Re: [PSES] Johnson City NY - crazy street lights

[John Woodgate]

This is true, but I don't see it as cynical 'planned obsolescence'; it's 
a two-edged sword: 'We want to give the public all the benefits of 
advancing technology, so there is no point in designing for a life of 
even 10 years'. Like my grandfather's garden fork, which is about 100 
years old and still fully functional. Printers and copiers are 
mechanical, so wear out,  but we throw away millions of perfectly good 
computers because they won't run a supported OS any more. The same 
applies to cellphones.


Actually, the new update system for Windows 10 tends to combat the waste 
of computers, but I have one which is half-dead because the manufacturer 
refuses to update a driver that Windows 10 now needs.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-02-06 04:19, Doug Powell wrote:

Interesting indeed,

The thing that probably should surprise me and does not is that as we 
get more sophisticated in our technology the more ways that technology 
can fail.


I can't help but remember the old copy machine in our offices that had 
nothing more a zoom control, number of copies and a big green button 
to make the copies happen.  That machine outlasted the next three 
generations of copiers containing all the features you could ever 
imagine. All the features except longevity.


Best,

Doug in Colorado

*From:* lanterna.viri...@gmail.com
*Sent:* February 4, 2019 5:54 PM
*To:* doug...@gmail.com
*Cc:* EMC-PSTC@listserv.ieee.org
*Subject:* Re: [PSES] Johnson City NY - crazy street lights


These are LED technology from a 2015-2016 vintage conversion.

It could be any number of possible causes.  Based on the power outage, 
it could be a low voltage startup behavior of the LED driver.  Could 
also be comms-related as you describe.  Would be interesting if anyone 
has a reference related to voltage fluctuation during various power 
outages/grid designs.


In my locale, brightness sensors are not per luminaire. They are 
ganged/controlled in larger groups.  I was curious about the type 
installed in my neighborhood and got the datasheet from the electrical 
utility.  It appears to be a common supplier/type from reading 
articles about street light LED conversions and health/environmental 
concerns.  I inquired w/the supplier about in-rush performance of 
their driver having seen a few descriptions of hundreds of amps 
depending on the driver design.


I've seen similar frequency pulsing behaviors with individual LED 
lights during an early morning commute as well as a couple of bulbs in 
my home.  The in-home case, along with a couple of other electronics 
failures were due to failed electrolytic caps on the primary side.


Regards,
Adam in Atlanta
adam.di...@ieee.org 



On Mon, Feb 4, 2019 at 5:58 PM Doug Powell > wrote:


I tend to agree with your statements.

I have worked in a volunteer capacity in TV production studios and
doing stage design using LED lighting.  I am familiar with the
stroboscopic effects the more economical (Alibaba) multiplexed LED
drivers have on TV camera sensors and I believe this flashing is
far too low frequency,  This was part of the reason I suggested
communications issues.  Since street lighting falls under a public
safety category, many of the companies who produce these products
are exempt from EMC considerations and the equipment is made as
cheaply as possible. I believe this is why years ago, we often
heard a lot of interference on AM radio when stopped near traffic
lights.  Nowadays it is likely these fixtures are on a DMX512
universe and individually controlled by digital address.  But now
that I think it over, DMX512 is not two-way communications as such
and would not be able to report a defective fixture needing
maintenance, the next level protocol they may be used is called
"RDS" which does have two-way data communications.  If the main
controller were damaged in some way or if there is intermittent
loss of communication, the lights may behave in a wonky manner by
starting and stopping each time their digital address is polled.

Of course this is all speculation on my part.  I hope to finally
learn what is found in the investigation.

All the best, Doug

Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com 
http://www.linkedin.com/in/dougp01

On Mon, Feb 4, 2019 at 3:03 PM Richard Nute mailto:ri...@ieee.org>> wrote:

Hi Doug:

Each individual light is blinking at its own pace. You can see
this by pausing the video; at each pause, some lights are on,
while some are off.  (At first, I thought they were blinking
in sequence, but you can see that this is not the case by
pausing the video at different times.)

I agree that the lights are probably LEDs because 

Re: [PSES] [BULK] [PSES] Economical operator name & postal address onEEEproducts

[Scott Xe]

Dear Brian & Scott,

Thanks for your excellent guides for this matter!!

Currently we act as a manufacturer because the product has our own brand 
although the products are manufactured in China or other third countries 
outside EU.  The technical files are located at our branch offices outside EU 
but can be retrieved electronically within a short notice.  According to the 
Blue Guide, we do not need to change the name and postal address on the 
products even thought UK exits EU.  However, lots of UK companies are setting 
up another offices or EU headquarters within EU/EEA such as Sony, Panasonic, 
Dyson, etc. and leave their UK office for UK market.  Is this action of a 
finance consideration rather than regulation compliance?

Regards,

Scott


From: Scott Aldous
Sent: Wednesday, 6 February 2019 12:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [BULK] [PSES] Economical operator name & postal address 
onEEEproducts

Hi Scott,

I echo Brian's recommendation to read the relevant sections of the Blue Guide 
(2016 version is the latest I believe). You can download it here. See section 
4.2 on Traceability. It has a detailed description of obligations of different 
economic operators with regard to identification for market surveillance 
authorities. This section references 768/2008/EC, which outlines obligations 
(see Articles R2, R3 and R4 in Annex I).

On Tue, Feb 5, 2019 at 2:15 AM John Woodgate  wrote:
The responsibilities of importers and authorized representative specified in 
Directives and Regulations are insufficient to qualify as 'responsible person', 
because the 'responsible person' has to know that no changes have been made to 
the product that would affect its compliance. In other words, that person must 
have access to all the manufacturing data for the product.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-02-05 09:44, Scott Xe wrote:
Dear Brian,
 
Thanks for your useful info!  Must the responsible person be in EU/EEA 
countries?  Otherwise the responsible person will fall into the importers or 
authorized resprentatives who is in EU/EEA countries?
 
Regards,
 
Scott
 
 
 
 
Scott,
 
The short answer to your question is, the name and address of the responsible 
party for placing a product on the EU market is required to be on the products. 
 EU documents often refer to the responsible party as the “Manufacturer” even 
though the responsible party may not have manufactured the product.  
 
Read the “Blue Guide” on the implementation of the EU products rules 2016/C 
272/01 (unless there is a newer version).  It does a good job explaining the 
many possible roles and players under the New Legislative Form.  
 
The Other Brian
 
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: Saturday, February 02, 2019 3:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [BULK] [PSES] Economical operator name & postal address on EEE products
Importance: Low
 
Regarding the name & address on EEE products in EU market, should they be the 
manufacturers, importers or authorized representatives and which regulation 
does call for it?
 
