Re: CE Approval of equipment utilizing HPMs
Michael Hello, 1. You state a piece of equipment. Is this piece going to be integrated into an end-product? If so, it is wise to ask the Irish end- product manufacturer or installer, what the requirements (EMC, Safety, etc.) for the end-product are and work accordingly. Otherwise, you may be designing to the wrong standards and/or Directives. If your piece of equipment is a component, you might be exempt from the Machinery, LVD and EMC Directives depending on the equipment - not enough details were provided! However, you still need to design to the appropriate standards and Directives and prepare a file to submit to the end-product manufacturer or installer. The end-product manufacturer or installer having confidence in your test results, will then CE their equipment. Regarding hazardous materials within a piece of equipment, you may wish to contact TUV Rheinland, Koln, Germany. If you wish, I can provide you with a contact name. 2. If you are the end-product manufacturer, you may not require to comply with the Machinery Directive - again depending on the type of equipment. A risk analysis should be made to determine if the risks are more mechanical or electrical. If mechanical hazards are more than the electrical hazards, the Machinery Directive route is more appropriate. If hazards are more electrical, the Low Voltage Directive route is more appropriate. 3. Please be aware that for the Machinery Directive, the Official Journal lists many standards. You must make sure that you pick the most appropriate standards (and believe me for a typical Machinery Directive investigation you could easily use up to 5 or 6 standards). Many people think that by complying with EN60204 they solved their Machinery Directive requirements. This is absolutely incorrect since this standard pertains to the electrical requirements for machinery. There are many other standards to consider. 4. Please be aware that other Directives might be needed - again depends what your piece of equipment does. For example, if conneccted to the telecom network, you may need to comply with the TTE Directive (unless your modem or other telecom interface has a host-independent European Approval). Should you wish, I can discuss these requirements in detail with you and our PSTC members; however, I believe that you need to provide me with additional info regarding your equipment before I proceed any further. From: Michael Garretson m.garret...@ieee.org To: emc-p...@majordomo.ieee.org Subject:CE Approval of equipment utilizing HPMs Date sent: Mon, 5 Oct 1998 17:17:45 -0700 Send reply to: Michael Garretson m.garret...@ieee.org I am forwarding this question on behalf of one of our clients. Please forgive the lack of detail in some areas. CE marking is not within the normal scope of my responsibilities, so my awareness of the specific requirements is not great. I would appreciate clarification of some of these issues so that we can provide the information to my client in the early stages of their design evaluation. It is my understanding that they are working with a US-based lab for portions of this work, but are not confident that they are being provided with accurate information regarding what requirements may exist to achieve CE marking of the equipment. My company is working with a manufacturer that is intending to send a piece of equipment to Ireland for the first time. The equipment is intended to be installed in a non-classified location, however it uses flammable liquid (hazardous) process chemicals (details unavailable at this time). I am under the impression that the manufacturer plans to assemble a Technical Construction File in order to demonstrate conformance with the applicable requirements of the pertinent CE directives. At this time, they intend to demonstrate compliance with the applicable portions of the Low Voltage, Machinery and EMC directives. Due to the hazardous chemical issues, it has also been suggested that conformance with 94/009 EEC may be required. I would appreciate it if anyone can provide me with guidance on whether this approach is reasonable or whether alternatives need to be pursued. Also if there are specific pitfalls that this manufacturer may encounter, please indicate where those may be, as well. If you require additional detail in order to assist my client with this matter, please let me know what information you require and I will pass the request on to my client. Michael Garretson Sr. Compliance Engineer Electro-Test, Inc. +1 503 653 6781 voice +1 503 659 9733 fax mailto:m.garret...@ieee.org - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j
CE Approval of equipment utilizing HPMs
I am forwarding this question on behalf of one of our clients. Please forgive the lack of detail in some areas. CE marking is not within the normal scope of my responsibilities, so my awareness of the specific requirements is not great. I would appreciate clarification of some of these issues so that we can provide the information to my client in the early stages of their design evaluation. It is my understanding that they are working with a US-based lab for portions of this work, but are not confident that they are being provided with accurate information regarding what requirements may exist to achieve CE marking of the equipment. My company is working with a manufacturer that is intending to send a piece of equipment to Ireland for the first time. The equipment is intended to be installed in a non-classified location, however it uses flammable liquid (hazardous) process chemicals (details unavailable at this time). I am under the impression that the manufacturer plans to assemble a Technical Construction File in order to demonstrate conformance with the applicable requirements of the pertinent CE directives. At this time, they intend to demonstrate compliance with the applicable portions of the Low Voltage, Machinery and EMC directives. Due to the hazardous chemical issues, it has also been suggested that conformance with 94/009 EEC may be required. I would appreciate it if anyone can provide me with guidance on whether this approach is reasonable or whether alternatives need to be pursued. Also if there are specific pitfalls that this manufacturer may encounter, please indicate where those may be, as well. If you require additional detail in order to assist my client with this matter, please let me know what information you require and I will pass the request on to my client. Michael Garretson Sr. Compliance Engineer Electro-Test, Inc. +1 503 653 6781 voice +1 503 659 9733 fax mailto:m.garret...