Re: [PSES] Battery certification issue
On 9/3/2014 6:23 PM, Richard Nute wrote: such reviews only address how they evaluate to a standard. The don't address how the cert house addresses things that are not included in the standard such as True story. A reputable and well run lab once tested an EUT for RF susceptibility while I was watching. I had expected the product to pass. It failed. I asked how they knew they had 80 percent AM, and they said that when audio signal generator was set for 1VRMS, they should get 80 percent modulation when the RF generator's modulation meter read 80 on a 0-100 scale. That's when I asked they look at the signal in zero span. It took some convincing and I had to get the head engineer, but they learned they'd been clipping, and going far below 100% negative modulation. The product still didn't pass. Heh! I wonder if ANY assessors would have caught over-reliance on disparate operating instructions. Cortland Richmond - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
On 9/4/2014 1:09 PM, Richard Nute wrote: They use the argument that the NRTL must KNOW that the equipment is safe through their own measurements. They cannot be held responsible for tests that are done by another NRTL. Or liable for another's.Pay for three approvals and use the one that's granted? Ouch! Cortland - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
In message 54097f7a.3030...@earthlink.net, dated Fri, 5 Sep 2014, CR k...@earthlink.net writes: Pay for three approvals and use the one that's granted? Ouch! Yes, that's a danger; some test houses (not in USA, of course) would see a commercial advantage in being a bit lax, so more clients would come away satisfied, and return many times. On the other hand, another test house could rapidly develop a reputation for being very strict, and potential clients would be warned off. -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Hello Sudhakar, I am just trying to understand here. India is CB Scheme member but it does not accept any CB test report and they also have in country test requirement using BIS standard instead i don't understand it . Please clarify the steps and process including advantage of using CB scheme in India for outside manufacturer / customer. According to IECEE website The IECEE Certification Body (CB) Full Certification Scheme (CB-FCS) is an extension of the international IECEE CB Scheme and is an option to be exercised by the participants in the CB Scheme and by Applicants under the same IECEE management structure. The CB-FCS is a Scheme based on the principle of mutual recognition of Conformity Assessment Certificates (CACs) and Conformity Assessment Reports (CARs) by its Members as the basis for approval or certification, at national level of products within the scope to the standards accepted for use in the IECEE System. http://www.iecee.org/cb_fcs/default.htm Thank you. Best regards, Binayak www.kebamerica.com Email: binayak.maraha...@kebamerica.com Phone: Main Phone: 952-224-1400 KEB products are Control Technology, Inverters, Converters, Servo systems, Frequency generators, Communication, EMC, Magnetic Technology, Motor and Gears, Elevator Technology, Medical Technology, Material Technology, Automotive etc. - This e-mail, and any attachment to it, contains confidential information that may be legally privileged and which is intended only for the addressee(s) named above. Any use by an unintended recipient is strictly prohibited. If you have received this e-mail in error, please contact the sender and delete it from your system. From: sudhakar wasnik 008dfaa51ca2-dmarc-requ...@ieee.org To: EMC-PSTC@LISTSERV.IEEE.ORG, Date: 09/04/2014 08:31 PM Subject:Re: [PSES] Battery certification issue India is a CB scheme member, However the Mandatory (Compulsory) registration of ITE and A/V products is a national registration scheme. As it is the national scheme, India insist on in-country testing at BIS( Bureau of Indian Standards) certified labs. The applicable standard is BIS ... and not IEC/EN 60950-1. Best, Sudhakar On Thursday, September 4, 2014 1:02 PM, John Woodgate j...@jmwa.demon.co.uk wrote: 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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
Re: [PSES] Battery certification issue
Hi Kevin, Thank you for the clarifications and status of the NRTL program. And the link for updates!! Have a nice weekend! From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] Sent: Thursday, September 04, 2014 3:51 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue Hi Brian, You stated : Do not understand the statement that components are not covered by NRTL program, as the standards list does include component standards: www.osha.gov/dts/otpca/nrtl/list_standards.htmlhttp://www.osha.gov/dts/otpca/nrtl/list_standards.html In short, we know, and we are attempting to clean up that list to remove standards that should no longer be on there (or ones that never should have been added to the list that somehow were added). The first of what will likely be many Federal Register notices dealing with the list of appropriate test standards: http://www.regulations.gov/#!documentDetail;D=OSHA-2013-0012-0004 . Many standards that could be considered component only standards do apply in some instances to end products (ex. motors, transformers etc.). Internally, it is a discussion that we have all the time, and we do receive comments that recommend the addition or deletion of test standards. Kevin Robinson Electrical Engineer Senior Assessor OSHA NRTL Program robinson.ke...@dol.govmailto:robinson.ke...@dol.gov 202-693-1911tel:202-693-1911 On Thu, Sep 4, 2014 at 4:16 PM, Brian Oconnell oconne...@tamuracorp.commailto:oconne...@tamuracorp.com wrote: As previously stated to Mr. Robinson, the industrial compliance engineering community very much appreciates his support of our concerns and ideas. Good people, this is our chance to provide some relevant industry comments. For example, for some product classes the default factory FUS audit interval should be no more than twice per year where the site has not received any variation notices, and there are no new product classes added to production. NRTLs should not be allowed to use the factory audit system as a profit center. Many other ideas, so let us write (link in below message). Do not understand the statement that components are not covered by NRTL program, as the standards list does include component standards: www.osha.gov/dts/otpca/nrtl/list_standards.htmlhttp://www.osha.gov/dts/otpca/nrtl/list_standards.html Perhaps there are differences in implementation. Note that a few AHJs will actually look up a component's 'recognition' to see if the scoped standard was on the NRTL list. Brian From: Kevin Robinson [mailto:kevinrobinso...@gmail.commailto:kevinrobinso...@gmail.com] Sent: Thursday, September 04, 2014 12:15 PM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto: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
Re: [PSES] Battery certification issue
Colleagues, Well, altho my initial question ran far afield I thank everyone who chimed in to respond. The discussion has been quite interesting even tho the initial question is still left somewhat hanging. The business/cultural/legal discussion that has blossomed shows us that the interaction between a worldwide set of manufacturers certifiers has not yet settled down into smooth working system. In some ways it is better than the system in place more than 35 years ago when I started working with test house certifications. In other ways it has become messier because of trying to institute an approval system that is acceptable worldwide. The US based OSHA system comes from a different cultural place than many of the other schemes instituted around the world. The whole US system is more driven by legal and market forces, which I fully support in spite of the difficulties in brings. The mfgr gets to choose their level of exposure in providing their goods into the marketplace. Remember, workplace safety is not the only exposure; AHJs inspecting construction and retailers selling products have a significant role in this process. An interesting discussion about the certification of components ensued. From my perspective the NA Recognition of component safety provides a unique building block capability for mfgrs in that the same components do not need to be re-evaluated over and over when used across products. (The 800lb gorilla rules here; component mfgrs have little choice but to use their service since their customers will need that cert for many product certs thru the same lab.) This simplifies the initial certification evaluation of a product and ensures that there is ongoing surveillance of the product downstream. The CE marking scheme could have invoked such a method but has chosen not to do so; it's probably too late to start one now. I understand the need of countries that institute a full certification scheme to develop a national base of qualified staff to run the scheme so they invoke in-country testing to bring their staff up to speed. The international community ought to be supportive enough to help them work thru that phase get to the phase where they will fully accept CB Reports. This has been done in the past and is going on now in some cases. (I know that some mfgrs are sending their CB Report and EMC reports to India along with the product for evaluation; I sure that Indian engineers will read them carefully during their evaluation - if they get them.) Since I commonly work with small companies here in the US with limited staff and budget I recommend that they use a NRTL for their safety evaluation and also get a CB Report - which contains all of the data - plus provides a nice certificate which they can provide to anyone who asks for proof of conformance (without revealing the details of the product design or evaluation). That covers a lot of bases from what I see. Again, thanx to each one who joined in. Hopefully many silent followers have gained some additional insight into the issues discussed. :) br, Pete Peter E Perkins, PE Principal Product Safety Engineer PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 fone/fax p.perk...@ieee.org - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