Thanks and regards,
 
Scott
 
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Re: [PSES] Johnson City NY - crazy street lights

[Doug Powell]

  Interesting indeed,The thing that probably should surprise me and does not is that as we get more sophisticated in our technology the more ways that technology can fail. I can't help but remember the old copy machine in our offices that had nothing more a zoom control, number of copies and a big green button to make the copies happen.  That machine outlasted the next three generations of copiers containing all the features you could ever imagine.  All the features except longevity.Best,Doug in Colorado    From: lanterna.viri...@gmail.comSent: February 4, 2019 5:54 PMTo: doug...@gmail.comCc: EMC-PSTC@listserv.ieee.orgSubject: Re: [PSES] Johnson City NY - crazy street lights  These are LED technology from a 2015-2016 vintage conversion.It could be any number of possible causes.  Based on the power outage, it could be a low voltage startup behavior of the LED driver.  Could also be comms-related as you describe.  Would be interesting if anyone has a reference related to voltage fluctuation during various power outages/grid designs.In my locale, brightness sensors are not per luminaire.  They are ganged/controlled in larger groups.  I was curious about the type installed in my neighborhood and got the datasheet from the electrical utility.  It appears to be a common supplier/type from reading articles about street light LED conversions and health/environmental concerns.  I inquired w/the supplier about in-rush performance of their driver having seen a few descriptions of hundreds of amps depending on the driver design.I've seen similar frequency pulsing behaviors with individual LED lights during an early morning commute as well as a couple of bulbs in my home.  The in-home case, along with a couple of other electronics failures were due to failed electrolytic caps on the primary side.Regards,Adam in Atlantaadam.di...@ieee.orgOn Mon, Feb 4, 2019 at 5:58 PM Doug Powell  wrote:I tend to agree with your statements.  I have worked in a volunteer capacity in TV production studios and doing stage design using LED lighting.  I am familiar with the stroboscopic effects the more economical (Alibaba) multiplexed LED drivers have on TV camera sensors and I believe this flashing is far too low frequency,  This was part of the reason I suggested communications issues.  Since street lighting falls under a public safety category, many of the companies who produce these products are exempt from EMC considerations and the equipment is made as cheaply as possible. I believe this is why years ago, we often heard a lot of interference on AM radio when stopped near traffic lights.  Nowadays it is likely these fixtures are on a DMX512 universe and individually controlled by digital address.  But now that I think it over, DMX512 is not two-way communications as such and would not be able to report a defective fixture needing maintenance, the next level protocol they may be used is called "RDS" which does have two-way data communications.  If the main controller were damaged in some way or if there is intermittent loss of communication, the lights may behave in a wonky manner by starting and stopping each time their digital address is polled.Of course this is all speculation on my part.  I hope to finally learn what is found in the investigation.All the best, DougDouglas E PowellLaporte, Colorado USAdoug...@gmail.comhttp://www.linkedin.com/in/dougp01On Mon, Feb 4, 2019 at 3:03 PM Richard Nute  wrote: Hi Doug: Each individual light is blinking at its own pace.  You can see this by pausing the video; at each pause, some lights are on, while some are off.  (At first, I thought they were blinking in sequence, but you can see that this is not the case by pausing the video at different times.) I agree that the lights are probably LEDs because they have none of the start-up and shut-down partial illumination of other lamp technology.  (I think there is very little stroboscopic effect of the TV camera.) LEDs have different start-up times depending on the individual drive circuitry.  Hence, they will come on at different times after application of the supply.   Here is one hypothesis:  The LED driver circuitry has automatic excessive voltage protection, and shuts down the circuitry in the event of an overvoltage.  Then, it auto-starts, the LED comes on, but shuts down as the voltage is too high.   Another hypothesis:  Street lights are/were in series to cut down on wire size for a large string.  But, to prevent all lights from going out if one is burned out, each lamp is supplied by an individual transformer or a film cut-out.  https://en.wikipedia.org/wiki/Street_light  In 

Re: [PSES] A question about FDA language and interlocking devices

[MIKE SHERMAN]

I see another probably more likely interpretation of "knife edge and finger 
stock" in this context. Look up a knife edge fuse on the internet. Presumably 
the socket the fuse seats in would be the finger stock.


Mike Sherman

Graco Inc.

> On February 5, 2019 at 2:34 PM "Schmidt, Mark"  wrote:
> 
> 
> Please see test below:
> 
>  
> 
> “Safety Interlocks [21 CFR 1020.40(c)(4)(i)]:Each door of a cabinet x-ray 
> system shall have a minimum of two safety interlocks. One, but not both of 
> the required interlocks shall be such that door opening results in physical 
> disconnection of the energy supply circuit to the high-voltage generator, and 
> such disconnection shall not be dependent upon any moving part other than the 
> door. [Note: Safety interlock is defined in 21 CFR 1020.40(b)(11).]
> 
>  
> 
> The primary door interlock should be of conventional design. The second 
> door interlock must physically disconnect the energy supply circuit to the 
> high voltage generator. Physical disconnection means opening the energy 
> supply circuit by removing a piece of the circuit. This is usually 
> accomplished with a ‘knife-edge and finger stock’ or ‘plug and socket’ type 
> connection. It is good practice to assure the primary interlock will remove 
> power from the energy supply circuit before the physical disconnection 
> occurs. Relays, micro switches, and ‘safety switches’ all contain moving 
> parts and, therefore, cannot be used to satisfy the requirement that the 
> physical disconnect interlock is "not dependent on any moving part other than 
> the door."”
> 
>  
> 
> Compliance Guide for Cabinet X-Ray Systems  
> https://www.fda.gov/MedicalDevices/ucm094358.htm
> 
>  
> 
>  
> 
> Mark
> 
>  
> 
>  
> 
> From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
> Sent: Tuesday, February 5, 2019 12:31 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] A question about FDA language and interlocking devices
> 
>  
> 
> That seems to make more sense.  I don’t know anything about X-ray 
> requirements but the FDA requirements laser interlocks are not specific, only 
> referring to “interlocks”.
> 
> -Dave
> 
>  
> 
> From: MIKE SHERMAN [mailto:msherma...@comcast.net]
> Sent: Tuesday, February 05, 2019 12:27 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] A question about FDA language and interlocking devices
> 
>  
> 
> Doug --
> 
>  
> 
> "knife-edge and finger stock" sounds more like the gasketing around the 
> door to keep the radiation inside. I think you'll find similar gasketing on 
> doors to EMC chambers. I've not heard of this term applied to interlock 
> switches.
> 
>  
> 
> Mike Sherman
> 
> Graco Inc.
> 
>  
> 
> > > 
> > On February 5, 2019 at 10:35 AM Doug Nix  > mailto:d...@ieee.org > wrote:
> > 
> > Colleagues,
> > 
> >  
> > 
> > I had a question come my way yesterday that I need a little help 
> > with. Here’s the question:
> > 
> >  
> > 
> > > > > 
> > > I have a customer that produces X-ray equipment. The FDA 
> > > requires that the door that gives access to the X-ray source must have an 
> > > interlock with a ‘knife-edge and finger stock’ type connection.  Also the 
> > > FDA mentions that interlocks should be of conventional design. What is 
> > > understood by “conventional design”? 
> > > 
> > > > > 
> >  
> > 
> > My reading on this requirement is that any conventional 
> > electromechanical interlocking device like this:
> > 
> > [Image result for keyed interlock switch images]
> > 
> > will meet the basic requirements as described by the FDA as 
> > “knife-edge and fingerstock” connection, but I am concerned that this may 
> > not be at all what is meant. 
> > 
> >  
> > 
> > As always, any guidance you can offer will be welcomed and 
> > appreciated!
> > 
> >  
> > 
> > Best,
> > 
> >  
> > 
> > Doug Nix
> > d...@ieee.org mailto:d...@ieee.org
> > +1 (519) 729-5704
> > 
> >  
> > 
> > > 
> 
>  
> 
> > > 
> > -
> > 
> > 
> > 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 mailto:emc-p...@ieee.org >
> > 
> > All emc-pstc postings are archived and searchable on the web at: 
> > http://www.ieee-pses.org/emc-pstc.html 
> > https://urldefense.proofpoint.com/v2/url?u=http-3A__www.ieee-2Dpses.org_emc-2Dpstc.html=DwMGaQ=9mghv0deYPYDGP-W745IEdQLV1kHpn4XJRvR6xMRXtA=RsvNGGiEXp8Wa3AN0R9oJL3JV5vFvlTsmxQpMmBLBIw=vyaFOhjo-plOUNaXICPTF5v8c1AZLKllr7lyVp2wGwk=WXEKr-BkVSmhSljRxt3Sf9e6PaKu6vocdIDAQUX0lbE=
> > 
> >

