Pete Tarver pointed out that:
The primary protector at a building entrance limits the voltages available
to do harm to 600Vrms (assumed sinusoidal). There might also be
secondary protection on telecommunication lines that include
supplemental overvoltage protection that limits the voltage
The old requirement that copies of technical files be maintained at some
physical location within the EU is essentially unenforceable. As John Woodgate
pointed out, newer Directives do not incorporate that wording.
To my knowledge, the only entities in the EU that have the legal authority to
Hi David.
It might be necessary to make a distinction about the type of evaluation
you're talking about. In the case of EMC compliance, I think there's a lot
of guidance and documented support that allows a manufacturer to declare EMC
compliance by combining EMC compliant subsystems under
In response to John's comment/question, the answer could well be that the
Commission and it's national enforcing authorities do not want to be faced
with the possibility of having chase 2(or even 3 or more under a multiple
branding situation) companies over a non-compliance/safety situation.
In a message dated 11/8/02 7:56:16 AM Eastern Standard Time,
chris_al...@eur.3com.com writes:
Company B should issue the DoC. But to show due diligence they should
obtain a
DoC (and copies of test reports) from Company A.
That makes two DoC's for one product. If company A issues a
Greg
I think your statement needs some clarification.
Even if it is produced by Company A, the DoC must clearly state the name and
model number of the Company B which sells the product in question in the EU,
so that the document is clearly and specifically associated with that
product as sold in
In a message dated 11/6/02 4:42:04 PM Eastern Standard Time, gui...@cae.com
writes:
For the European law, company B is considered as manufacturer and shall
issue the DoC. No point company A issues its own DoC.
I don't think that's entirely correct. I think it depends on the
relationship
Company A builds a device for company B which sells the device in the EU
under their own brand name. The device is subject to a Declaration of
Conformity, and both companies are located within the EU. Must both
companies issue a Declaration?
No. A declaration from either company will suffice.
Chris asks:
In a quick paragraph, would you provide your opinion on the value of a
Non-NRTL Listing Certification.
Hard to talk about value in such general terms, when the neither the product
nor the application is known. However, a few reactions come to mind:
1. UL was a non-NRTL
In a message dated 10/9/02 3:22:12 PM Eastern Daylight Time,
john_t...@bose.com writes:
Unless something has changed in the in the last two years, when I was
employed at TUV, this is actually not quite correct. The GS Mark is only
for finished ready to use products which do not require any
From Doug McKean:
In 20 years, I've never seen this before but that's not saying much.
Why would a mfr get a UL recognition approval for a commercial
ITE style single phase 155-230vac computer style product but for
that same product get the TUV GS mark?
Mfr is a stateside company.
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A HREF=http://www.mp3.com/soundsurfr;Soundsurfr At MP3.com/A
In response to the 9/27/02 post from Gregg at Test4safety.com:
There are some serious questions and there is a lot of information missing
from your description of the situation. I'll try to address your statements
one by one and offer my reaction as a former certification agency manager:
Can
In a message dated 9/27/02 3:38:55 AM Eastern Daylight Time,
pmerguer...@itl.co.il writes:
.Yes, UL and CSA unfortunately are the only organizations who would like
to
see their country standards covered by their own laboratories. That means
CSA will accept a UL Recognized component when
Hello Amund,
Yes, all of the certification bodies you mentioned will provide a mark that
gives full access within Canada - although in the outlying regions some
inspectors may only be familiar with CSA. Provincial law requires them to
accept a mark issued by any organization accredited as a
So to recap, so far we've got:
a. Yes, they're clearly covered under both the EMC and LVD Directives.
b. No, they're not necessarily covered under either Directive.
c. There's no testing required to CE Mark passive speakers.
d. Passive speakers could be affected by radiated emmissions and
In a message dated 9/18/02 4:40:07 AM Eastern Daylight Time,
j...@jmwa.demon.co.uk writes:
Have you looked at a properly-labelled loudspeaker? Or the spec for a
pair of headphones? Electrical ratings in there!
I own four sets of passive loudspeakers, a passive subwoofer and two pairs of
John,
You wrote, with regard to passive speakers and headphones:
The absence of active components is irrelevant. The EMC and Low Voltage
Directives apply.
How is it that the Directives apply to products that do not carry an
electrical rating?
And in response to the question of getting a
Gregg
To my knowledge, there is no consumer law in the US that requires telephone
answering machines to function properly under abnormal conditions. It is
also not a safety concern.
