer B makes a device (product B) that will plug into a connector in
product A
(actually inside product A's enclosure - like a 'daughter' module) as a
value added feature. 
There are no external interfaces on product B, and it is not accessible
unless product A is totally dismantled. Product B is intended/sold only for
use with product A,
and is otherwise useless.
The two products are sold independent of each other by the manufacturers to
'dealer/installers'. 
When the dealer/installer sells/installs product A, he can offer product B
as an option.

What are the regulatory requirements/manufacturer's responsibilities for
product B?
(est. 2-3 inches square, UL 94V-0 printed circuit board, tens of mA 12V DC,
no external interfaces.
On-board clock). 

Thoughts?

John A. Juhasz

GE Interlogix
Fiber Options Div.
Bohemia, NY 


---
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 Jim Bacher: j.bac...@ieee.org

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