Re: [PSES] A question about FDA language and interlocking devices

[Schmidt, Mark]

Please see test below:

“Safety Interlocks [21 CFR 1020.40(c)(4)(i)]:Each door of a cabinet x-ray 
system shall have a minimum of two safety interlocks. One, but not both of the 
required interlocks shall be such that door opening results in physical 
disconnection of the energy supply circuit to the high-voltage generator, and 
such disconnection shall not be dependent upon any moving part other than the 
door. [Note: Safety interlock is defined in 21 CFR 1020.40(b)(11).]

The primary door interlock should be of conventional design. The second door 
interlock must physically disconnect the energy supply circuit to the high 
voltage generator. Physical disconnection means opening the energy supply 
circuit by removing a piece of the circuit. This is usually accomplished with a 
‘knife-edge and finger stock’ or ‘plug and socket’ type connection. It is good 
practice to assure the primary interlock will remove power from the energy 
supply circuit before the physical disconnection occurs. Relays, micro 
switches, and ‘safety switches’ all contain moving parts and, therefore, cannot 
be used to satisfy the requirement that the physical disconnect interlock is 
"not dependent on any moving part other than the door."”

Compliance Guide for Cabinet X-Ray Systems  
https://www.fda.gov/MedicalDevices/ucm094358.htm


Mark


From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
Sent: Tuesday, February 5, 2019 12:31 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] A question about FDA language and interlocking devices

That seems to make more sense.  I don’t know anything about X-ray requirements 
but the FDA requirements laser interlocks are not specific, only referring to 
“interlocks”.
-Dave

From: MIKE SHERMAN [mailto:msherma...@comcast.net]
Sent: Tuesday, February 05, 2019 12:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] A question about FDA language and interlocking devices


Doug --



"knife-edge and finger stock" sounds more like the gasketing around the door to 
keep the radiation inside. I think you'll find similar gasketing on doors to 
EMC chambers. I've not heard of this term applied to interlock switches.



Mike Sherman

Graco Inc.


On February 5, 2019 at 10:35 AM Doug Nix mailto:d...@ieee.org>> 
wrote:

Colleagues,

I had a question come my way yesterday that I need a little help with. Here’s 
the question:

I have a customer that produces X-ray equipment. The FDA requires that the door 
that gives access to the X-ray source must have an interlock with a ‘knife-edge 
and finger stock’ type connection.  Also the FDA mentions that interlocks 
should be of conventional design. What is understood by “conventional design”?

My reading on this requirement is that any conventional electromechanical 
interlocking device like this:
[Image result for keyed interlock switch images]
will meet the basic requirements as described by the FDA as “knife-edge and 
fingerstock” connection, but I am concerned that this may not be at all what is 
meant.

As always, any guidance you can offer will be welcomed and appreciated!

Best,

Doug Nix
d...@ieee.org
+1 (519) 729-5704



-


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 can be used for graphics (in well-used formats), large files, etc.

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Re: [PSES] A question about FDA language and interlocking devices

[Nyffenegger, Dave]

That seems to make more sense.  I don’t know anything about X-ray requirements 
but the FDA requirements laser interlocks are not specific, only referring to 
“interlocks”.
-Dave

From: MIKE SHERMAN [mailto:msherma...@comcast.net]
Sent: Tuesday, February 05, 2019 12:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] A question about FDA language and interlocking devices


Doug --



"knife-edge and finger stock" sounds more like the gasketing around the door to 
keep the radiation inside. I think you'll find similar gasketing on doors to 
EMC chambers. I've not heard of this term applied to interlock switches.



Mike Sherman

Graco Inc.


On February 5, 2019 at 10:35 AM Doug Nix mailto:d...@ieee.org>> 
wrote:

Colleagues,

I had a question come my way yesterday that I need a little help with. Here’s 
the question:

I have a customer that produces X-ray equipment. The FDA requires that the door 
that gives access to the X-ray source must have an interlock with a ‘knife-edge 
and finger stock’ type connection.  Also the FDA mentions that interlocks 
should be of conventional design. What is understood by “conventional design”?

My reading on this requirement is that any conventional electromechanical 
interlocking device like this:
[Image result for keyed interlock switch images]
will meet the basic requirements as described by the FDA as “knife-edge and 
fingerstock” connection, but I am concerned that this may not be at all what is 
meant.

As always, any guidance you can offer will be welcomed and appreciated!

Best,

Doug Nix
d...@ieee.org
+1 (519) 729-5704



-


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David Heald: 

Re: [PSES] A question about FDA language and interlocking devices

[Nyffenegger, Dave]

EN ISO 14119 Safety of machinery - Interlocking devices associated with guards 
- Principles for design and selection has good information to refer to for 
safety interlocks.  Compliance with this standard is required for machinery 
under the Machinery Directive  for CE marking.   While there may not be any 
formal requirement to follow this standard for X-ray machines it may still be a 
useful reference and wouldn’t hurt to follow it.  This standard would apply to 
CE marked X-ray machines if they fall under the Machinery Directive.

-Dave

From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: Tuesday, February 05, 2019 2:07 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] A question about FDA language and interlocking devices

Doug,

These type of interlock switches are new to me. They are used in industrial 
applications where they protect the user from a very hazardous condition.

These switches usually have what is called a Positive Mechanical Action or 
Certified Direct Opening mechanism which forces a Normally Closed contact OPEN 
when in the SAFE State. In these cases, when the key is removed from the switch 
there is an internal mechanism which forces a NC contact OPEN (removing the 
hazard).  If the contact is stuck closed, then the key cannot be removed from 
the switch.  There are usually other contacts within the switch that can be 
used to monitor the switch to verify its proper function.

If the switch is certified to EN60947-5-1 for the direct opening mechanism, the 
switch will have a symbol that looks like an arrow pointing to the right inside 
a circle.

That is about all I know about these.

The Other Brian


From: Doug Nix [mailto:d...@ieee.org]
Sent: Tuesday, February 05, 2019 11:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] A question about FDA language and interlocking devices

Colleagues,

I had a question come my way yesterday that I need a little help with. Here’s 
the question:

I have a customer that produces X-ray equipment. The FDA requires that the door 
that gives access to the X-ray source must have an interlock with a ‘knife-edge 
and finger stock’ type connection.  Also the FDA mentions that interlocks 
should be of conventional design. What is understood by “conventional design”?

My reading on this requirement is that any conventional electromechanical 
interlocking device like this:
[Image result for keyed interlock switch images]
will meet the basic requirements as described by the FDA as “knife-edge and 
fingerstock” connection, but I am concerned that this may not be at all what is 
meant.

As always, any guidance you can offer will be welcomed and appreciated!

Best,

Doug Nix
d...@ieee.org
+1 (519) 729-5704

-


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information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you.
-


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-

Re: [PSES] A question about FDA language and interlocking devices

[Kunde, Brian]

Doug,

These type of interlock switches are new to me. They are used in industrial 
applications where they protect the user from a very hazardous condition.

These switches usually have what is called a Positive Mechanical Action or 
Certified Direct Opening mechanism which forces a Normally Closed contact OPEN 
when in the SAFE State. In these cases, when the key is removed from the switch 
there is an internal mechanism which forces a NC contact OPEN (removing the 
hazard).  If the contact is stuck closed, then the key cannot be removed from 
the switch.  There are usually other contacts within the switch that can be 
used to monitor the switch to verify its proper function.

If the switch is certified to EN60947-5-1 for the direct opening mechanism, the 
switch will have a symbol that looks like an arrow pointing to the right inside 
a circle.

That is about all I know about these.

The Other Brian


From: Doug Nix [mailto:d...@ieee.org]
Sent: Tuesday, February 05, 2019 11:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] A question about FDA language and interlocking devices

Colleagues,

I had a question come my way yesterday that I need a little help with. Here’s 
the question:

I have a customer that produces X-ray equipment. The FDA requires that the door 
that gives access to the X-ray source must have an interlock with a ‘knife-edge 
and finger stock’ type connection.  Also the FDA mentions that interlocks 
should be of conventional design. What is understood by “conventional design”?

My reading on this requirement is that any conventional electromechanical 
interlocking device like this:
[Image result for keyed interlock switch images]
will meet the basic requirements as described by the FDA as “knife-edge and 
fingerstock” connection, but I am concerned that this may not be at all what is 
meant.

As always, any guidance you can offer will be welcomed and appreciated!

Best,

Doug Nix
d...@ieee.org
+1 (519) 729-5704

-


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discussion list. To post a message to the list, send your e-mail to 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you.

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
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All emc-pstc postings are archived and searchable on the web at:
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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 
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Re: [PSES] UK Gov Using The UKCA Mark

[Dennis Ward]

Not exactly correct – unintentional radiators, regardless if they are SDOC or 
certified, are to be tested using C63.4_2014.  C63.4 requires the site must 
meet the site requirements of C63.4 and requires that antennas used for 
measurements must be calibrated to C63.5 (latest edition).
Thanks


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended 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.


From: Charlie Blackham 
Sent: Tuesday, February 5, 2019 2:52 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

Glyn

For sDoC... there is no requirement to be accredited, nor listed on the FCC 
website.   So, anyone can do sDoC testing.

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: Payne, Glyn 
<0d283c0acebb-dmarc-requ...@listserv.ieee.org>
Sent: 05 February 2019 10:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

Hi John,

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

Regards,

Glyn Payne

Validation and Compliance Engineer

Solid State Logic - UK Headquarters

www.solidstatelogic.com

Facebook : 
Twitter : 
Youtube

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK

t: +44 1865 664894 | m: +44 7989 163937


From: John Woodgate mailto:j...@woodjohn.uk>>
Reply-To: John Woodgate mailto:j...@woodjohn.uk>>
Date: Tuesday, 5 February 2019 at 10:23
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: Re: [PSES] UK Gov Using The UKCA Mark


Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world.

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk

Rayleigh, Essex UK
On 2019-02-05 09:59, Scott Xe wrote:
I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it?

Regards,

Scott


On Tue, 5 Feb 2019 at 01:51, Kapur, Ken 
mailto:ken.ka...@thermofisher.com>> wrote:
Hi John,
These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any relabeling to happen will definitely 
take a lot of time.  Hopefully, there will be no new testing and existing 
standards would be accepted.

Will there be an 18 month transition? Will there be a different set of 
requirements for products shipping EU to UK versus from other countries?


Best Regards,
Ken Kapur
Director, Compliance
Thermo Fisher Scientific
Mobile: 408-685-1454



From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Monday, February 04, 2019 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.


We need to get a Mutual Recognition Agreement as soon as possible. I'm 
surprised that the UK Gov document doesn't even mention the possibility. 

Re: [PSES] A question about FDA language and interlocking devices

[Ted Eckert]

Hello Doug,

I have only a limited amount of knowledge in this area, and I hope another 
listserv member can either correct me or provide more detail. I also believe 
Mike Sherman may be correct on the knife edge/finger stock description.

The CDRH at the FDA is generally very conservative and they don't update 
requirements often as technology changes. (Their inspection 
guide
 still dates from 1985.) I believe that the restrictions on interlock type is 
based on making it difficult to override the interlock. I do believe that your 
interpretation is correct. The interlocks you show should meet the CDRH 
requirements.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer or the FDA.

From: Doug Nix 
Sent: Tuesday, February 5, 2019 8:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] A question about FDA language and interlocking devices

Colleagues,

I had a question come my way yesterday that I need a little help with. Here's 
the question:

I have a customer that produces X-ray equipment. The FDA requires that the door 
that gives access to the X-ray source must have an interlock with a 'knife-edge 
and finger stock' type connection.  Also the FDA mentions that interlocks 
should be of conventional design. What is understood by "conventional design"?

My reading on this requirement is that any conventional electromechanical 
interlocking device like this:
[Image result for keyed interlock switch images]
will meet the basic requirements as described by the FDA as "knife-edge and 
finger stock" connection, but I am concerned that this may not be at all what 
is meant.

As always, any guidance you can offer will be welcomed and appreciated!

Best,

Doug Nix
d...@ieee.org
+1 (519) 729-5704

-


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 can be used for graphics (in well-used formats), large files, etc.

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Re: [PSES] Economical operator name & postal address on EEEproducts

[Nyffenegger, Dave]

Nice summary.

From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: Tuesday, February 05, 2019 10:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Economical operator name & postal address on EEEproducts

Scott,

Go to this link:
https://ec.europa.eu/growth/content/%E2%80%98blue-guide%E2%80%99-implementation-eu-product-rules-0_en

At the bottom of the page, click on “BLUE GUIDE 2016”. It should download the 
document in .pdf format.

Go to page 30 which should be section 3.1 on “MANUFACTURER”.

There is a lot of good information in this document. As I said, the word 
“Manufacturer” is given to the responsible person (natural or legal). As such, 
the Manufacturer has many responsibilities.

