[PSES] Definition of unsafe product

2014-07-31 Thread Scott Xe
Recently we received a sales ban from an authority. The authority took a sample from the market and appointed a 3rd party laboratory for verification of LVD conformity. They found a non conformance on construction according to the latest version of safety standard and concluded the product is

[PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

2014-07-31 Thread Dave Heald
Hi all, I know the 2.4 GHz band for WiFi no longer requires the Alert sign as the last restriction on use fell out in 2012, but I have a question on the 5GHz bands: Specifically, if there is an EU-wide restriction on use (indoor use with power limits based on sub-band), is the Alert symbol

Re: [PSES] Definition of unsafe product

2014-07-31 Thread John Woodgate
In message e3b064b4-f401-4b4b-85b4-f8bbbdb94...@gmail.com, dated Fri, 1 Aug 2014, Scott Xe scott...@gmail.com writes: hen our product was verified by the 3rd party test house, it complied with previous version of safety standard but was the latest version of the safety standard at time of

Re: [PSES] Definition of unsafe product

2014-07-31 Thread Nyffenegger, Dave
Refer to the Blue Guide 2014 section 1.1.3 * Products manufactured in compliance with harmonised standards benefit from a presumption of conformity with the corresponding essential requirements of the applicable legislation, and, in some cases, the manufacturer may benefit from a simplified

Re: [PSES] Definition of unsafe product

2014-07-31 Thread John Woodgate
In message 62acad4bbe3449198bb398e2c437b...@bn1pr08mb059.namprd08.prod.outlook.com , dated Thu, 31 Jul 2014, Nyffenegger, Dave dave.nyffeneg...@bhemail.com writes: You can also prove your product is safe and complies with the Directives even if it does not comply with a standard. Perhaps,

Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

2014-07-31 Thread Bayo Olabisi
The use of the alert sign is determined by whether or not it's Class 1 equipment under the RTTE directive - under Class 1 designation, the operating frequency needs to be harmonized at EU member countries, and the regulating standards are harmonized also. The current list of class 1 devices

Re: [PSES] Definition of unsafe product

2014-07-31 Thread Crane, Lauren
Having tracked development of the proposed Market Surveillance Regulation, and stared for hours at NLF model language now incorporated in LVD... it is frustrating how ambiguous the actionable criteria are for this sort of thing. Authorities may act on Risk, but there is no risk assessment

Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

2014-07-31 Thread Michael Derby
Hello Dave, 5 GHz WLAN are indeed Class 2 and do indeed require the Alert Symbol. The restriction of their use is that they are only permitted indoors in the band from 5.15 GHz to 5.35 GHz. The Commission does provide a short list of typical Class 2 devices that are easy to explain.

Re: [PSES] Definition of unsafe product

2014-07-31 Thread Michael Derby
I'm certainly not a safety expert but I think that Lauren is on the right track here. The Harmonised Standards are really a tool to show compliance with the standards. But still, regardless of compliance with the standards if your product is found to be non-compliant with the Directive,

Re: [PSES] Definition of unsafe product

2014-07-31 Thread John Woodgate
In message 04b801cfacf0$22a263f0$67e72bd0$@acbcert.com, dated Thu, 31 Jul 2014, Michael Derby micha...@acbcert.com writes: So, maybe it was unsafe? The OP wrote: They found a non conformance on construction according to the latest version of safety standard and concluded the product is

Re: [PSES] Definition of unsafe product

2014-07-31 Thread Jim Hulbert
A little different problem than Mr. Xe is experiencing, but we recently had a product stopped at Customs in an EU country because the Declaration of Conformity supplied with the product did not call out the latest amendment to an applicable harmonized standard. We had previously performed an

Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

2014-07-31 Thread Crane, Lauren
The RTTE is replaced, in part by the RED (Radio Equipment Directive – 2014/53/EU) which covers the ‘use of spectrum’ topic and no longer calls for the alert symbol. From RED … “Article 50 Repeal Directive 1999/5/EC is repealed with effect from 13 June 2016. References to the repealed Directive

Re: [PSES] Definition of unsafe product

2014-07-31 Thread Crane, Lauren
Jim, Was this for an EMCD issue, or other? The reason I ask is I think that only the EMCD explicitly presses for keeping up with state of the art in its essential requirements (e.g., LVD and MD do not). Which might mean that an insistence on latest-and-greatest is reasonable for EMC

Re: [PSES] Definition of unsafe product

2014-07-31 Thread John Woodgate
In message 7B9D892F88F070469771832D78B3086E2831C2C8@013-BR1MPN1-011.MGDPBI.global.p vt, dated Thu, 31 Jul 2014, Jim Hulbert jim.hulb...@pb.com writes: A little different problem than Mr. Xe is experiencing, but we recently had a product stopped at Customs in an EU country because the

Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

2014-07-31 Thread Michael Derby
The RE Directive is ‘into force’ for the member states to begin transitioning into their national law. That has not happened yet. Also, there are no harmonised standards or Notified Bodies for the RED, so it’s unusable from a practical point of view. The relevant stakeholders have until

Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

2014-07-31 Thread John Woodgate
In message ca+nn3168jxqbrh8strdyyp9xwn--bxjjeolzbeo_xhqxt2c...@mail.gmail.com, dated Thu, 31 Jul 2014, Dave Heald emcp...@gmail.com writes: So in this case, it's an EU-wide restriction on use (indoor use only), so it's not clearly defined as Class 1, and I don't know if the Class 2

Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

2014-07-31 Thread John Woodgate
In message 6ea35dc06888465d8cb4cb752f5ef...@blupr03mb119.namprd03.prod.outlook.com , dated Thu, 31 Jul 2014, Crane, Lauren lauren.cr...@kla-tencor.com writes: I think the above means the RED is in transition and you may chose to follow it vs. the RTTED. The RED cannot be used until at least

Re: [PSES] Definition of unsafe product

2014-07-31 Thread Jim Hulbert
This was in regard to the LVD. Jim -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Thursday, July 31, 2014 3:33 PM To: Jim Hulbert; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Definition of unsafe product Jim, Was this for an EMCD issue, or other?

Re: [PSES] Definition of unsafe product

2014-07-31 Thread Jim Hulbert
OK. So I guess this would be a reasonable request from the authorities. Lesson learned: make sure DoC's are up-to-date to avoid delays. -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Thursday, July 31, 2014 3:35 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: