Re: [PSES] Shipping into Europe - Basic question
I like your pragmatism, but to what directive should you apply the ce mark then ? Applying the ce mark without an applicable directive is illegal and an economic crime. Regards, Ing. Gert Gremmen, BSc g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. -Oorspronkelijk bericht- Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens McInturff, Gary Verzonden: Wednesday, March 28, 2012 10:46 PM Aan: 'oconne...@tamuracorp.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Onderwerp: RE: [PSES] Shipping into Europe - Basic question I propose an IECEE form for the Proclamation of the Declaration of a Certification of Conformity. Why propose new documents when good old circular reasoning can solve the problem. Especially if the real problem is not necessarily complying with the directive but getting it past the customs folks. Being able to CE mark the thing makes that easier since they generally stop when they see the CE mark and documentation. They rarely, in my experience, stop the import while they check out if it really should be CE marked. However, if it's not marked that often seems to catch their eye. So if all other things were even then having the CE mark and the claim to meet the directive in place would be the best choice. One can attest to the directives a number of ways, Harmonized standards, NCB's, TCB's etc, and quite frankly just plain ol' I just think it meets the requirements. There are differing consequences for each choice when it all goes bad - but each of them is doable. The self analysis portion is imperative given Charlie's citations. 1.2.3.2 expressly must be understood to determine you don't need to apply the directive to the pcb. Using the directive itself, thanks to Charlie's citations to the EMC directive, we can use the directive to defeat the directive. From Charlie's citation: 1.2.3.2 Excluded components/sub-assemblies Components and sub-assemblies intended for incorporation by persons other than the end user into apparatus and/or a subsequent sub-assembly are not considered to be apparatus and are therefore not covered by the EMC Directive. This may also be applied to the examples in 1.2.3.1. And now the circular reasoning. The directive says I have to consider the EMC directive when applying the CE mark. This reference above says the pcb it's out of scope and I don't need to mark it. But since marking is the presumed better solution I want to mark the part. Since I did read, I did understand, I know I don't have to mark. But in knowing it's out of scope I actually comply with the directive and I should apply CE mark. Ta da The conversation between Yosarian and Orr in the book Catch 22 which discusses Orr's apple cheeks is the best example of circular reasoning I've ever read. It not only makes you laugh but frustrates the heck out of you as you try to follow the logic. It is a classic catch 22 Gary - 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://listserv.ieee.org/request/user-guide.html 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://listserv.ieee.org/request/user-guide.html 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] Shipping into Europe - Basic question
In message FCA549BE3ECF9D4CB8CB8576837EA4891405BD@ZEUS.cetest.local, dated Thu, 29 Mar 2012, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: I like your pragmatism, but to what directive should you apply the ce mark then ? Applying the ce mark without an applicable directive is illegal and an economic crime. I would invoke the Sanity Clause. Unfortunately, it is well known that, especially in the European Commission, there IS no Sanity Clause. It's your Big Brother dressed up. (;-) -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for? - 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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
In message 5AB06609F29645B0BF401F0345A4C081@RichardHPdv6, dated Wed, 28 Mar 2012, Richard Nute ri...@ieee.org writes: All my part drawings include notes that the material must be UL-recognized and the molder must be UL-recognized. The notes also specify the material flame-rating. I have found that putting critical information on 'drawings', even if the 'drawing' is just text with no graphic at all, is a powerful method of preventing incorrect parts being supplied. BUT the Purchasing Department must accept that the drawing is 100% mandatory unless they ask for and receive a concession. Some Purchasing Departments are totally out of control, and just buy whatever is offered at the lowest price. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for? - 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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
Required for what reason and by whom? By law, by company procedure, by contract, by customer, to satisfy an approvals mark scheme, to keep the insurers happy, etc., etc.? To take your last example, where does the need for a CB report arise? We have customers who always get CB reports done as part of their CE marking process, but when you ask them why, they don't know, it's just a thing they always do. Given that all the things you list cost somebody some money, there has to be a justification for doing them. John C -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: 29 March 2012 01:00 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] receiving/approval processes under fire The siege is underway. The senior design engineers claim that, after conference with colleagues in other companies, many of my conformity requirements have never been required by their compliance people. Some of the receiving/approval processes that are in dispute: - CoC from plastic component supplier that is not recognized molder. - processed wire tags from re-spoolers. - document audits from suppliers having no agency recognition. - labeling requirements for re-packaged chemicals. - EMC re-test for some changes of PCB layout. - update of CB report when values on some safety-critical components changed. The last one I slammed and immediately won the argument. Others may be more difficult. Yes, I know that UL and others publish papers on traceability requirements. So none of you regulatory people do this?? Brian - 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://listserv.ieee.org/request/user-guide.html 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://listserv.ieee.org/request/user-guide.html 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