“The manufacturer has ultimate responsibility for the conformity of the product 
to the applicable Union harmonisation legislation, whether he designed and 
manufactured the product himself or is considered as a manufacturer because the 
product is placed on the market under his name or trademark.”

“The manufacturer is obliged to understand both the design and construction of 
the product to be able to take the responsibility for the product being in 
compliance with all provisions of the relevant Union harmonisation legislation. 
This applies equally to situations where the manufacturer designs, 
manufactures, packs and labels the product himself, as to situations where some 
or all of these operations are carried out by a subcontractor. The manufacturer 
needs to have the relevant information to demonstrate compliance of the product 
at its disposal.”

“Union harmonisation legislation does not require the manufacturer to be 
established in the European Union. Thus, when placing a product on the Union 
market, the responsibilities of a manufacturer are the same whether he is 
established outside the European Union or in a Member State.”

Under 3.1 subpart 5 regarding the Name and Address on the product, “The single 
contact point may not necessarily be located in the Member State where the 
product is made available on the market;”

Also read the section 3.3 on IMPORTER.  The importer takes on the role of 
Manufacturer (and responsibilities of) when they place a product from a “third 
country” on the EU market.  In some cases, the name and address of the Importer 
should be added to the product in addition to the original third country 
manufacturer.

I also highly recommend reading section 3.2.AUTHORISED REPRESENTATIVE.  You 
will find that having a AR is the choice of the Manufacturer and not required 
even for Manufacturers outside of the EU.  The AR is often mistaken as the 
“person responsible for compiling the Technical Documents” as required by some 
Directives such as the Machinery Directive.  The ‘person’ can be anyone and 
does not have to be an AR.

Hope this information was helpful.

The Other Brian

From: Scott Xe [mailto:scott...@gmail.com]
Sent: Tuesday, February 05, 2019 4:44 AM
To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [BULK] [PSES] Economical operator name & postal address on 
EEEproducts
Importance: Low

Dear Brian,

Thanks for your useful info!  Must the responsible person be in EU/EEA 
countries?  Otherwise the responsible person will fall into the importers or 
authorized resprentatives who is in EU/EEA countries?

Regards,

Scott




Scott,

The short answer to your question is, the name and address of the responsible 
party for placing a product on the EU market is required to be on the products. 
 EU documents often refer to the responsible party as the “Manufacturer” even 
though the responsible party may not have manufactured the product.

Read the “Blue Guide” on the implementation of the EU products rules 2016/C 
272/01 (unless there is a newer version).  It does a good job explaining the 
many possible roles and players under the New Legislative Form.

The Other Brian

From: Scott Xe [mailto:scott...@gmail.com]
Sent: Saturday, February 02, 2019 3:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [BULK] [PSES] Economical operator name & postal address on EEE products
Importance: Low

Regarding the name & address on EEE products in EU market, should they be the 
manufacturers, importers or authorized representatives and which regulation 
does call for it?

Thanks and regards,

Scott

-


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discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

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Re: [PSES] A question about FDA language and interlocking devices

[MIKE SHERMAN]

Doug --


"knife-edge and finger stock" sounds more like the gasketing around the door to 
keep the radiation inside. I think you'll find similar gasketing on doors to 
EMC chambers. I've not heard of this term applied to interlock switches.


Mike Sherman

Graco Inc.


> On February 5, 2019 at 10:35 AM Doug Nix  wrote:
> 
> Colleagues,
> 
> I had a question come my way yesterday that I need a little help with. 
> Here’s the question:
> 
> 
> > > I have a customer that produces X-ray equipment. The FDA requires 
> that the door that gives access to the X-ray source must have an interlock 
> with a ‘knife-edge and finger stock’ type connection.  Also the FDA mentions 
> that interlocks should be of conventional design. What is understood by 
> “conventional design”? 
> > 
> > > 
> My reading on this requirement is that any conventional electromechanical 
> interlocking device like this:
> [Image result for keyed interlock switch images]
> will meet the basic requirements as described by the FDA as “knife-edge 
> and fingerstock” connection, but I am concerned that this may not be at all 
> what is meant. 
> 
> As always, any guidance you can offer will be welcomed and appreciated!
> 
> Best,
>  
> Doug Nix
> d...@ieee.org mailto:d...@ieee.org
> +1 (519) 729-5704
> 
> 


 

> -
> 
> 
> 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 
> mailto: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 mailto:sdoug...@ieee.org >
> Mike Cantwell mailto:mcantw...@ieee.org >
> 
> For policy questions, send mail to:
> Jim Bacher mailto:j.bac...@ieee.org >
> David Heald mailto:dhe...@gmail.com >
> 


 

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Re: [PSES] UK Gov Using The UKCA Mark

[Dennis Ward]

Correct.  Mommas kitchen is not acceptable place to test
SDOC requirements are listed in KDB896810D01 SDoC v01r01.  There are also 
general requirements for any testing of unintentional devices that must be met.
For example”
While an accredited lab is not required. Section 15.31(a)(4) reminds the party 
responsible that testing of any unintentional radiator is to be done IAW C63.4 
(excluding certain sections). This section also instructs that, if using the 
alternate method of 15.109(g)(2) must also be tested using C63.4
C63.4:2014 requires that any testing performed to its method must meet the NSA 
requirements; also, measurement antennas must be calibrated to meet the 
requirements of C63.5 latest edition and the site, must also follow the 
requirements for site validation etc.
So, while not requiring to be listed or accredited, the test site must be able 
to show that it meets all of the stated requirements.
Thanks


Dennis Ward
This communication and its attachements contain information from PCTEST 
Engineering Laboratory, Inc., and is intended 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.


From: Michael Derby 
Sent: Tuesday, February 5, 2019 3:15 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

Anyone with a test site that meets the requirements of ANSI C63.4.☺

Michael.


From: Charlie Blackham [mailto:char...@sulisconsultants.com]
Sent: 05 February 2019 10:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

Glyn

For sDoC... there is no requirement to be accredited, nor listed on the FCC 
website.   So, anyone can do sDoC testing.

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: Payne, Glyn 
<0d283c0acebb-dmarc-requ...@listserv.ieee.org>
Sent: 05 February 2019 10:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

Hi John,

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

Regards,

Glyn Payne

Validation and Compliance Engineer

Solid State Logic - UK Headquarters

www.solidstatelogic.com

Facebook : 
Twitter : 
Youtube

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK

t: +44 1865 664894 | m: +44 7989 163937


From: John Woodgate mailto:j...@woodjohn.uk>>
Reply-To: John Woodgate mailto:j...@woodjohn.uk>>
Date: Tuesday, 5 February 2019 at 10:23
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: Re: [PSES] UK Gov Using The UKCA Mark


Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world.

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk

Rayleigh, Essex UK
On 2019-02-05 09:59, Scott Xe wrote:
I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it?