In message 006201cfc938$cf4f3560$6deda020$@cs.com, dated Fri, 5 Sep 2014, Pete Perkins 0061f3f32d0c-dmarc-requ...@ieee.org writes: . From my perspective the NA Recognition of component safety provides a unique building block capability for mfgrs in that the same components do not need to be re-evaluated over and over when used across products This is also covered by various IEC/EN component standards and the IECEE scheme. Look at all the component standards normatively referenced in IEC 62368-1. -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
In message 54079132.7070...@ieee.org, dated Wed, 3 Sep 2014, Richard Nute ri...@ieee.org writes: The manufacturer hasn't been damaged by the cert house, so there is nothing that a lawyer can recover on behalf or the manufacturer. Well, that's arguable. Time has been lost. Dollars have been spent. The manufacturer can go to another cert house. If there is one that deals with the same product. If not, and the manufacturer cannot market the product, the cert house is in restraint of trade and would need to justify its actions. I am really surprised to learn this: it seems so different from what we over here think we understand about the US legal system. -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
From what I'm told, just the opposite. The NRTLs need to be able to justify all their decisions to the accreditation body if questioned, or so I'm told. Of course if something slips through and is not questioned by the body during review then... -Dave -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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
The NRTLs I work with don't seem to have any issue with mutual recognition with other NRTLs. Only issue they have is with CE mark which of course is self-certified so can be rightly questioned. -Dave -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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
In message 92dfdeb9614f468a9db0cb3301143...@bn1pr08mb202.namprd08.prod.outlook.com , dated Thu, 4 Sep 2014, Tyra, John john_t...@bose.com writes: 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. I understand, but it seems to create an anomaly in accreditation. Either the more liberal NRTLs are not strict enough or the strict NRTL is gold-plating the requirements. European assessors are charged with disallowing both. (It is not *quite* true that they are charged with disallowing everything.) -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Don't forget we are dealing with Registered Trademarks. The NRTLs have complete discretion over who is allowed to use their mark. They also, of course, have complete discretion over what test data they accept. We have found some NRTLs accept other NRTLs data only when a complete test report is provided. Complete = list of equipment, method, results, signatures, etc. that complies with ISO17025. Providing just a lists of tests conducted has not gotten us very far. Unfortunately some NRTLs no longer provide complete test reports and/or don't allow you to copy and send to anyone. Is it that NRTLs don't trust each other's data? Or is the pink elephant in the room revenue and market share?? I completely understand this, but can't competitors separate themselves based on price and service? Wouldn't it be nice if we can all just get along and get out of the way of mfg'rs so they can get products to market faster? Doesn't this ultimately improve all of our economies?? - getting more done in less time. I believe this discussion has been going on for years and will likely continue for many more. -Original Message- From: Tyra, John [mailto:john_t...@bose.com] Sent: Thursday, September 04, 2014 8:01 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc
Re: [PSES] Battery certification issue
In message 2CF77CABFB3BC045B2724A8EF4182E7310324D46E0@P3PW5EX1MB13.EX1.SECURESERVER .NET, dated Thu, 4 Sep 2014, jral...@productsafetyinc.com jral...@productsafetyinc.com writes: Don't forget we are dealing with Registered Trademarks. The NRTLs have complete discretion over who is allowed to use their mark. They also, of course, have complete discretion over what test data they accept. This is what we had in Europe with each country having its government agency with trademark. It was decided long ago that it is not the best solution. -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Hi John: On 9/4/2014 8:52 AM, jral...