[PSES] Raspberry Pi Shipping Delayed Due To CE Testing
Hopefully their compliance guy is having a straightforward time of things! http://www.reghardware.com/2012/03/29/raspberry_pi_supplier_apologises_for_ship_date_delay_glitch/ http://www.raspberrypi.org/archives/852 Worth reading the last link for some of the commentards :P James Pawson Leading Hardware Engineer - EMC EchoStar Europe - 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://listserv.ieee.org/request/user-guide.html 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] Raspberry Pi Shipping Delayed Due To CE Testing
It seems a pity that such a great idea that will train tomorrows Software Engineers is being slowed down by what many may argue is unnecessary testing. Regards Ian White Compliance and Reliability. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Pawson, James Sent: Thursday, March 29, 2012 10:28 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Raspberry Pi Shipping Delayed Due To CE Testing Hopefully their compliance guy is having a straightforward time of things! http://www.reghardware.com/2012/03/29/raspberry_pi_supplier_apologises_for_ship_date_delay_glitch/ http://www.raspberrypi.org/archives/852 Worth reading the last link for some of the commentards :P James Pawson Leading Hardware Engineer - EMC EchoStar Europe - 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://listserv.ieee.org/request/user-guide.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://listserv.ieee.org/request/user-guide.html 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] Raspberry Pi Shipping Delayed Due To CE Testing
It's unusual to find a firm that could stay on schedule for EMC. We managed to at (believe it or not) Tandy Computers, when Radio Shack still made their own computers. I've seen SOME firms who think they can lawyer their way around annoying requirements like these, long may *they* fail. Good luck to Element 14. Cortland Richmond On 3/29/2012 0527, Pawson, James wrote: Hopefully their compliance guy is having a straightforward time of things! _http://www.reghardware.com/2012/03/29/raspberry_pi_supplier_apologises_for_ship_date_delay_glitch/_ _http://www.raspberrypi.org/archives/852_ Worth reading the last link for some of the commentards :P James Pawson Leading Hardware Engineer - EMC *EchoStar Europe* - 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://listserv.ieee.org/request/user-guide.html 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] Raspberry Pi Shipping Delayed Due To CE Testing
This idea has not been delayed by unnecessary testing but by bad management. Testing should have been completed a long time ago, and if the designers were competent, testing might have shown it was unnecessary after all ;) Regards, Ing. Gert Gremmen, BSc g.grem...@cetest.nl mailto:g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Ian White (UK) Verzonden: Thursday, March 29, 2012 12:32 PM Aan: Pawson, James; EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: RE: Raspberry Pi Shipping Delayed Due To CE Testing It seems a pity that such a great idea that will train tomorrows Software Engineers is being slowed down by what many may argue is unnecessary testing. Regards Ian White Compliance and Reliability. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Pawson, James Sent: Thursday, March 29, 2012 10:28 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Raspberry Pi Shipping Delayed Due To CE Testing Hopefully their compliance guy is having a straightforward time of things! http://www.reghardware.com/2012/03/29/raspberry_pi_supplier_apologises_f or_ship_date_delay_glitch/ http://www.raspberrypi.org/archives/852 Worth reading the last link for some of the commentards :P James Pawson Leading Hardware Engineer - EMC EchoStar Europe - 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://listserv.ieee.org/request/user-guide.html 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://listserv.ieee.org/request/user-guide.html 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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
Comments interspaced in your text below, but basically I agree with you, not only here but over the last 30 years or so of doing this. Gary -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Wednesday, March 28, 2012 5:00 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] receiving/approval processes under fire The siege is underway. The senior design engineers claim that, after conference with colleagues in other companies, many of my conformity requirements have never been required by their compliance people. Some of the receiving/approval processes that are in dispute: - CoC from plastic component supplier that is not recognized molder. We require this - processed wire tags from re-spoolers. We require this - document audits from suppliers having no agency recognition. This is only done when new vendors are qualified not as ongoing process - my concerns are addressed by the C of C's above - labeling requirements for re-packaged chemicals. Don't use chemicals in our products, but chemicals, must arrive with or access to MDS sheets, and if we used chemicals they would fall into the C of C thing along with MDS