Regards,

Scott


On Tue, 5 Feb 2019 at 01:51, Kapur, Ken 
mailto:ken.ka...@thermofisher.com>> wrote:
Hi John,
These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any 

Re: [PSES] [BULK] [PSES] Economical operator name & postal address on EEEproducts

[Scott Aldous]

Hi Scott,

I echo Brian's recommendation to read the relevant sections of the Blue
Guide (2016 version is the latest I believe). You can download it here
.
See section 4.2 on Traceability. It has a detailed description of
obligations of different economic operators with regard to identification
for market surveillance authorities. This section references 768/2008/EC
,
which outlines obligations (see Articles R2, R3 and R4 in Annex I).

On Tue, Feb 5, 2019 at 2:15 AM John Woodgate  wrote:

> The responsibilities of importers and authorized representative specified
> in Directives and Regulations are insufficient to qualify as 'responsible
> person', because the 'responsible person' has to know that no changes have
> been made to the product that would affect its compliance. In other words,
> that person must have access to all the manufacturing data for the product.
>
> Best wishes
> John Woodgate OOO-Own Opinions Only
> J M Woodgate and Associates www.woodjohn.uk
> Rayleigh, Essex UK
>
> On 2019-02-05 09:44, Scott Xe wrote:
>
> Dear Brian,
>
>
>
> Thanks for your useful info!  Must the responsible person be in EU/EEA
> countries?  Otherwise the responsible person will fall into the importers
> or authorized resprentatives who is in EU/EEA countries?
>
>
>
> Regards,
>
>
>
> Scott
>
>
>
>
>
>
>
>
>
> Scott,
>
>
>
> The short answer to your question is, the name and address of the
> responsible party for placing a product on the EU market is required to be
> on the products.  EU documents often refer to the responsible party as the
> “Manufacturer” even though the responsible party may not have manufactured
> the product.
>
>
>
> Read the “Blue Guide” on the implementation of the EU products rules
> 2016/C 272/01 (unless there is a newer version).  It does a good job
> explaining the many possible roles and players under the New Legislative
> Form.
>
>
>
> The Other Brian
>
>
>
> *From:* Scott Xe [mailto:scott...@gmail.com ]
> *Sent:* Saturday, February 02, 2019 3:19 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [BULK] [PSES] Economical operator name & postal address on EEE
> products
> *Importance:* Low
>
>
>
> Regarding the name & address on EEE products in EU market, should they be
> the manufacturers, importers or authorized representatives and which
> regulation does call for it?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
>
>
> -
> 
>
> 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 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>
> *LECO Corporation Notice:* This communication may contain confidential
> information intended for the named recipient(s) only. If you received this
> by mistake, please destroy it and notify us of the error. Thank you.
>
>
> -
> 
>
> 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 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>
> -
> 
>
> 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] A question about FDA language and interlocking devices

[Doug Nix]

Colleagues,

I had a question come my way yesterday that I need a little help with. Here’s 
the question:

> I have a customer that produces X-ray equipment. The FDA requires that the 
> door that gives access to the X-ray source must have an interlock with a 
> ‘knife-edge and finger stock’ type connection.  Also the FDA mentions that 
> interlocks should be of conventional design. What is understood by 
> “conventional design”? 

My reading on this requirement is that any conventional electromechanical 
interlocking device like this:

will meet the basic requirements as described by the FDA as “knife-edge and 
fingerstock” connection, but I am concerned that this may not be at all what is 
meant. 

As always, any guidance you can offer will be welcomed and appreciated!

Best,
 
Doug Nix
d...@ieee.org
+1 (519) 729-5704


-

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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] UK Gov Using The UKCA Mark

[McBurney, Ian]

Hello Michael.

Am I right in believing that you can now affix the FCC logo to products when 
using the sDoc scheme?

Kind regards;

Ian McBurney
Lead Compliance Engineer
Allen & Heath Ltd.
Kernick Industrial estate,
Penryn,
Cornwall. TR10 9LU. UK.
Tel: 01326 372070
Email: ian.mcbur...@allen-heath.com

From: Michael Derby 
Sent: 05 February 2019 11:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

Anyone with a test site that meets the requirements of ANSI C63.4.☺

Michael.


From: Charlie Blackham [mailto:char...@sulisconsultants.com]
Sent: 05 February 2019 10:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

Glyn

For sDoC... there is no requirement to be accredited, nor listed on the FCC 
website.   So, anyone can do sDoC testing.

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: Payne, Glyn 
<0d283c0acebb-dmarc-requ...@listserv.ieee.org>
Sent: 05 February 2019 10:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

Hi John,

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

Regards,

Glyn Payne

Validation and Compliance Engineer

Solid State Logic - UK Headquarters

www.solidstatelogic.com

Facebook : 
Twitter : 
Youtube

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK

t: +44 1865 664894 | m: +44 7989 163937


From: John Woodgate mailto:j...@woodjohn.uk>>
Reply-To: John Woodgate mailto:j...@woodjohn.uk>>
Date: Tuesday, 5 February 2019 at 10:23
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: Re: [PSES] UK Gov Using The UKCA Mark


Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world.

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk

Rayleigh, Essex UK
On 2019-02-05 09:59, Scott Xe wrote:
I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it?

Regards,

Scott


On Tue, 5 Feb 2019 at 01:51, Kapur, Ken 
mailto:ken.ka...@thermofisher.com>> wrote:
Hi John,
These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any relabeling to happen will definitely 
take a lot of time.  Hopefully, there will be no new testing and existing 
standards would be accepted.

Will there be an 18 month transition? Will there be a different set of 
requirements for products shipping EU to UK versus from other countries?


Best Regards,
Ken Kapur
Director, Compliance
Thermo Fisher Scientific
Mobile: 408-685-1454



From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Monday, February 04, 2019 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.


We need to get a Mutual Recognition Agreement as soon as possible. I'm 
surprised that the UK Gov document doesn't even mention the possibility. It 
ought to be very easy, because on March 28 the UK NBs were accredited to EU and 
they didn't suddenly become incompetent on March 29. The problem is pure petty 
bureaucracy (and spite!).

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 

Re: [PSES] Economical operator name & postal address on EEEproducts

[Kunde, Brian]

Scott,

Go to this link:
https://ec.europa.eu/growth/content/%E2%80%98blue-guide%E2%80%99-implementation-eu-product-rules-0_en

At the bottom of the page, click on “BLUE GUIDE 2016”. It should download the 
document in .pdf format.

Go to page 30 which should be section 3.1 on “MANUFACTURER”.

There is a lot of good information in this document. As I said, the word 
“Manufacturer” is given to the responsible person (natural or legal). As such, 
the Manufacturer has many responsibilities.

“The manufacturer has ultimate responsibility for the conformity of the product 
to the applicable Union harmonisation legislation, whether he designed and 
manufactured the product himself or is considered as a manufacturer because the 
product is placed on the market under his name or trademark.”

“The manufacturer is obliged to understand both the design and construction of 
the product to be able to take the responsibility for the product being in 
compliance with all provisions of the relevant Union harmonisation legislation. 
This applies equally to situations where the manufacturer designs, 
manufactures, packs and labels the product himself, as to situations where some 
or all of these operations are carried out by a subcontractor. The manufacturer 
needs to have the relevant information to demonstrate compliance of the product 
at its disposal.”

