Re: CE-mark compliance

2001-11-16 Thread info

John

We often come across large systems or machines where we ask the
manufacturer for certification details for the components, they sometimes
are unable to get much information from their suppliers, a common example
is for transformers where it is unlikely that they have been tested, except
as an end of line production test and are only supplied with a DOC.  We do
not accept these but are always asked.

I am sorry to hear that you are leaving this forum.  My feeling is that
your input was extremely useful and it will be missed (where do you get the
time to do the research, or is it all in your head).  It is particularly
useful to have somebody on standards committees to show us all how it
works.

Regards

Glenn Moffat
TUV International UK
Tel: +44 121 634 8000
Fax: +44 121 634 8080

I read in !emc-pstc that i...@uk.tuv.com wrote (in OF47447D6C.F0A6BF4C-
on80256b05.00425...@jpn.tuv.com) about 'CE-mark compliance', on Thu, 15
Nov 2001:
 Test houses generally do
not accept a Declaration of Conformity for any product unless further
proof
is available in the form of acceptable test results (from a 3rd party
laboratory or approved in-house laboratory).

There is normally no reason for a test house to be asked to 'accept' a
DOC, unless the manufacturer commissions it to use the DOC to support a
claim of conformity to some other requirements, such as Australian.
--
Regards, John Woodgate, OOO - Own Opinions Only.
http://www.jmwa.demon.co.uk
Eat mink and be dreary!


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Re: CE-mark compliance

2001-11-15 Thread John Woodgate

I read in !emc-pstc that i...@uk.tuv.com wrote (in OF47447D6C.F0A6BF4C-
on80256b05.00425...@jpn.tuv.com) about 'CE-mark compliance', on Thu, 15
Nov 2001:
 Test houses generally do
not accept a Declaration of Conformity for any product unless further proof
is available in the form of acceptable test results (from a 3rd party
laboratory or approved in-house laboratory).  

There is normally no reason for a test house to be asked to 'accept' a
DOC, unless the manufacturer commissions it to use the DOC to support a
claim of conformity to some other requirements, such as Australian.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk 
Eat mink and be dreary!

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Re: CE-mark compliance

2001-11-15 Thread info

Look in the archives of this discussion forum and you will see instances of
occassions where no testing has been conducted.  Test houses generally do
not accept a Declaration of Conformity for any product unless further proof
is available in the form of acceptable test results (from a 3rd party
laboratory or approved in-house laboratory).  This is not because they want
more testing and more money but because it is well known that the CE
marking process is abused by a large number of companies to different
degrees.  It is not uncommon for products to have a CE label attached but
no documentation at all and these products are frequently found to be
unsafe or to not comply with the EMC Directive.  Some companies do the
minimum possible i.e. make a quick assessment (not necessarily by a
knowledgable person) and write a Declaration of conformity, other companies
will do more in house testing, for example, hi-pot, leakage current and
earth bond.  Some companies employ safety engineers to perform testing and
others use external test houses.  For EMC it is more likely that nothing
has been done as a large number of companies know that they will only get
caught if their equipment is causing serious interference.

There is a sliding scale of testing that companies do, at one end nothing
is done, costs are low and risks are high, at the other end full third
party testing is conducted therefore costs are high but risks are low.  It
is up to buyers to decide where they want their end product to lie on that
scale and to buy from companies that are at a similar position or better.
They should request documentation to ensure that the equipment is suitably
assessed to that level of risk.

Some years ago before most of us knew what EMC meant, I came across a
company that did not employ a safety engineer and did not use a test lab at
all since it was cheaper to employ a lawyer with the knowledge to get them
off any charges if their equipment was found to be unsafe!

My advice, decide on your level of risk and choose your suppliers
carefully.

Glenn Moffat
TUV International UK
Tel: +44 121 634 8000
Fax: +44 121 634 8080

Hi all,

Do all manufactures fulfill the EU-directives with testing in their own
facilities or by an independent test lab? I guess the answer must be No.

From my time working in a test lab, my experience is that big companies
like
Alcatel, Siemens and so on, do the required testing according to relevant
requirements. I also got the feeling that small companies (I do not
generalize) where a bit laid-back and often put the CE-mark into the
products without any tests or with a very limited test process.