@productsafetyinc.com wrote: Is it that NRTLs don't trust each other's data? Or is the pink elephant in the room revenue and market share?? The issue is revenue (profits). If the NRTL performs ALL of the tests, the revenue is higher and the profits higher. They use the argument that the NRTL must KNOW that the equipment is safe through their own measurements. They cannot be held responsible for tests that are done by another NRTL. On the other hand, some NRTLs do accept tests and data from other NRTLs. And, some NRTLs have MRAs (to reduce time and costs for a client). Best regards, Rich - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Hi Rich, Yes, I would agree. Not sure how or if we'll ever get there, but if an NRTL is covered by OSHA for a Standard, all NRTLs should accept their mark and not have to repeat any testing. How do we get there if the Standard itself leaves too much room for interpretation?? If all the Standards were Hazard Based (I know you'll love this), do we have a chance of getting to harmonized interpretations?? -Original Message- From: Richard Nute [mailto:ri...@ieee.org] Sent: Thursday, September 04, 2014 12:10 PM To: jral...@productsafetyinc.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue Hi John: On 9/4/2014 8:52 AM, jral...@productsafetyinc.com wrote: Is it that NRTLs don't trust each other's data? Or is the pink elephant in the room revenue and market share?? The issue is revenue (profits). If the NRTL performs ALL of the tests, the revenue is higher and the profits higher. They use the argument that the NRTL must KNOW that the equipment is safe through their own measurements. They cannot be held responsible for tests that are done by another NRTL. On the other hand, some NRTLs do accept tests and data from other NRTLs. And, some NRTLs have MRAs (to reduce time and costs for a client). Best regards, Rich - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Europe is dealing with separate and sovereign countries, so MRA and the like between certifiers in all countries are needed. 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. The US in one country, not many. So, while most if not all NRTLs in the US have their own test labs, there is no need for any MRA between NRTLs within the US. And, as they are their own test house and as they also use registered trademarks and registered certification marks, they also do not need to accept test data from other test houses. It is extremely unlikely that this will change any time in the foreseeable future. Thanks Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and I sintended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Thursday, September 4, 2014 9:40 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue In message 2CF77CABFB3BC045B2724A8EF4182E7310324D46E0@P3PW5EX1MB13.EX1.SECURESERVER .NET, dated Thu, 4 Sep 2014, jral...@productsafetyinc.com jral...@productsafetyinc.com writes: Don't forget we are dealing with Registered Trademarks. The NRTLs have complete discretion over who is allowed to use their mark. They also, of course, have complete discretion over what test data they accept. This is what we had in Europe with each country having its government agency with trademark. It was decided long ago that it is not the best solution. -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
To continue flogging a dead frog The PHB/MBA style management that has plagued North American compliance labs is where it is because we, the compliance engineering community, have chosen the path of least resistance (which is required for reliable bonding...). Mr. Nute is correct in the statement that agencies are being driven by bottom line concerns. But will also take the side of some of these labs (those that know me are probably having seizures), as have personally seen much weirdness in the test and certification of power conversion stuff. There is one particular lab, even if requested by customer, that my employer will never use: incorrect/incomplete reports, no conditions of acceptability, incorrectly scoped standards, no evidence of factory surveillance, etc. Under the SCC/OSHA systems, the lab takes considerable risk (regardless of the language in your General Services agreement with the agencies) under the civil tort process for all North American legal jurisdictions. One questioned if Is it that NRTLs don't trust each other's data? Yes. In some cases, have had a customer say the marks of X and Y will not fly with Z because they also want yada yada. If customer will pay, we re-submit to Z, where they have access to all of my most wonderful TRFs, pics of test configs, etc; so Z will take my Tech File and use the reports from X and Y as basis for use of their mark and add the model to their FUS audits. Agency Z's management is happy they made more with minimal engineering hours, and agency Z's assessment engineer can go home, drink an ale, and feel reasonably assured that the product is ok. Another wondered if this is ok in legal terms. Yes. If the lab adheres to 29CFR1910, OSHA cannot do anything about a lab's refusal to accept another lab's certification, or a lab's internal policy structure. One commented that their labs typically accept other labs' reports. Have found to be true where there are personal relationships and mutual respect among the various compliance and assessment engineers. A customer once commented that his assessment engineer accepted my employer's box because he knew the people that wrote the report. Finally, it was said by another august member that It is extremely unlikely that this will change any time in the foreseeable future. As the situation is not intractable in technical sense, we should all endeavor to gently persuade some amount of change in lab attitudes. And as Mr. Nute noted, just take your business elsewhere. Brian -Original Message- From: Richard Nute [mailto:ri...