@ieee.org - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j...@gwmail.monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: CE Approval of equipment utilizing HPMs
Michael, I've been working with CE in the semiconductor industry for about 3 years. Here are some things to look out for. Self declaration to the Machinery Directive is not very complicated. Make sure your client has a response to every one of the essential requirements of Annex 1. It would be best if they had a relevant standard or section of a standard for their equipment as it relates to an annex 1 issue. i.e. electrical, lasers, radiation, ventilation, acoustical noiseThis affords them a much more defendable presumption of compliance to the MD. It is best practice, however, in the declaration of conformity, to only claim compliance to a standard if you comply to ALL of the standard. If they only comply to select sections, the words in the declaration should indicate this. Self declaration to the LVD is also a fair route to take. However, since there is a much more generalized list of essential requirements in the LVD, there seems to be more pressure to comply to a particular standard. If their equipment does fall in the scope of an existing EN standard, especially one that is listed in the official journal of the European commission as being applicable to the LVD, they have little excuse for not using it,.in full. One not-so obvious quirk of the LVD is that it requires that its supporting information (Technical Documentation in the language of the LVD) be kept on European soil. This responsibility falls to who ever the importer of record is. Self declaration to the EMC directive is nearly impossible unless your client is able to do the required testing themselves exactly as spelled out in the relevant standards. This usually requires a lot of sophisticated equipment and technique. A competent body along with a third party test lab are the best way to go, especially for large or unusual equipment (i.e. NOT a tv, radio, computer, etc...). The equipment you're talking about does sound unusual. Remember each of these directives has a different name for the technical information. MD=technical file, LVD=technical documentation, EMCD=technical construction file. I think it is reasonable to put it all in one file with an appropriate table of contents explaining which bits support which directive. Surf around the European commission web sights concerning hazardous materials. I know there is a hazardous preparations directive and hazardous materials directive. Also watch out for the simple pressure vessel directive for pressurized systems in equipment. You might try giving the NY branch of the commission a call. It would be easiest if your client did not actually supply the hazmat to Europe, but left it up to their customer to acquire the hazmat for use in the equipment. Cheers, Lauren Crane lcr...@aus.etn.com -Original Message- From: Michael Garretson [SMTP:m.garret...@ieee.org] Sent: Monday, October 05, 1998 7:18 PM To: emc-p...@majordomo.ieee.org Subject: CE Approval of equipment utilizing HPMs I am forwarding this question on behalf of one of our clients. Please forgive the lack of detail in some areas. CE marking is not within the normal scope of my responsibilities, so my awareness of the specific requirements is not great. I would appreciate clarification of some of these issues so that we can provide the information to my client in the early stages of their design evaluation. It is my understanding that they are working with a US-based lab for portions of this work, but are not confident that they are being provided with accurate information regarding what requirements may exist to achieve CE marking of the equipment. My company is working with a manufacturer that is intending to send a piece of equipment to Ireland for the first time. The equipment is intended to be installed in a non-classified location, however it uses flammable liquid (hazardous) process chemicals (details unavailable at this time). I am under the impression that the manufacturer plans to assemble a Technical Construction File in order to demonstrate conformance with the applicable requirements of the pertinent CE directives. At this time, they intend to demonstrate compliance with the applicable portions of the Low Voltage, Machinery and EMC directives. Due to the hazardous chemical issues, it has also been suggested that conformance with 94/009 EEC may be required. I would appreciate it if anyone can provide me with guidance on whether this approach is reasonable or whether alternatives need to be pursued. Also if there are specific pitfalls that this manufacturer may encounter, please indicate where those may be, as well. If you require additional detail in order to assist my client with this matter, please let me know what information you require and I will pass the request on to my client. Michael Garretson Sr. Compliance Engineer Electro-Test, Inc. +1 503 653 6781 voice +1 503 659 9733 fax mailto:m.garret