Should a system builder trust a Declaration of Conformity from a big
manufacturer, without asking for test reports in order to verify compliance
with relevant directives ? Would you sleep well at night,  if you only
trusted the CE-mark 100% and build a large broadband telecom system only
based on the CE-mark without any further documentation?

What is your opinion?

Best regards
Amund Westin, Oslo/Norway


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Re: CE-mark compliance

2001-11-14 Thread Jacob Schanker

Amund:

In answer to your question, I would cite the words of President
Ronald Reagan, quoting Chairman Gorbachev, quoting V.I. Lenin:

Doveryay, no proveryay. -  Trust, but verify.

Regards,

Jack

Jacob Z. Schanker, P.E.
65 Crandon Way
Rochester, NY 14618
Phone: 716 442 3909
Fax: 716 442 2182
j.schan...@ieee.org




- Original Message -
From: am...@westin-emission.no
To: emc-p...@majordomo.ieee.org
Sent: Wednesday, November 14, 2001 9:45 AM
Subject: CE-mark compliance


|
| Hi all,
|
| Do all manufactures fulfill the EU-directives with testing in
their own
| facilities or by an independent test lab? I guess the answer
must be No.
|
| From my time working in a test lab, my experience is that big
companies like
| Alcatel, Siemens and so on, do the required testing according
to relevant
| requirements. I also got the feeling that small companies (I do
not
| generalize) where a bit laid-back and often put the CE-mark
into the
| products without any tests or with a very limited test process.
|
| Should a system builder trust a Declaration of Conformity from
a big
| manufacturer, without asking for test reports in order to
verify compliance
| with relevant directives ? Would you sleep well at night,  if
you only
| trusted the CE-mark 100% and build a large broadband telecom
system only
| based on the CE-mark without any further documentation?
|
| What is your opinion?
|
| Best regards
| Amund Westin, Oslo/Norway
|
|
|
| ---
| 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/
|
| To cancel your subscription, send mail to:
|  majord...@ieee.org
| with the single line:
|  unsubscribe emc-pstc
|
| For help, send mail to the list administrators:
|  Michael Garretson:pstc_ad...@garretson.org
|  Dave Healddavehe...@mediaone.net
|
| For policy questions, send mail to:
|  Richard Nute:   ri...@ieee.org
|  Jim Bacher: j.bac...@ieee.org
|
| All emc-pstc postings are archived and searchable on the web
at:
| No longer online until our new server is brought online and
the old messages are imported into the new server.
|


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SV: CE-mark compliance

2001-11-14 Thread amund

John,

I mean the CE mark + DoC. From my point of view, I'd like to see some test
reports or other relevant documentation. But I'm now talking about
standalone products build-in for commercial systems. I think I will accept
the CE mark next time I buy an electric shaver. Guess Philips won't spend
time sending me the test report 

Amund

-Opprinnelig melding-
Fra: Allen, John [mailto:john.al...@uk.thalesgroup.com]
Sendt: 14. november 2001 18:43
Til: 'am...@westin-emission.no'; emc-p...@majordomo.ieee.org
Emne: RE: CE-mark compliance


Amund

Do you mean just the CE Mark, or the CE Mark accompanied by the appropriate
DoC?

Here is a an example of what can happen if you accept the  Mark on its own,

A few years ago, in a well-publised legal case in the UK, a PC reseller had
his own badge placed on the equipment. However, when tested for the Trading
Standards Office (local government enforcers!) the PC failed various EMC
tests.

The PC reseller was successfully prosecuted for non-compliance with the EMC
Directive because he had asked for - but not obtained - the DoC from the
actual manufacturer. The main the reason for the successful conviction was
that he had not exercised due dilegence in obtaining the correct
supporting documentation. (The manufacturer was also successfully prosecuted
as well!)

Therefore I would never trust the CE Mark on its own without appropriate
supporting documentation - but the latter may, or may not, be a full
technical report from the supplier. However, in my view, if the equipment is
badged as yours, or is incorporated in your own equipment, then you should
get the appropriate full reports.

John Allen
Thales Defence Communications Division
Bracknell, UK.

-Original Message-
From: am...@westin-emission.no [mailto:am...@westin-emission.no]
Sent: 14 November 2001 14:46
To: emc-p...@majordomo.ieee.org
Subject: CE-mark compliance



Hi all,

Do all manufactures fulfill the EU-directives with testing in their own
facilities or by an independent test lab? I guess the answer must be No.