@ieee.org] Sent: Thursday, September 04, 2014 10:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue Hi John: On 9/4/2014 8:52 AM, jral...@productsafetyinc.com wrote: Is it that NRTLs don't trust each other's data? Or is the pink elephant in the room revenue and market share?? The issue is revenue (profits). If the NRTL performs ALL of the tests, the revenue is higher and the profits higher. They use the argument that the NRTL must KNOW that the equipment is safe through their own measurements. They cannot be held responsible for tests that are done by another NRTL. On the other hand, some NRTLs do accept tests and data from other NRTLs. And, some NRTLs have MRAs (to reduce time and costs for a client). Best regards, Rich - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] 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.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.gov 202-693-1911 On Thu, Sep 4, 2014 at 1:15 PM, jral...@productsafetyinc.com 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 covered by OSHA for a Standard, all NRTLs should accept their mark and not have to repeat any testing. How do we get there if the Standard itself leaves too much room for interpretation?? If all the Standards were Hazard Based (I know you'll love this), do we have a chance of getting to harmonized interpretations?? -Original Message- From: Richard Nute [mailto:ri...@ieee.org] Sent: Thursday, September 04, 2014 12:10 PM To: jral...@productsafetyinc.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue Hi John: On 9/4/2014 8:52 AM, jral...@productsafetyinc.com wrote: Is it that NRTLs don't trust each other's data? Or is the pink elephant in the room revenue and market share?? The issue is revenue (profits). If the NRTL
Re: [PSES] Battery certification issue
In message CADYqxLChbO-RFt2pTTSRP6Am9+SJcRhwgp7iuDmvtyhPCNo8=a...@mail.gmail.com, dated Thu, 4 Sep 2014, Kevin Robinson kevinrobinso...@gmail.com writes: 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. Even I can understand that.(;-) In Europe, most electrical safety standards also apply to 'finished goods' only, but to all finished goods, not just those used in the workplace but in the home and everywhere else. However, there are some standards that can be applied to sub-assemblies: IEC 61204-7:2006 Low-voltage power supplies, d.c. output - Part 7: Safety requirements -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
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
Re: [PSES] Battery certification issue
As previously stated to Mr. Robinson, the industrial compliance engineering community very much appreciates his support of our concerns and ideas. Good people, this is our chance to provide some relevant industry comments. For example, for some product classes the default factory FUS audit interval should be no more than twice per year where the site has not received any variation notices, and there are no new product classes added to production. NRTLs should not be allowed to use the factory audit system as a profit center. Many other ideas, so let us write (link in below message). Do not understand the statement that components are not covered by NRTL program, as the standards list does include component standards: www.osha.gov/dts/otpca/nrtl/list_standards.html Perhaps there are differences in implementation. Note that a few AHJs will actually look up a component's 'recognition' to see if the scoped standard was on the NRTL list. Brian From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] Sent: Thursday, September 04, 2014 12:15 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 mee! ting 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.gov . Future updates to the program, including the draft directive
Re: [PSES] Battery certification issue
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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Hi Brian, You stated : Do not understand the statement that components are not covered by NRTL program, as the standards list does include component standards: www.osha.gov/dts/otpca/nrtl/list_standards.html In short, we know, and we are attempting to clean up that list to remove standards that should no longer be on there (or ones that never should have been added to the list that somehow were added). The first of what will likely be many Federal Register notices dealing with the list of appropriate test standards: http://www.regulations.gov/#!documentDetail;D=OSHA-2013-0012-0004 . Many standards that could be considered component only standards do apply in some instances to end products (ex. motors, transformers etc.). Internally, it is a discussion that we have all the time, and we do receive comments that recommend the addition or deletion of test standards. Kevin Robinson Electrical Engineer Senior Assessor OSHA NRTL Program robinson.ke...@dol.gov 202-693-1911 On Thu, Sep 4, 2014 at 4:16 PM, Brian Oconnell oconne...@tamuracorp.com wrote: As previously stated to Mr. Robinson, the industrial compliance engineering community very much appreciates his support of our concerns and ideas. Good people, this is our chance to provide some relevant industry comments. For example, for some product classes the default factory FUS audit interval should be no more than twice per year where the site has not received any variation notices, and there are no new product classes added to production. NRTLs should not be allowed to use the factory audit system as a profit center. Many other ideas, so let us write (link in below message). Do not understand the statement that components are not covered by NRTL program, as the standards list does include component standards: www.osha.gov/dts/otpca/nrtl/list_standards.html Perhaps there are differences in implementation. Note that a few AHJs will actually look up a component's 'recognition' to see if the scoped standard was on the NRTL list. Brian From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] Sent: Thursday, September 04, 2014 12:15 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
Re: [PSES] Battery certification issue
India is a CB scheme member, However the Mandatory (Compulsory) registration of ITE and A/V products is a national registration scheme. As it is the national scheme, India insist on in-country testing at BIS( Bureau of Indian Standards) certified labs. The applicable standard is BIS ... and not IEC/EN 60950-1. Best, Sudhakar On Thursday, September 4, 2014 1:02 PM, John Woodgate j...@jmwa.demon.co.uk wrote: 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Dear Sudhakar, So what is the point being member of CB scheme if they do not accept results from IECEE CB report? This is in contradiction to CB scheme idea which points out one time testing. US national standard is also UL 60950-1 but they accept IECEE report if national differences are applied. I think it is just a politics and money collection. Best regards, Bostjan From: sudhakar wasnik [mailto:008dfaa51ca2-dmarc-requ...@ieee.org] Sent: Friday, September 05, 2014 3:27 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue India is a CB scheme member, However the Mandatory (Compulsory) registration of ITE and A/V products is a national registration scheme. As it is the national scheme, India insist on in-country testing at BIS( Bureau of Indian Standards) certified labs. The applicable standard is BIS ... and not IEC/EN 60950-1. Best, Sudhakar On Thursday, September 4, 2014 1:02 PM, John Woodgate j...@jmwa.demon.co.ukmailto:j...@jmwa.demon.co.uk wrote: 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.ukhttp://www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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://www.ieee-pses.org/list.html (including how to unsubscribe)http://www.ieee-pses.org/list.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 emc-pstc discussion list. To post a message to the list, send your e-mail to 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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
In message 007501cfc6f7$be0b7f40$3a227dc0$@cs.com, dated Tue, 2 Sep 2014, Pete Perkins 0061f3f32d0c-dmarc-requ...@ieee.org writes: The cert lab enginer, however, wants full pedigree papers for the batteries citing which clause of which standard? - which the mfgr feels is not needed. citing which clause of which standard? Safety standards should cover everything, and most do, so there is no room for 'want' or 'feel'. -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Welcome to the North American compliance landscape where the NRTL/SCC/NOM process allows an agency to cite 'internal' policy and the assessment engineer's 'judgment' in lieu of any other rationale. Not often, but it does occur. Brian -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Tuesday, September 02, 2014 11:11 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue In message 007501cfc6f7$be0b7f40$3a227dc0$@cs.com, dated Tue, 2 Sep 2014, Pete Perkins 0061f3f32d0c-dmarc-requ...@ieee.org writes: The cert lab enginer, however, wants full pedigree papers for the batteries citing which clause of which standard? - which the mfgr feels is not needed. citing which clause of which standard? Safety standards should cover everything, and most do, so there is no room for 'want' or 'feel'. -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