Greg Galluccio
www.productapprovals.com
---
This message is from the
A telephone headset is not within the scope of EN 60950, I think.
EN 60065 is more applicable.
I would disagree on this one. A telephone is covered under EN 60950,
therefore the logical place for a telephone accessory would be the same
standard.
Actually, this points out the need for the
Mark Gill asked:
I have a question for the group on the effects of temperature rating and
deterioration. If a pcb is rated X degrees C, and the sizing of the power
traces on an inner layer is such that the pcb temperature is now (X-1)
degrees C,
What effect does this have on the longevity of
www.productapprovals.com
A HREF=www.soundsurfr.comwww.soundsurfr.com/A
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Sorry, my last response was incomplete:
Regarding telecom testing, it is possible that most, if not all of the
telecom testing will have to be done at COMTEST in Russia. However, just
last month, ETL SEMKO announced an agreement with COMTEST. The announcement
is vague, and states that
I am not aware of any written Russian law requiring testing to take place on
Russian soil. On the contrary, UL, DEMKO and SGS all have publicized signed
agreements with Gosstandart which (they claim) allow them to run tests on
behalf of Gosstandart. The scope of the agreements include IEC
In Canada, the analagous organization is Health Canada. Similar rules and
responsibilities to FDA.
The European system is somewhat different. All medical devices being
marketed or placed into service in Europe must comply with the European
Medical Device Directive (MDD) and carry a CE
In a message dated 8/2/02 11:00:58 AM Eastern Daylight Time,
gho...@regulatory-compliance.com writes:
They are arguably under obligation if they are using the NFPA-70 NEC as
law.(assuming that they are considering it has been adopted and enforced in
50 states). Which actually calls out the
Gary McInturff wrote:
I believe UL does require it, but as Rich pointed out it isn't always
followed up, and II think is somewhat vague about it, intentionally I
imagine. To be very specific about it one would have to know what countries
the equipment will be installed in? Often the
The local AHJ can do whatever it wants.
NRTL is an OSHA designation which applies only to the workplace. Local
installation code inspection authorities are under no obligation to recognize
an NRTL. They don't have to accept UL either.
Greg Galluccio
www.productapprovals.com
If the product is being marketed in the US and Canada, then the markings
should be in both French and English. There are actually only two Provinces
in Canada that require the markings to be in French, but why bother with such
distinction? UL made a decision some time ago that the
This is a topic that can be of great benefit to a lot of people.
I've had extensive experience communicating this topic to managers and execs
throughout my career, and there is a logical approach that I've adopted which
seems to work well.
First, there are three major components of any
Hey Doug,
I guess it seems to me that if the device is non-functional, then none of
the regulatory information applies.
I see your point, but that's not how the lawyers think!
I was thinking about manufacturer ID's, certification file numbers or other
traceability-type markings such
Doug,
I think it's an interesting idea. Unfortunately, you have as many different
regulators to convince as you have labels.
As a former certifier, I have a few questions that I think would need to
be resolved. For example, if there were some question about the device that
an authority
Scott,
Peter is right. The LVD was never intended to cover components - it was
originally written only for OEM products. In fact, the CE marking scheme is
wholly inadequate as a means of ensuring any level of compliance at the
component level. (Some of the EU Directives specifically
Hi Steve.
My opinion, based on my experience is this:
1. Yes, the product is exempt from the LVD for the reasons stated.
2. If the product is intended to be built into a system, and not used as a
standalone device, AND responsibility for the overall system will be declared
by the OEM, then
Glen Moffat wrote:
Technically, the machinery Directive does apply since it meets the
definition of a machine, assuming that it is not excluded by article 1(5),
that is a risk assessment shows that the risks are not mainly of electrical
origin. However in the UK, I do remember a DTI document
Dear Amund,
Did someone around here say the US system is easy to figure out?
There are differences between ANSI and NIST. To put it as simply as
possible, NIST traditionally controls weights and measures, while ANSI deals
primarily with product standards. There is overlap, but the core
Hi David.
You can order TRF's for EN and IEC standards directly from the IECEE
Webstore:
http://www.iec.ch/webstore/
There is a list of available documents on the IECEE website:
http://www.iecee.org
Regards,
Greg Galluccio
www.productapprovals.com
I used to work for one of those large NRTL's. Their policy when evaluating
equipment incorporating a laser device was to request a copy of the CDRH
report, mostly to ascertain that it was filed. If the investigating engineer
found some overt reason to question the safety of the laser
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