info - EMC re-test for some changes of PCB layout. We require this - but base the decision on the change following the typical FCC guidelines. Embedding a blue wire that was on the original test unit probably no, but depends on how much of the pcb routing is changed. I can do a A/B compare in house in a pretty good chamber, but if the product required a formal EMC test, then it's off to the lab. - update of CB report when values on some safety-critical components changed. XXX We update both the UL and the CB report at the same time. The only useful piece of the full CB report is the critical components list. The rest is a waste of paper, in my opinion, well not the test records. The last one I slammed and immediately won the argument. Others may be more difficult. Yes, I know that UL and others publish papers on traceability requirements. So none of you regulatory people do this?? Brian - 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://listserv.ieee.org/request/user-guide.html 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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
EMC re-test for changes in PCB layout? You betcha. Ghery S. Pettit -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian Oconnell Sent: Wednesday, March 28, 2012 5:00 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: receiving/approval processes under fire The siege is underway. The senior design engineers claim that, after conference with colleagues in other companies, many of my conformity requirements have never been required by their compliance people. Some of the receiving/approval processes that are in dispute: - CoC from plastic component supplier that is not recognized molder. - processed wire tags from re-spoolers. - document audits from suppliers having no agency recognition. - labeling requirements for re-packaged chemicals. - EMC re-test for some changes of PCB layout. - update of CB report when values on some safety-critical components changed. The last one I slammed and immediately won the argument. Others may be more difficult. Yes, I know that UL and others publish papers on traceability requirements. So none of you regulatory people do this?? Brian - 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://listserv.ieee.org/request/user-guide.html 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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
Hi Brian, I find the claim of those senior design engineers suspect, which in my opinion appears to be self-serving. And, referring to compliance people in that way reminds me that the rift between design and compliance still exists, even over many years. But if, in fact, those compliance people were not requiring those things, they would certainly not be effective and would not be taking their responsibility seriously or seriously enough. As a curiosity, what is the validity of what those design engineers are claiming? Or, is it just so much rhetoric? So, I recommend that you hold fast against the hordes. In my opinion, I suggest you tell them either FUGETABOUTIT or KWITCHEBELIAKIN. Maybe John could impart some British witticisms here. Please note that my employer expects me to do my job effectively and my responsibilities at least include those processes you've outlined below. Please also find my comments below. IHTH. Best regards, Ron -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Wednesday, March 28, 2012 5:00 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] receiving/approval processes under fire The siege is underway. The senior design engineers claim that, after conference with colleagues in other companies, many of my conformity requirements have never been required by their compliance people. Some of the receiving/approval processes that are in dispute: - CoC from plastic component supplier that is not recognized molder. I require [1]all major plastic parts be made only from recognized molders and [2]CofCs for all plastics to ensure plastic material traceability all of the time. - processed wire tags from re-spoolers. I, too, require this. - document audits from suppliers having no agency recognition. I, too, require this. - labeling requirements for re-packaged chemicals. We only use chemicals for manufacturing processing and those are outside of my control. - EMC re-test for some changes of PCB layout. I, too, require this for some changes, but only where a due diligent EMC analysis indicates retesting is necessary. - update of CB report when values on some safety-critical components changed. The CB cert/report is invaluable for multi-country safety approvals. But, it's not clear what those values are and if those values are not critical, then I would recommend having them removed. The last one I slammed and immediately won the argument. Others may be more difficult. Yes, I know that UL and others publish papers on traceability requirements. So none of you regulatory people do this?? Peshaw! (sp) Balderdash also works here. Brian - 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://listserv.ieee.org/request/user-guide.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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
In message b7f552a0b5f127469b900605a0827bdb2df...@p3pwex2mb012.ex2.secureserver.net , dated Thu, 29 Mar 2012, Ron Pickard rpick...@equinoxpayments.com writes: So, I recommend that you hold fast against the hordes. In my opinion, I suggest you tell them either FUGETABOUTIT or KWITCHEBELIAKIN. Maybe John could impart some British witticisms here. I'm fresh out of Wittish Briticisms. But I know how to resolve the conflict between Design and Compliance. However, no CEO will understand it or implement it. Call me Cassandra! What you do is make the design team leader *responsible*for the compliance of the design. He/she doesn't do the tests but has to understand the standards that apply enough to assess the test reports and sign them off. That not only resolves the conflict but, if the design team leader has a brain cell, he/she makes sure, as far as possible (easier for safety than EMC) that the design is compliant *before* Compliance formally get their hands on it, thus saving $1000 in re-work. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for? - 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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
Mr. Woodgate suggests: What you do is make the design team leader *responsible*for the compliance of the design. He/she doesn't do the tests but has to understand the standards that apply enough to assess the test reports and sign them off. Absolutely! I have successfully used this process for years! My designers have been very complementary. However, to do this, the compliance engineer must partner with the designer so as to offer various alternatives that complement his design, not just a one-size-fits-all. And, you must take some risk with the certification house so that your promises to the design engineer are fulfilled. To do this means you must also partner with the cert house at the same time to be certain that the design is certifiable. This means you join the design team in the very early stages of the design and jointly agree with the design team as to a safety design strategy -- BEFORE the design is developed to a physical model. This has another advantage: the very first prototypes comply with the requirements, and can be used for certification. This means that the certification timetable is not in the critical path to project completion. Good luck! 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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
Excellent advice Rich. I am a proponent of “design for compliance” and have been for years. Getting involved early solves more than you can possibly know; if possible do it at the napkin design stage. Here is a list of ideas that immediately come to mind, there's probably much more. 1) Early involvement identifies markets, requirements, standards, and design risks. 2) “Involvement” means getting down in the trenches with design engineers, manufacturing engineers, procurement, operations, incoming inspection, everyone. Understand the designs, materials, suppliers. Be able to fully comprehend schematics and mechanical diagrams, know company processes, know the customer needs, and make suggestions. 3) Be an advocate for the company when facing the agency and work through the issues to mutual agreement. I’ve seen plenty of compliance engineers forget this and simply “go by the book”. 4) Compliance is not a roadblock to productivity; it is an essential function in of the company and it opens market doors. Sales people know how to buy into this idea. 5) Don't simply say no and shut them down. If something is not right, offer a minimum of three alternative ideas. I once ran into a compliance engineer whose first idea was to go to the engineer's manager to try and force the issue. This is clearly the wrong answer; working through the tough problems together actually wins a compliance advocate on the engineering side of the house. I've had some great arguments and won some dear friends doing this. 6) If it is non-negotiable (and I mean really non-negotiable), be courteous and respectful while explaining the case. It means all the difference. 7) Complaint: Design people say Compliance stifles creativity! Answer: Designers already work within a set of rules called the laws of physics, materials properties, etc. What we really need is more creative designers and engineers that know how to apply ALL the rules. 8) Compliance costs too much. Compared to what, not selling your products at all? This does not fly with me after I participated in the redesign of a line of low cost high power energy conversion products. By replacing all the general purpose and cheap components with those too expensive circuit breakers, fuses, optocouplers, transformers, etc. we achieved a 6% in the cost of goods sold (COGS). In addition, this product line was the history of the company that subsequently demonstrated six-sigma quality. 9) Compliance people have a big advantage in that they see all the departments of a company. A great design idea in one business unit is a great design idea in another business unit. Same goes for processes. Spreading these ideas around the whole business makes you look good too. My goal is to always, always develop great rapport, collaboration, and to be just as agile as the rest of the company. After all, the competition is not inside the company and if you miss the market, you missed it all. Enough for now, I'm on lunch and have to get back to work. -Doug On Thu, Mar 29, 2012 at 11:23 AM, Richard Nute ri...@ieee.org wrote: Mr. Woodgate suggests: What you do is make the design team leader *responsible*for the compliance of the design. He/she doesn't do the tests but has to understand the standards that apply enough to assess the test reports and sign them off. Absolutely! I have successfully used this process for years! My designers have been very complementary. However, to do this, the compliance engineer must partner with the designer so as to offer various alternatives that complement his design, not just a one-size-fits-all. And, you must take some risk with the certification house so that your promises to the design engineer are fulfilled. To do this means you must also partner with the cert house at the same time to be certain that the design is certifiable. This means you join the design team in the very early stages of the design and jointly agree with the design team as to a safety design strategy -- BEFORE the design is developed to a physical model. This has another advantage: the very first prototypes comply with the requirements, and can be used for certification. This means that the certification timetable is not in the critical path to project completion. Good luck! 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://listserv.ieee.org/request/user-guide.html List
Re: [PSES] receiving/approval processes under fire
Rich, Ron, John, et al, Many thanks for the sanity check (not me, the process requirements). Reminds me of (in another life) the boss's favorite retort: 'too many stupid people, not enough napalm.' Where we were also taught to immediately assault directly into an ambush. Intend to do that. I have received many off-line replies that indicate their design engineers had said the exact same thing to them. And just received another reply from an agency engineer I have known 10 years. He says this he hears this stuff all the time from eng dept at companies not having a compliance person - Never had to do anything like this at any other company. Time to go break in the new boss. This may hurt... Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Richard Nute Sent: Thursday, March 29, 2012 10:24 AM To: 'John Woodgate'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] receiving/approval processes under fire Mr. Woodgate suggests: What you do is make the design team leader *responsible*for the compliance of the design. He/she doesn't do the tests but has to understand the standards that apply enough to assess the test reports and sign them off. Absolutely! I have successfully used this process for years! My designers have been very complementary. However, to do this, the compliance engineer must partner with the designer so as to offer various alternatives that complement his design, not just a one-size-fits-all. And, you must take some risk with the certification house so that your promises to the design engineer are fulfilled. To do this means you must also partner with the cert house at the same time to be certain that the design is certifiable. This means you join the design team in the very early stages of the design and jointly agree with the design team as to a safety design strategy -- BEFORE the design is developed to a physical model. This has another advantage: the very first prototypes comply with the requirements, and can be used for certification. This means that the certification timetable is not in the critical path to project completion. Good luck! 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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
In message cabyvtvo1ywokftibjbssslfp2irn0thfhv81sss36zwtlub...@mail.gmail.com, dated Thu, 29 Mar 2012, Doug Powell doug...@gmail.com writes: 4) Compliance is not a roadblock to productivity; it is an essential function in of the company and it opens market doors. Sales people know how to buy into this idea. 8) Compliance costs too much. Compared to what, not selling your products at all? These two are closely associated. I'm not sure how much sales people realise that, but I can say that Marketing Directors don't like the 'huge' cost of compliance being compared with the cost of advertising! -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for? - 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://listserv.ieee.org/request/user-guide.html 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] receiving/approval processes under fire
I would add one thing to the list - in most cases compliance is a much a part of the customers functional specification as are the more traditional values for operating, intended environment, data rates, pixel size, fit and finish. That is the case whether it's a custom designed product where specifications are spelled out in the contract phase, or even in the more generalized case where you are selling to a market niche - internet routers and switches, computers, or camshawrinkback frackacycles with rotating Johnson rods. In this case and federal regulations such as FCC or national electrical codes or even just customer reliability concerns are the driver. Gary From: Doug Powell [mailto:doug...@gmail.com] Sent: Thursday, March 29, 2012 12:23 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] receiving/approval processes under fire Excellent advice Rich. I am a proponent of design for compliance and have been for years. Getting involved early solves more than you can possibly know; if possible do it at the napkin design stage. Here is a list of ideas that immediately come to mind, there's probably much more. 1) Early involvement identifies markets, requirements, standards, and design risks. 2) Involvement means getting down in the trenches with design engineers, manufacturing engineers, procurement, operations, incoming inspection, everyone. Understand the designs, materials, suppliers. Be able to fully comprehend schematics and mechanical diagrams, know company processes, know the customer needs, and make suggestions. 3) Be an advocate for the company when facing the agency and work through the issues to mutual agreement. I've seen plenty of compliance engineers forget this and simply go by the book. 4) Compliance is not a roadblock to productivity; it is an essential function in of the company and it opens market doors. Sales people know how to buy into this idea. 5) Don't simply say no and shut them down. If something is not right, offer a minimum of three alternative ideas. I once ran into a compliance engineer whose first idea was to go to the engineer's manager to try and force the issue. This is clearly the wrong answer; working through the tough problems together actually wins a compliance advocate on the engineering side of the house. I've had some great arguments and won some dear friends doing this. 6) If it is non-negotiable (and I mean really non-negotiable), be courteous and respectful while explaining the case. It means all the difference. 