In message b17a1c7235ca48aeb5ff6a4c66495...@blupr02mb116.namprd02.prod.outlook.com , dated Wed, 3 Sep 2014, Brian Oconnell oconne...@tamuracorp.com writes: Welcome to the North American compliance landscape where the NRTL/SCC/NOM process allows an agency to cite 'internal' policy and the assessment engineer's 'judgment' in lieu of any other rationale. Not often, but it does occur. Isn't that a field-day for lawyers? -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Was much legal wrangling in past decades where you could only go to FM or UL, but the courts have, in fact, blessed most of the agency shenanigans, typically due to component tracibility requirements per the OSHA NRTL and Canada SCC Accreditation Services programs. There is no mutual recognition requirement among NRTLs, but some individual agencies have had MRAs for some stuff. Brian -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Wednesday, September 03, 2014 11:31 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue In message b17a1c7235ca48aeb5ff6a4c66495...@blupr02mb116.namprd02.prod.outlook.com , dated Wed, 3 Sep 2014, Brian Oconnell oconne...@tamuracorp.com writes: Welcome to the North American compliance landscape where the NRTL/SCC/NOM process allows an agency to cite 'internal' policy and the assessment engineer's 'judgment' in lieu of any other rationale. Not often, but it does occur. Isn't that a field-day for lawyers? -- 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
On 9/3/2014 11:31 AM, John Woodgate wrote: In message b17a1c7235ca48aeb5ff6a4c66495...@blupr02mb116.namprd02.prod.outlook.com , dated Wed, 3 Sep 2014, Brian Oconnell oconne...@tamuracorp.com writes: Welcome to the North American compliance landscape where the NRTL/SCC/NOM process allows an agency to cite 'internal' policy and the assessment engineer's 'judgment' in lieu of any other rationale. Not often, but it does occur. Isn't that a field-day for lawyers? No. The North American certification houses are non-government. As such, the product they sell is certification (the right to use the mark). They can (and do) set any rules they want, including internal policy and engineering judgment. What's worse, they don't have to apply them consistently. (And, they don't have to apply science or engineering.) You either toe the line, or they don't give you the right to use their mark. The manufacturer hasn't been damaged by the cert house, so there is nothing that a lawyer can recover on behalf or the manufacturer. The manufacturer can go to another cert house. (I did this once when a cert house was intransigent on my product.) The CB scheme has reduced this somewhat. Now they worry about (and are driven by) what another cert house will think of their appraisal. Pete's client is SOL (unless Pete can fix the situation). Maybe the client should switch to Li-ion batteries! :-) Best regards, Rich - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
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. -Dave -Original Message- From: Richard Nute [mailto:ri...@ieee.org] Sent: Wednesday, September 03, 2014 6:08 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue On 9/3/2014 11:31 AM, John Woodgate wrote: In message b17a1c7235ca48aeb5ff6a4c66495...@blupr02mb116.namprd02.prod.outlook.c om , dated Wed, 3 Sep 2014, Brian Oconnell oconne...@tamuracorp.com writes: Welcome to the North American compliance landscape where the NRTL/SCC/NOM process allows an agency to cite 'internal' policy and the assessment engineer's 'judgment' in lieu of any other rationale. Not often, but it does occur. Isn't that a field-day for lawyers? No. The North American certification houses are non-government. As such, the product they sell is certification (the right to use the mark). They can (and do) set any rules they want, including internal policy and engineering judgment. What's worse, they don't have to apply them consistently. (And, they don't have to apply science or engineering.) You either toe the line, or they don't give you the right to use their mark. The manufacturer hasn't been damaged by the cert house, so there is nothing that a lawyer can recover on behalf or the manufacturer. The manufacturer can go to another cert house. (I did this once when a cert house was intransigent on my product.) The CB scheme has reduced this somewhat. Now they worry about (and are driven by) what another cert house will think of their appraisal. Pete's client is SOL (unless Pete can fix the situation). Maybe the client should switch to Li-ion batteries! :-) Best regards, Rich - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
On 9/3/2014 3:16 PM, Nyffenegger, Dave wrote: 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. -Dave Yes, but such reviews only address how they evaluate to a standard. The don't address how the cert house addresses things that are not included in the standard such as NiCad batteries. Rich - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
