RE: product modifications by the end user

2002-03-21 Thread Colgan, Chris

Thank you for the many replies on this topic, as usual this forum has come
up trumps.  I managed to compose a memo that persuaded our people that
modification kits should only be supplied to suitably qualified
distributors.

Cheers

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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Telephone : 01480 415600 (+44 1480 415600)
Facsimile : 01480 52159 (+44 1480 52159)

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RE: product modifications by the end user

2002-03-19 Thread Greilich, Jeff

Et Al:

I fully agree with Bob Wilson's comments concerning a good solution.
It is only when marketing becomes responsible for its decisions will it
provide marketing information that is truly useful.

Regards,

Jeff
  

-Original Message-
From: Robert Wilson [mailto:robert_wil...@tirsys.com]
Sent: Tuesday, March 19, 2002 12:16 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: product modifications by the end user



One solution that would soon get rid of the problem at its source,
would be to have the Marketing Moron do a few of the upgrades himself.
With any luck, he would find out firsthand the effects of electrical
current flow through the human body.  :)

Bob Wilson
TIR Systems Ltd.
Vancouver.

-Original Message-
From: Colgan, Chris [mailto:chris.col...@tagmclaren.com] 
Sent: March 19, 2002 4:36 AM
To: 'Emc-Pstc' (E-mail)
Subject: product modifications by the end user


Hello good people

Just say someone in your marketing department came up with the bright
idea
of selling upgrade kits to an unqualified, untrained end user that
involved
removing the top cover of a product.  In the process not only would the
victim be exposed to hazardous voltages (if the product was still
connected
to the mains) but he/she would also have to wire up mains connections.
There would also be a possibility that critical insulation would be
disturbed.

Apart from telling them that they were mad and suggesting that someone
could
be killed or seriously injured, would there be any black and white
legislation that you could use to help bin this idea?  I can't find
anything
specific in EN60065 or the LVD.

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



**  
   Please visit us at www.tagmclaren.com
**

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use of the intended recipient. If you receive this E-mail in error,
please delete it from your system immediately and notify us either
by E-mail, telephone or fax. You  should not  copy, forward or 
otherwise disclose the content of the E-mail.

TAG McLaren Audio Ltd
The Summit, 11 Latham Road
Huntingdon, Cambs, PE29 6ZU
Telephone : 01480 415600 (+44 1480 415600)
Facsimile : 01480 52159 (+44 1480 52159)

**  
   Please visit us at www.tagmclaren.com
**

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Re: product modifications by the end user

2002-03-19 Thread John Woodgate

I read in !emc-pstc that Allen, John john.al...@uk.thalesgroup.com
wrote (in 999c839e7e27d41185ec00d0b7473692024cd...@norway.int.rdel.co.u
k) about 'product modifications by the end user', on Tue, 19 Mar 2002:
John Allen
Thales 
Bracknell 
(This is probably my last post on the forum as I will be leaving Thales
tomorrow!

You don't have to leave the group for that reason. (;-)
-- 
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: product modifications by the end user

2002-03-19 Thread Bill Ellingford

Hi Folks
Safety compliance for an add-in card is not an impossibiity!
You can follow EN 60950 and come up with a compliant product design which
allows user access to internal SELV status parts.  This is often the case
with PC's.  You may then design a card for installation within such a
product which, together with the installation instructions, is deemed a
compliant product.  The same is true of certain games machines having SELV
cartridge ports where a cover is removed allowing expansion memory etc. to
be fitted.

PCs designed in this way often require no tools to remove the access cover,
some have knurled nuts or twist locks.

I even beleive there is a UL scheme (although I haven't checked for a few
months) to cover PCs designed in this way and also a scheme to cover a UL
Listed Accessory card for use in these.  This scheme includes the
documentation in the listing.

There may still be some EMC issues to address but safety compliance is not
impossible!

Bill Ellingford

-Original Message-
From: geor...@lexmark.com [mailto:geor...@lexmark.com]
Sent: 19 March 2002 14:26
To: Colgan, Chris
Cc: 'Emc-Pstc' (E-mail)
Subject: Re: product modifications by the end user





Chris,

Every set of existing rules has an intent, to be achieved by
following the letter of the rules.  Personally, I always consider
meeting the intent far superior to meeting the letter of rules.
Example, the letter of the law says we must stop at stop signs before
proceeding.  The intent is to avoid accidents.  We all know that
sometimes we must exceed the rules, i.e. defensive driving, because
the situation demands it.  We also know that if the stop sign is in
the middle of a desert, and we can see 5 miles in all directions,
one would be meeting the intent of the law if no other cars could be
seen, an we did not stop at the sign.

The intent of IEC 60950 and like standards is to avoid personal injury
and property damage.  End users are generally considered operators
under the standard.  As such, they are to be reasonably prevented
from access to hazards in the equipment.  This does not mean that
the equipment must be in a welded steel box, but that tools are
required to enter hazardous areas, and the operator manual does not
direct the operator to access such areas.

The General Principles of 60950 (page 19) clearly states under
Electric Shock : Prevent operator access to parts at hazardous voltage
by fixed or locked covers, interlocks, etc.  Page 17 indicates that
operators are assumed to be oblivious to electrical hazards.

When all else fails in such situations as yours, I get something in
writing indicating that my team has explained the hazards and risks,
and the the Product Manager (or other responsible party) understands
and accepts these risks.  This usually closes the issue.

George





Colgan, Chris chris.colgan%tagmclaren@interlock.lexmark.com on
03/19/2002 07:36:09 AM

Please respond to Colgan, Chris
  chris.colgan%tagmclaren@interlock.lexmark.com

To:   'Emc-Pstc' (E-mail)
emc-pstc%majordomo.ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  product modifications by the end user




Hello good people

Just say someone in your marketing department came up with the bright idea
of selling upgrade kits to an unqualified, untrained end user that involved
removing the top cover of a product.  In the process not only would the
victim be exposed to hazardous voltages (if the product was still connected
to the mains) but he/she would also have to wire up mains connections.
There would also be a possibility that critical insulation would be
disturbed.

Apart from telling them that they were mad and suggesting that someone could
be killed or seriously injured, would there be any black and white
legislation that you could use to help bin this idea?  I can't find anything
specific in EN60065 or the LVD.

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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RE: product modifications by the end user

2002-03-19 Thread Robert Wilson

One solution that would soon get rid of the problem at its source,
would be to have the Marketing Moron do a few of the upgrades himself.
With any luck, he would find out firsthand the effects of electrical
current flow through the human body.  :)

Bob Wilson
TIR Systems Ltd.
Vancouver.

-Original Message-
From: Colgan, Chris [mailto:chris.col...@tagmclaren.com] 
Sent: March 19, 2002 4:36 AM
To: 'Emc-Pstc' (E-mail)
Subject: product modifications by the end user


Hello good people

Just say someone in your marketing department came up with the bright
idea
of selling upgrade kits to an unqualified, untrained end user that
involved
removing the top cover of a product.  In the process not only would the
victim be exposed to hazardous voltages (if the product was still
connected
to the mains) but he/she would also have to wire up mains connections.
There would also be a possibility that critical insulation would be
disturbed.

Apart from telling them that they were mad and suggesting that someone
could
be killed or seriously injured, would there be any black and white
legislation that you could use to help bin this idea?  I can't find
anything
specific in EN60065 or the LVD.

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



**  
   Please visit us at www.tagmclaren.com
**

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use of the intended recipient. If you receive this E-mail in error,
please delete it from your system immediately and notify us either
by E-mail, telephone or fax. You  should not  copy, forward or 
otherwise disclose the content of the E-mail.

TAG McLaren Audio Ltd
The Summit, 11 Latham Road
Huntingdon, Cambs, PE29 6ZU
Telephone : 01480 415600 (+44 1480 415600)
Facsimile : 01480 52159 (+44 1480 52159)

**  
   Please visit us at www.tagmclaren.com
**

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RE: product modifications by the end user

2002-03-19 Thread Ron Pickard


Hi Chris,

In addition to what Richard has said, may I suggest that you take a serious 
look at the Product
Liability Directive, 85/374/EEC along with its amending directive 1999/34/EC. 
Remember, that it is a
fuzzy gray area, indeed, that separates product safety from product liability, 
no matter how
descriptive the standards are. And, due diligence has left the building whereby 
untrained personnel
is allowed into an unsafe area of your product(s), which might be considered as 
lawyer fodder. Do
you really want to go there? Ultimately, the decision must be laid at the feet 
of your company's
management.

I hope this helps.

Best regards,

Ron Pickard
rpick...@hypercom.com







richwo...@tycoint.com   

Sent by:   To: 
emc-p...@majordomo.ieee.org  
owner-emc-pstc@majordomcc:  

o.ieee.org Subject: RE: product 
modifications by the end user   




03/19/02 07:38 AM   

Please respond to   

richwoods   










The LVD has an essential requirement for the safety of the user from
electrical shock - see 1d, 2a and 2d of Annex 1. This essential requirement
is transposed into the user access requirements of EN 60065. Anytime the
user instructions instruct the user to open an electrical enclosure, the
design must be sufficient to ensure that the user cannot access hazardous
parts. Instructing them to remove power is not sufficient.