7) Complaint: Design people say Compliance stifles creativity! Answer: Designers already work within a set of rules called the laws of physics, materials properties, etc. What we really need is more creative designers and engineers that know how to apply ALL the rules. 8) Compliance costs too much. Compared to what, not selling your products at all? This does not fly with me after I participated in the redesign of a line of low cost high power energy conversion products. By replacing all the general purpose and cheap components with those too expensive circuit breakers, fuses, optocouplers, transformers, etc. we achieved a 6% in the cost of goods sold (COGS). In addition, this product line was the history of the company that subsequently demonstrated six-sigma quality. 9) Compliance people have a big advantage in that they see all the departments of a company. A great design idea in one business unit is a great design idea in another business unit. Same goes for processes. Spreading these ideas around the whole business makes you look good too. My goal is to always, always develop great rapport, collaboration, and to be just as agile as the rest of the company. After all, the competition is not inside the company and if you miss the market, you missed it all. Enough for now, I'm on lunch and have to get back to work. -Doug On Thu, Mar 29, 2012 at 11:23 AM, Richard Nute ri...@ieee.orgmailto:ri...@ieee.org wrote: Mr. Woodgate suggests: What you do is make the design team leader *responsible*for the compliance of the design. He/she doesn't do the tests but has to understand the standards that apply enough to assess the test reports and sign them off. Absolutely! I have successfully used this process for years! My designers have been very complementary. However, to do this, the compliance engineer must partner with the designer so as to offer various alternatives that complement his design, not just a one-size-fits-all. And, you must take some risk with the certification house so that your promises to the design engineer are fulfilled. To do this means you must also partner with the cert house at the same time to be certain that the design is certifiable. This means you join the design team in the very early stages of the design and jointly agree with the design team as to a safety design strategy -- BEFORE the design is developed to a physical model. This has another
Re: [PSES] receiving/approval processes under fire
For some folks, I offer them the FCC form 730 (?, a senior moment!) The import compliance one. And point out that sure they can import that product that has no documentation, etc. Just sign here. Note this clause that details your impending 5 year Federal vacation that you get to pay a quarter million dollars for. There is usually a long pause while they read that and digest it. Most have handed the form back and said to get the documentation. By then, the shipment usually get returned to sender, if there is time left, otherwise destroyed by Customs which we get to pay for. Sometimes Corp Legal would get involved. Both sides of the debate would present their position and the legal beagle would decide. The decision as one shyster put it to the questioner that asked just why they had to endure this charade, was that the lawyer needed the information to determine which table he would be sitting at, the questioners... or the other side!!| Funny how they all wanted the Corp lawyer sitting at their table. From: Brian Oconnell oconne...@tamuracorp.com To: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Thursday, March 29, 2012 3:25 PM Subject: RE: [PSES] receiving/approval processes under fire Rich, Ron, John, et al, Many thanks for the sanity check (not me, the process requirements). Reminds me of (in another life) the boss's favorite retort: 'too many stupid people, not enough napalm.' Where we were also taught to immediately assault directly into an ambush. Intend to do that. I have received many off-line replies that indicate their design engineers had said the exact same thing to them. And just received another reply from an agency engineer I have known 10 years. He says this he hears this stuff all the time from eng dept at companies not having a compliance person - Never had to do anything like this at any other company. Time to go break in the new boss. This may hurt... Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Richard Nute Sent: Thursday, March 29, 2012 10:24 AM To: 'John Woodgate'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] receiving/approval processes under fire Mr. Woodgate suggests: What you do is make the design team leader *responsible*for the compliance of the design. He/she doesn't do the tests but has to understand the standards that apply enough to assess the test reports and sign them off. Absolutely! I have successfully used this process for years! My designers have been very complementary. However, to do this, the compliance engineer must partner with the designer so as to offer various alternatives that complement his design, not just a one-size-fits-all. And, you must take some risk with the certification house so that your promises to the design engineer are fulfilled. To do this means you must also partner with the cert house at the same time to be certain that the design is certifiable. This means you join the design team in the very early stages of the design and jointly agree with the design team as to a safety design strategy -- BEFORE the design is developed to a physical model. This has another advantage: the very first prototypes comply with the requirements, and can be used for certification. This means that the certification timetable is not in the critical path to project completion. Good luck! 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://listserv.ieee.org/request/user-guide.html 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to