All of Mr Nute's comments are so very true. And there is another wrinkle - if you build your box with a component certified by agency X and submit your box to agency Y, you may have your construction rejected out of hand unless the component maker agrees to resubmit to agency Y for re-certification. This is ok per North American accreditation systems for test labs. For batteries, once you operate above Class 2 or 3 limits (NEC articles 725, 800), construction requirements will always be based, at least in part, on engineering judgment where the standard is not explicit. And standards cannot possibly address all constructions. Hence IEC62368-1, where North America compliance can return to the wild and open west. Brian -Original Message- From: Richard Nute [mailto:ri...@ieee.org] Sent: Wednesday, September 03, 2014 3:24 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Battery certification issue On 9/3/2014 3:16 PM, Nyffenegger, Dave wrote: 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. -Dave Yes, but such reviews only address how they evaluate to a standard. The don't address how the cert house addresses things that are not included in the standard such as NiCad batteries. Rich - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Dunno, depends on safety standard for the end-use equipment, and where placed on market. For example, both 60950 and 60065 talk about equipment with installed batteries, where some of the clauses apply to any battery chemistry. Generic requirements for US would be UL2054 for much non-industrial stuff, and IEC62133 (but seems focused on Li) most elsewhere. For medical stuff, FDA wants you to have either 1642 (Li only) or 2054 certification. The other biggie for batteries is UN/IATA transport requirements. Brian -Original Message- From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] Sent: Tuesday, September 02, 2014 2:49 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Battery certification issue PSNet, Working with a client who is caught in a battery certification issue during a product certification. This product uses Ni-metal hydride rechargable batteries. All the certification focus seemed to have moved to Li based batteries with not a lot of concern for older constructions. The cert lab enginer, however, wants full pedigree papers for the batteries - which the mfgr feels is not needed. Wot's the experience of others on this net? :) br, Pete Peter E Perkins, PE Principal Product Safety Engineer PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 fone/fax p.perk...@ieee.org - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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] Battery certification issue
Hi Pete, If it is for CB Scheme, that rule was put out by IECEE in 2011 with exemption to TC108 standards. For others, unless it is Hazardous Location or Intrinsic Safety, it is probably based on the lab exactly how the situation is handled. Best Regards, Jody Leber Consumer Testing Services Global Battery and Accumulator Technical Manager Battery, Energy Efficiency and Safety Laboratory Manager Direct: 770.570.1838 Main: 770.570.1800 Mobile: 678.469.9835 -Original Message- From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] Sent: Tuesday, September 02, 2014 5:49 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Battery certification issue PSNet, Working with a client who is caught in a battery certification issue during a product certification. This product uses Ni-metal hydride rechargable batteries. All the certification focus seemed to have moved to Li based batteries with not a lot of concern for older constructions. The cert lab enginer, however, wants full pedigree papers for the batteries - which the mfgr feels is not needed. Wot's the experience of others on this net? :) br, Pete Peter E Perkins, PE Principal Product Safety Engineer PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 fone/fax p.perk...@ieee.org - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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 Information in this email and any attachments is confidential and intended solely for the use of the individual(s) to whom it is addressed or otherwise directed. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the Company. Finally, the recipient should check this email and any attachments for the presence of viruses. The Company accepts no liability for any damage caused by any virus transmitted by this email. All SGS services are rendered in accordance with the applicable SGS conditions of service available on request and accessible at http://www.sgs.com/en/Terms-and-Conditions.aspx - 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.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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html 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