From my time working in a test lab, my experience is that big companies like
Alcatel, Siemens and so on, do the required testing according to relevant
requirements. I also got the feeling that small companies (I do not
generalize) where a bit laid-back and often put the CE-mark into the
products without any tests or with a very limited test process.

Should a system builder trust a Declaration of Conformity from a big
manufacturer, without asking for test reports in order to verify compliance
with relevant directives ? Would you sleep well at night,  if you only
trusted the CE-mark 100% and build a large broadband telecom system only
based on the CE-mark without any further documentation?

What is your opinion?

Best regards
Amund Westin, Oslo/Norway



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SV: CE-mark compliance

2001-11-14 Thread amund

John,

I won't take any risk at all  I mean, as long as you verify test reports
for standalone units and also check up with possible addition hardware
requirements if the unit shall be incorporated to a larger system, I think
we have done as much as you can expect. The next step would be to test the
complete system.

Amund

-Opprinnelig melding-
Fra: John Juhasz [mailto:jjuh...@fiberoptions.com]
Sendt: 14. november 2001 16:59
Til: 'am...@westin-emission.no'; emc-p...@majordomo.ieee.org
Emne: RE: CE-mark compliance


In the past I had been involved with integration of standalone products
into a larger system. Ultimately my larger system would be required to
be tested, and I would want it to pass.
As the customer who would integrate production quantities of the
standalone, I asked for the report. Those that tested their
products sent it - those that didn't . . . lost a sale.
In that manner, I reduced the possibility of integrating a product
which could create failure that I would have to deal with.

I suppose the question would be - what is acceptable risk
for you?

John Juhasz

-Original Message-
From: am...@westin-emission.no [mailto:am...@westin-emission.no]
Sent: Wednesday, November 14, 2001 9:46 AM
To: emc-p...@majordomo.ieee.org
Subject: CE-mark compliance



Hi all,

Do all manufactures fulfill the EU-directives with testing in their own
facilities or by an independent test lab? I guess the answer must be No.

From my time working in a test lab, my experience is that big companies like
Alcatel, Siemens and so on, do the required testing according to relevant
requirements. I also got the feeling that small companies (I do not
generalize) where a bit laid-back and often put the CE-mark into the
products without any tests or with a very limited test process.

Should a system builder trust a Declaration of Conformity from a big
manufacturer, without asking for test reports in order to verify compliance
with relevant directives ? Would you sleep well at night,  if you only
trusted the CE-mark 100% and build a large broadband telecom system only
based on the CE-mark without any further documentation?

What is your opinion?

Best regards
Amund Westin, Oslo/Norway



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Re: CE-mark compliance

2001-11-14 Thread John Woodgate

I read in !emc-pstc that am...@westin-emission.no wrote (in LFENJLPMMJB
mhpeibnilieagcbaa.am...@westin-emission.no) about 'CE-mark compliance',
on Wed, 14 Nov 2001:

Hi all,

Do all manufactures fulfill the EU-directives with testing in their own
facilities or by an independent test lab? I guess the answer must be No.

There is no *requirement* to test under the LVD and EMC Directives. All
that is required is that the Declaration of Conformity (DOC) is true.

From my time working in a test lab, my experience is that big companies like
Alcatel, Siemens and so on, do the required testing according to relevant
requirements. I also got the feeling that small companies (I do not
generalize) where a bit laid-back and often put the CE-mark into the
products without any tests or with a very limited test process.

No tests, or limited tests, may often be sufficient. You do not need to
do EMC tests on a resistive heating product that has no thermostat.

Should a system builder trust a Declaration of Conformity from a big
manufacturer, without asking for test reports in order to verify compliance
with relevant directives ? 

Your technical file would be incomplete without at least a copy of the
DOC from the supplier. But suppliers are under no obligation to release
test results and normally regard them as commercially confidential.

Would you sleep well at night,  if you only
trusted the CE-mark 100% and build a large broadband telecom system only
based on the CE-mark without any further documentation?

No, that would not be prudent. You would have no evidence to prove 'due
diligence' - that you made sure in advance that you could demonstrate
the truth of your DOC.


-- 
Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk 
Eat mink and be dreary!

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RE: CE-mark compliance

2001-11-14 Thread Allen, John

Amund 

Do you mean just the CE Mark, or the CE Mark accompanied by the appropriate
DoC?

Here is a an example of what can happen if you accept the  Mark on its own,

A few years ago, in a well-publised legal case in the UK, a PC reseller had
his own badge placed on the equipment. However, when tested for the Trading
Standards Office (local government enforcers!) the PC failed various EMC
tests.

The PC reseller was successfully prosecuted for non-compliance with the EMC
Directive because he had asked for - but not obtained - the DoC from the
actual manufacturer. The main the reason for the successful conviction was
that he had not exercised due dilegence in obtaining the correct
supporting documentation. (The manufacturer was also successfully prosecuted
as well!)

Therefore I would never trust the CE Mark on its own without appropriate
supporting documentation - but the latter may, or may not, be a full
technical report from the supplier. However, in my view, if the equipment is
badged as yours, or is incorporated in your own equipment, then you should
get the appropriate full reports.

John Allen
Thales Defence Communications Division
Bracknell, UK.

-Original Message-
From: am...@westin-emission.no [mailto:am...@westin-emission.no]
Sent: 14 November 2001 14:46
To: emc-p...@majordomo.ieee.org
Subject: CE-mark compliance



Hi all,

Do all manufactures fulfill the EU-directives with testing in their own
facilities or by an independent test lab? I guess the answer must be No.

From my time working in a test lab, my experience is that big companies like
Alcatel, Siemens and so on, do the required testing according to relevant
requirements. I also got the feeling that small companies (I do not
generalize) where a bit laid-back and often put the CE-mark into the
products without any tests or with a very limited test process.

Should a system builder trust a Declaration of Conformity from a big
manufacturer, without asking for test reports in order to verify compliance
with relevant directives ? Would you sleep well at night,  if you only
trusted the CE-mark 100% and build a large broadband telecom system only
based on the CE-mark without any further documentation?

What is your opinion?

Best regards
Amund Westin, Oslo/Norway



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RE: CE-mark compliance

2001-11-14 Thread John Juhasz

In the past I had been involved with integration of standalone products
into a larger system. Ultimately my larger system would be required to
be tested, and I would want it to pass. 
As the customer who would integrate production quantities of the
standalone, I asked for the report. Those that tested their
products sent it - those that didn't . . . lost a sale.
In that manner, I reduced the possibility of integrating a product
which could create failure that I would have to deal with.

I suppose the question would be - what is acceptable risk
for you?

John Juhasz

-Original Message-
From: am...@westin-emission.no [mailto:am...@westin-emission.no]
Sent: Wednesday, November 14, 2001 9:46 AM
To: emc-p...@majordomo.ieee.org
Subject: CE-mark compliance



Hi all,

Do all manufactures fulfill the EU-directives with testing in their own
facilities or by an independent test lab? I guess the answer must be No.

From my time working in a test lab, my experience is that big companies like
Alcatel, Siemens and so on, do the required testing according to relevant
requirements. I also got the feeling that small companies (I do not
generalize) where a bit laid-back and often put the CE-mark into the
products without any tests or with a very limited test process.

Should a system builder trust a Declaration of Conformity from a big
manufacturer, without asking for test reports in order to verify compliance
with relevant directives ? Would you sleep well at night,  if you only
trusted the CE-mark 100% and build a large broadband telecom system only
based on the CE-mark without any further documentation?

What is your opinion?

Best regards
Amund Westin, Oslo/Norway



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CE-mark compliance

2001-11-14 Thread amund

Hi all,

Do all manufactures fulfill the EU-directives with testing in their own
facilities or by an independent test lab? I guess the answer must be No.

From my time working in a test lab, my experience is that big companies like
Alcatel, Siemens and so on, do the required testing according to relevant
requirements. I also got the feeling that small companies (I do not
generalize) where a bit laid-back and often put the CE-mark into the
products without any tests or with a very limited test process.

Should a system builder trust a Declaration of Conformity from a big
manufacturer, without asking for test reports in order to verify compliance
with relevant directives ? Would you sleep well at night,  if you only
trusted the CE-mark 100% and build a large broadband telecom system only
based on the CE-mark without any further documentation?

What is your opinion?

Best regards
Amund Westin, Oslo/Norway



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