“Union harmonisation legislation does not require the manufacturer to be 
established in the European Union. Thus, when placing a product on the Union 
market, the responsibilities of a manufacturer are the same whether he is 
established outside the European Union or in a Member State.”

Under 3.1 subpart 5 regarding the Name and Address on the product, “The single 
contact point may not necessarily be located in the Member State where the 
product is made available on the market;”

Also read the section 3.3 on IMPORTER.  The importer takes on the role of 
Manufacturer (and responsibilities of) when they place a product from a “third 
country” on the EU market.  In some cases, the name and address of the Importer 
should be added to the product in addition to the original third country 
manufacturer.

I also highly recommend reading section 3.2.AUTHORISED REPRESENTATIVE.  You 
will find that having a AR is the choice of the Manufacturer and not required 
even for Manufacturers outside of the EU.  The AR is often mistaken as the 
“person responsible for compiling the Technical Documents” as required by some 
Directives such as the Machinery Directive.  The ‘person’ can be anyone and 
does not have to be an AR.

Hope this information was helpful.

The Other Brian

From: Scott Xe [mailto:scott...@gmail.com]
Sent: Tuesday, February 05, 2019 4:44 AM
To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [BULK] [PSES] Economical operator name & postal address on 
EEEproducts
Importance: Low

Dear Brian,

Thanks for your useful info!  Must the responsible person be in EU/EEA 
countries?  Otherwise the responsible person will fall into the importers or 
authorized resprentatives who is in EU/EEA countries?

Regards,

Scott




Scott,

The short answer to your question is, the name and address of the responsible 
party for placing a product on the EU market is required to be on the products. 
 EU documents often refer to the responsible party as the “Manufacturer” even 
though the responsible party may not have manufactured the product.

Read the “Blue Guide” on the implementation of the EU products rules 2016/C 
272/01 (unless there is a newer version).  It does a good job explaining the 
many possible roles and players under the New Legislative Form.

The Other Brian

From: Scott Xe [mailto:scott...@gmail.com]
Sent: Saturday, February 02, 2019 3:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [BULK] [PSES] Economical operator name & postal address on EEE products
Importance: Low

Regarding the name & address on EEE products in EU market, should they be the 
manufacturers, importers or authorized representatives and which regulation 
does call for it?

Thanks and regards,

Scott

-


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 
mailto: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 mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcantw...@ieee.org>>

For policy 

Re: [PSES] UK Gov Using The UKCA Mark

[Michael Derby]

Hi Ian,

 

That’s correct.   In the past, the FCC logo was mandatory if you followed the 
old DoC route, and forbidden if you did not follow the old DoC route.

Many people got that wrong.   

 

So nowadays, if you follow the sDoC route, the logo is now optional for you.

 

Thanks,

 

Michael.

 

 

From: McBurney, Ian [mailto:ian.mcbur...@allen-heath.com] 
Sent: 05 February 2019 13:16
To: Michael Derby ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] UK Gov Using The UKCA Mark

 

Hello Michael.

 

Am I right in believing that you can now affix the FCC logo to products when 
using the sDoc scheme?

 

Kind regards;

 

Ian McBurney

Lead Compliance Engineer

Allen & Heath Ltd.

Kernick Industrial estate,

Penryn,

Cornwall. TR10 9LU. UK.

Tel: 01326 372070

Email: ian.mcbur...@allen-heath.com  

 

From: Michael Derby mailto:micha...@acbcert.com> > 
Sent: 05 February 2019 11:15
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Anyone with a test site that meets the requirements of ANSI C63.4.:)

 

Michael.

 

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 05 February 2019 10:52
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Glyn

 

For sDoC... there is no requirement to be accredited, nor listed on the FCC 
website.   So, anyone can do sDoC testing.

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  

 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Payne, Glyn <0d283c0acebb-dmarc-requ...@listserv.ieee.org 
 > 
Sent: 05 February 2019 10:41
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Hi John,

 

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

 

Regards,

 

Glyn Payne

 

Validation and Compliance Engineer

 

Solid State Logic - UK Headquarters

 

  www.solidstatelogic.com

 

  Facebook :  
 Twitter :  
 Youtube

 

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK 

 

t: +44 1865 664894 | m: +44 7989 163937

 

 

From: John Woodgate mailto:j...@woodjohn.uk> >
Reply-To: John Woodgate mailto:j...@woodjohn.uk> >
Date: Tuesday, 5 February 2019 at 10:23
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world. 

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-02-05 09:59, Scott Xe wrote:

I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it? 

 

Regards,

 

Scott

 

 

On Tue, 5 Feb 2019 at 01:51, Kapur, Ken mailto:ken.ka...@thermofisher.com> > wrote:

Hi John,

These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any relabeling to happen will definitely 
take a lot of time.  Hopefully, there will be no new testing and existing 
standards would be accepted.

 

Will there be an 18 month transition? Will there be a different set of 
requirements for products shipping EU to UK versus from other countries?

 

 

Best Regards,

Ken Kapur

Director, Compliance

Thermo Fisher Scientific

Mobile: 408-685-1454

 

 

 

From: John Woodgate [mailto:j...@woodjohn.uk  ] 
Sent: Monday, February 04, 2019 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] UK Gov Using The UKCA 

Re: [PSES] UK Gov Using The UKCA Mark

[Michael Derby]

Anyone with a test site that meets the requirements of ANSI C63.4.:)

 

Michael.

 

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 05 February 2019 10:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Glyn

 

For sDoC... there is no requirement to be accredited, nor listed on the FCC 
website.   So, anyone can do sDoC testing.

 

Regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  

 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Payne, Glyn <0d283c0acebb-dmarc-requ...@listserv.ieee.org 
 > 
Sent: 05 February 2019 10:41
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Hi John,

 

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

 

Regards,

 

Glyn Payne

 

Validation and Compliance Engineer

 

Solid State Logic - UK Headquarters

 

  www.solidstatelogic.com

 

  Facebook :  
 Twitter :  
 Youtube

 

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK 

 

t: +44 1865 664894 | m: +44 7989 163937

 

 

From: John Woodgate mailto:j...@woodjohn.uk> >
Reply-To: John Woodgate mailto:j...@woodjohn.uk> >
Date: Tuesday, 5 February 2019 at 10:23
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world. 

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-02-05 09:59, Scott Xe wrote:

I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it? 

 

Regards,

 

Scott

 

 

On Tue, 5 Feb 2019 at 01:51, Kapur, Ken mailto:ken.ka...@thermofisher.com> > wrote:

Hi John,

These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any relabeling to happen will definitely 
take a lot of time.  Hopefully, there will be no new testing and existing 
standards would be accepted.

 

Will there be an 18 month transition? Will there be a different set of 
requirements for products shipping EU to UK versus from other countries?

 

 

Best Regards,

Ken Kapur

Director, Compliance

Thermo Fisher Scientific

Mobile: 408-685-1454

 

 

 

From: John Woodgate [mailto:j...@woodjohn.uk  ] 
Sent: Monday, February 04, 2019 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

 

We need to get a Mutual Recognition Agreement as soon as possible. I'm 
surprised that the UK Gov document doesn't even mention the possibility. It 
ought to be very easy, because on March 28 the UK NBs were accredited to EU and 
they didn't suddenly become incompetent on March 29. The problem is pure petty 
bureaucracy (and spite!).