Re: [PSES] receiving/approval processes under fire
Hi Brian, I have to repeat Rich's sentiment below, Good luck. Hopefully, he/she will have had some positive compliance exposure before the breaking in. Best regards, Ron -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Brian Oconnell Sent: Thursday, March 29, 2012 12:25 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] receiving/approval processes under fire Rich, Ron, John, et al, Many thanks for the sanity check (not me, the process requirements). Reminds me of (in another life) the boss's favorite retort: 'too many stupid people, not enough napalm.' Where we were also taught to immediately assault directly into an ambush. Intend to do that. I have received many off-line replies that indicate their design engineers had said the exact same thing to them. And just received another reply from an agency engineer I have known 10 years. He says this he hears this stuff all the time from eng dept at companies not having a compliance person - Never had to do anything like this at any other company. Time to go break in the new boss. This may hurt... Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Richard Nute Sent: Thursday, March 29, 2012 10:24 AM To: 'John Woodgate'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] receiving/approval processes under fire Mr. Woodgate suggests: What you do is make the design team leader *responsible*for the compliance of the design. He/she doesn't do the tests but has to understand the standards that apply enough to assess the test reports and sign them off. Absolutely! I have successfully used this process for years! My designers have been very complementary. However, to do this, the compliance engineer must partner with the designer so as to offer various alternatives that complement his design, not just a one-size-fits-all. And, you must take some risk with the certification house so that your promises to the design engineer are fulfilled. To do this means you must also partner with the cert house at the same time to be certain that the design is certifiable. This means you join the design team in the very early stages of the design and jointly agree with the design team as to a safety design strategy -- BEFORE the design is developed to a physical model. This has another advantage: the very first prototypes comply with the requirements, and can be used for certification. This means that the certification timetable is not in the critical path to project completion. Good luck! 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://listserv.ieee.org/request/user-guide.html 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://listserv.ieee.org/request/user-guide.html 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
[PSES] Compliance costs too much.
I once worked with an EMC engineer who measured the performance of himself and his time by the cost of the components that were used in the equipment solely for the purpose of EMC control. His objective was to reduce the cost of compliance by advising designers of careful layout so as to minimize the need for EMC components. Safety is a bit different because many safety components are also functional components. Nevertheless, a ground wire can be eliminated if double-insulation is employed. In this example, a cost trade-off between the power cord and the extra insulation. But, these days, most primary circuit designs are indeed double-insulated as transformers simply don't use internal shields. Enclosures... only needed for primary circuits and secondary circuits exceeding 30 V. (Yes, you still want an enclosure, but not for safety!) Etc. So, compliance should not cost too much. I look forward to your comments on compliance costing too much. 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://listserv.ieee.org/request/user-guide.html 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] Compliance costs too much.
I guess to measure the cost of compliance; you certainly need to understand the cost of non-compliance. Safety, with regard to reputation, conscience, law suits, sleeping well at night, jail time, etc. EMC and Radio, with regard to quality, reputation, harmony within society, etc. In the USA, Canada and Europe, I see very real examples of how poor compliance rates do lead to a tightening in the requirements. So, you could also consider it an investment. Just a thought. :-) Michael. Michael Derby Regulatory Engineer ACB Europe -Original Message- From: Richard Nute [mailto:ri...@ieee.org] Sent: 30 March 2012 12:24 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Compliance costs too much. I once worked with an EMC engineer who measured the performance of himself and his time by the cost of the components that were used in the equipment solely for the purpose of EMC control. His objective was to reduce the cost of compliance by advising designers of careful layout so as to minimize the need for EMC components. Safety is a bit different because many safety components are also functional components. Nevertheless, a ground wire can be eliminated if double-insulation is employed. In this example, a cost trade-off between the power cord and the extra insulation. But, these days, most primary circuit designs are indeed double-insulated as transformers simply don't use internal shields. Enclosures... only needed for primary circuits and secondary circuits exceeding 30 V. (Yes, you still want an enclosure, but not for safety!) Etc. So, compliance should not cost too much. I look forward to your comments on compliance costing too much. 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://listserv.ieee.org/request/user-guide.html 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://listserv.ieee.org/request/user-guide.html 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