Richard Woods
Sensormatic Electronics
Tyco International


-Original Message-
From: Colgan, Chris [mailto:chris.col...@tagmclaren.com]
Sent: Tuesday, March 19, 2002 7:36 AM
To: 'Emc-Pstc' (E-mail)
Subject: product modifications by the end user



Hello good people

Just say someone in your marketing department came up with the bright idea
of selling upgrade kits to an unqualified, untrained end user that involved
removing the top cover of a product.  In the process not only would the
victim be exposed to hazardous voltages (if the product was still connected
to the mains) but he/she would also have to wire up mains connections.
There would also be a possibility that critical insulation would be
disturbed.

Apart from telling them that they were mad and suggesting that someone could
be killed or seriously injured, would there be any black and white
legislation that you could use to help bin this idea?  I can't find anything
specific in EN60065 or the LVD.

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



**
   Please visit us at www.tagmclaren.com
**

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use of the intended recipient. If you receive this E-mail in error,
please delete it from your system immediately and notify us either
by E-mail, telephone or fax. You  should not  copy, forward or
otherwise disclose the content of the E-mail.

TAG McLaren Audio Ltd
The Summit, 11 Latham Road
Huntingdon, Cambs, PE29 6ZU
Telephone : 01480 415600 (+44 1480 415600)
Facsimile : 01480 52159 (+44 1480 52159)

**
   Please visit us at www.tagmclaren.com
**

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Re: product modifications by the end user

2002-03-19 Thread John Woodgate

I read in !emc-pstc that Colgan, Chris chris.col...@tagmclaren.com
wrote (in AE0F4BD08FEAD211895900805FE67B1F01090F0D@CAT) about 'product
modifications by the end user', on Tue, 19 Mar 2002:

Just say someone in your marketing department came up with the bright idea
of selling upgrade kits to an unqualified, untrained end user that involved
removing the top cover of a product.  In the process not only would the
victim be exposed to hazardous voltages (if the product was still connected
to the mains) but he/she would also have to wire up mains connections.
There would also be a possibility that critical insulation would be
disturbed.

Apart from telling them that they were mad and suggesting that someone could
be killed or seriously injured, would there be any black and white
legislation that you could use to help bin this idea?  I can't find anything
specific in EN60065 or the LVD.

You wouldn't find such a detailed matter in a well-written new-style
Directive. In the EN, (1998 edition) it's in the first sentence of 8.4,
if you can get the top off without using a tool, and the first sentence
of 9.1.1 if you need a tool to get it off, but instruct the user to use
a tool. Operation with the cover off then becomes a 'normal operating
condition' under 4.2 and the product would be tested with the cover off
as well as on.

I agree that the EN is not very specific on this issue, and that is
because no-one envisaged that any manufacturer would be daft enough to
advise the user to use a tool to take the cover off!

If your marketroid persists, I'll take the issue to the committee
meeting in April and get a definite interpretation. 
-- 
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: product modifications by the end user

2002-03-19 Thread Allen, John

Chris

I would be inclined to look at the General Product Safety  Directive
http://europa.eu.int/eur-lex/en/lif/dat/1992/en_392L0059.html and the
Product Liability Directive
http://europa.eu.int/eur-lex/en/lif/dat/1999/en_399L0034.html

You would probably also have to look at case law which resulted from the
application of these two directives - notably the latter!

Probably means that you would need to talk of to relevant legal counsel
(e.g.  CMS Cameron McKenna = law...@cmck.com) who specialise in these
directives.

When you have shown how liable the company becomes under these, then maybe
you can scare the pants of the marketing department!

However, if for some reason, you do have to go ahead with these mod kits,
then ensure you have extremely explicit instructions (what to do/not do) and
diagrams - preceeed by a clear warning that the mods must only be performed
by a techically trained and competant person, and that the owner should not
proceed with the mods if he has any doubts on his ability to perform them
safely.

However, in the marketing department's defence, it must be said that even
repairing your own car incorrectly can be extremely dangerous (far more so
than these mod kits)- and yet you can buy the parts and the service manuals
almost anywhere. 

So there is some case for saying that such modifications can be quite
acceptable if performed by the right person with the correct tools and
training.

Regards

John Allen
Thales 
Bracknell 
(This is probably my last post on the forum as I will be leaving Thales
tomorrow!



You might also 

-Original Message-
From: Colgan, Chris [mailto:chris.col...@tagmclaren.com]
Sent: 19 March 2002 12:36
To: 'Emc-Pstc' (E-mail)
Subject: product modifications by the end user



Hello good people

Just say someone in your marketing department came up with the bright idea
of selling upgrade kits to an unqualified, untrained end user that involved
removing the top cover of a product.  In the process not only would the
victim be exposed to hazardous voltages (if the product was still connected
to the mains) but he/she would also have to wire up mains connections.
There would also be a possibility that critical insulation would be
disturbed.

Apart from telling them that they were mad and suggesting that someone could
be killed or seriously injured, would there be any black and white
legislation that you could use to help bin this idea?  I can't find anything
specific in EN60065 or the LVD.

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



**  
   Please visit us at www.tagmclaren.com
**

The contents of this E-mail are confidential and for the exclusive
use of the intended recipient. If you receive this E-mail in error,
please delete it from your system immediately and notify us either
by E-mail, telephone or fax. You  should not  copy, forward or 
otherwise disclose the content of the E-mail.

TAG McLaren Audio Ltd
The Summit, 11 Latham Road
Huntingdon, Cambs, PE29 6ZU
Telephone : 01480 415600 (+44 1480 415600)
Facsimile : 01480 52159 (+44 1480 52159)

**  
   Please visit us at www.tagmclaren.com
**

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Re: product modifications by the end user

2002-03-19 Thread georgea



Chris,

Every set of existing rules has an intent, to be achieved by
following the letter of the rules.  Personally, I always consider
meeting the intent far superior to meeting the letter of rules.
Example, the letter of the law says we must stop at stop signs before
proceeding.  The intent is to avoid accidents.  We all know that
sometimes we must exceed the rules, i.e. defensive driving, because
the situation demands it.  We also know that if the stop sign is in
the middle of a desert, and we can see 5 miles in all directions,
one would be meeting the intent of the law if no other cars could be
seen, an we did not stop at the sign.

The intent of IEC 60950 and like standards is to avoid personal injury
and property damage.  End users are generally considered operators
under the standard.  As such, they are to be reasonably prevented
from access to hazards in the equipment.  This does not mean that
the equipment must be in a welded steel box, but that tools are
required to enter hazardous areas, and the operator manual does not
direct the operator to access such areas.

The General Principles of 60950 (page 19) clearly states under
Electric Shock : Prevent operator access to parts at hazardous voltage
by fixed or locked covers, interlocks, etc.  Page 17 indicates that
operators are assumed to be oblivious to electrical hazards.

When all else fails in such situations as yours, I get something in
writing indicating that my team has explained the hazards and risks,
and the the Product Manager (or other responsible party) understands
and accepts these risks.  This usually closes the issue.

George





Colgan, Chris chris.colgan%tagmclaren@interlock.lexmark.com on
03/19/2002 07:36:09 AM

Please respond to Colgan, Chris
  chris.colgan%tagmclaren@interlock.lexmark.com

To:   'Emc-Pstc' (E-mail) emc-pstc%majordomo.ieee@interlock.lexmark.com
cc:(bcc: George Alspaugh/Lex/Lexmark)
Subject:  product modifications by the end user




Hello good people

Just say someone in your marketing department came up with the bright idea
of selling upgrade kits to an unqualified, untrained end user that involved
removing the top cover of a product.  In the process not only would the
victim be exposed to hazardous voltages (if the product was still connected
to the mains) but he/she would also have to wire up mains connections.
There would also be a possibility that critical insulation would be
disturbed.

Apart from telling them that they were mad and suggesting that someone could
be killed or seriously injured, would there be any black and white
legislation that you could use to help bin this idea?  I can't find anything
specific in EN60065 or the LVD.

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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Re: product modifications by the end user

2002-03-19 Thread Chris Allen



Chris,

I'm not sure about EN60065, but in EN60950 the user is always considered to be
unqualified personnel and therefore does not know what they are exposing
themselves to. If you invite a user to remove a cover from a unit (even if you
have told them to disconnect the mains) the whole of the unit becomes user
accessible by definition of the standard and must be safe even when powered.

The user should not be exposed to any hazardous energy / voltages i.e. all
circuits should be SELV.

Maybe you should ask the bright marketing person to have a go. If he survives
then it is OK.

Cheers,
Chris.





Colgan, Chris chris.col...@tagmclaren.com on 19/03/2002 12:36:09

Please respond to Colgan, Chris chris.col...@tagmclaren.com

Sent by:  Colgan, Chris chris.col...@tagmclaren.com


To:   'Emc-Pstc'
cc:(Chris Allen/GB/3Com)
Subject:  product modifications by the end user





Hello good people

Just say someone in your marketing department came up with the bright idea
of selling upgrade kits to an unqualified, untrained end user that involved
removing the top cover of a product.  In the process not only would the
victim be exposed to hazardous voltages (if the product was still connected
to the mains) but he/she would also have to wire up mains connections.
There would also be a possibility that critical insulation would be
disturbed.

Apart from telling them that they were mad and suggesting that someone could
be killed or seriously injured, would there be any black and white
legislation that you could use to help bin this idea?  I can't find anything
specific in EN60065 or the LVD.

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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