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk 

 
Rayleigh, Essex UK

On 2019-02-04 14:37, Mark Bailey wrote:

All,

 

Just received the following link from a colleague, using the UKCA marking if 
the UK leaves the EU without a deal. Links to part of the “[PSES] Brexit 

Re: [PSES] UK Gov Using The UKCA Mark

[Michael Derby]

UK-USA talks happened very quickly after the referendum, so they are quite 
advanced I think.

 

Michael.

 

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: 05 February 2019 11:06
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

I don't know. Maybe the UK has an MRA with the US, independent of any EU-US MRA.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-02-05 10:40, Payne, Glyn wrote:

Hi John,

 

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

 

Regards,

 

Glyn Payne

 

Validation and Compliance Engineer

 

Solid State Logic - UK Headquarters

 

  www.solidstatelogic.com

 

  Facebook :  
 Twitter :  
 Youtube

 

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK 

 

t: +44 1865 664894 | m: +44 7989 163937

 

 

From: John Woodgate   
Reply-To: John Woodgate   
Date: Tuesday, 5 February 2019 at 10:23
To:   
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world. 

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-02-05 09:59, Scott Xe wrote:

I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it? 

 

Regards,

 

Scott

 

 

On Tue, 5 Feb 2019 at 01:51, Kapur, Ken mailto:ken.ka...@thermofisher.com> > wrote:

Hi John,

These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any relabeling to happen will definitely 
take a lot of time.  Hopefully, there will be no new testing and existing 
standards would be accepted.

 

Will there be an 18 month transition? Will there be a different set of 
requirements for products shipping EU to UK versus from other countries?

 

 

Best Regards,

Ken Kapur

Director, Compliance

Thermo Fisher Scientific

Mobile: 408-685-1454

 

 

 

From: John Woodgate [mailto:j...@woodjohn.uk  ] 
Sent: Monday, February 04, 2019 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

 

We need to get a Mutual Recognition Agreement as soon as possible. I'm 
surprised that the UK Gov document doesn't even mention the possibility. It 
ought to be very easy, because on March 28 the UK NBs were accredited to EU and 
they didn't suddenly become incompetent on March 29. The problem is pure petty 
bureaucracy (and spite!).

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk 

 
Rayleigh, Essex UK

On 2019-02-04 14:37, Mark Bailey wrote:

All,

 

Just received the following link from a colleague, using the UKCA marking if 
the UK leaves the EU without a deal. Links to part of the “[PSES] Brexit 
requirements for UK manufacturers” a couple of weeks ago.

 

https://www.gov.uk/government/publications/prepare-to-use-the-ukca-mark-after-brexit/using-the-ukca-marking-if-the-uk-leaves-the-eu-without-a-deal
 

Re: [PSES] UK Gov Using The UKCA Mark

[Payne, Glyn]

Thanks Michael.

 

From: Michael Derby 
Reply-To: Michael Derby 
Date: Tuesday, 5 February 2019 at 11:14
To: 
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

UK-USA talks happened very quickly after the referendum, so they are quite 
advanced I think.

 

Michael.

 

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: 05 February 2019 11:06
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

I don't know. Maybe the UK has an MRA with the US, independent of any EU-US MRA.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-02-05 10:40, Payne, Glyn wrote:

Hi John,

 

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

 

Regards,

 

Glyn Payne

 

Validation and Compliance Engineer

 

Solid State Logic - UK Headquarters

 

www.solidstatelogic.com

 

Facebook : Twitter : Youtube

 

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK 

 

t: +44 1865 664894 | m: +44 7989 163937

 

 

From: John Woodgate 
Reply-To: John Woodgate 
Date: Tuesday, 5 February 2019 at 10:23
To: 
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world. 

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-02-05 09:59, Scott Xe wrote:

I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it? 

 

Regards,

 

Scott

 

 

On Tue, 5 Feb 2019 at 01:51, Kapur, Ken  wrote:

Hi John,

These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any relabeling to happen will definitely 
take a lot of time.  Hopefully, there will be no new testing and existing 
standards would be accepted.

 

Will there be an 18 month transition? Will there be a different set of 
requirements for products shipping EU to UK versus from other countries?

 

 

Best Regards,

Ken Kapur

Director, Compliance

Thermo Fisher Scientific

Mobile: 408-685-1454

 

 

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: Monday, February 04, 2019 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

 

We need to get a Mutual Recognition Agreement as soon as possible. I'm 
surprised that the UK Gov document doesn't even mention the possibility. It 
ought to be very easy, because on March 28 the UK NBs were accredited to EU and 
they didn't suddenly become incompetent on March 29. The problem is pure petty 
bureaucracy (and spite!).
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-02-04 14:37, Mark Bailey wrote:

All,

 

Just received the following link from a colleague, using the UKCA marking if 
the UK leaves the EU without a deal. Links to part of the “[PSES] Brexit 
requirements for UK manufacturers” a couple of weeks ago.

 

https://www.gov.uk/government/publications/prepare-to-use-the-ukca-mark-after-brexit/using-the-ukca-marking-if-the-uk-leaves-the-eu-without-a-deal

 

BR

Mark Bailey

IMPORTANT NOTICE: This e-mail message is intended to be received only by 
persons entitled to receive the confidential information it may contain. E-mail 
messages to clients of Telensa may contain information that is confidential and 
legally privileged. Please do not read, copy, forward, or store this message 
unless you are an intended recipient of it. If you have received this message 
in error, please forward it to the sender and delete it completely from your 
computer system. -


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 


All emc-pstc 

Re: [PSES] UK Gov Using The UKCA Mark

[Charlie Blackham]

Glyn

For sDoC... there is no requirement to be accredited, nor listed on the FCC 
website.   So, anyone can do sDoC testing.

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: Payne, Glyn <0d283c0acebb-dmarc-requ...@listserv.ieee.org>
Sent: 05 February 2019 10:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

Hi John,

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

Regards,

Glyn Payne

Validation and Compliance Engineer

Solid State Logic - UK Headquarters

www.solidstatelogic.com

Facebook : 
Twitter : 
Youtube

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK

t: +44 1865 664894 | m: +44 7989 163937


From: John Woodgate mailto:j...@woodjohn.uk>>
Reply-To: John Woodgate mailto:j...@woodjohn.uk>>
Date: Tuesday, 5 February 2019 at 10:23
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Subject: Re: [PSES] UK Gov Using The UKCA Mark


Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world.

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk

Rayleigh, Essex UK
On 2019-02-05 09:59, Scott Xe wrote:
I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it?

Regards,

Scott


On Tue, 5 Feb 2019 at 01:51, Kapur, Ken 
mailto:ken.ka...@thermofisher.com>> wrote:
Hi John,
These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any relabeling to happen will definitely 
take a lot of time.  Hopefully, there will be no new testing and existing 
standards would be accepted.

Will there be an 18 month transition? Will there be a different set of 
requirements for products shipping EU to UK versus from other countries?


Best Regards,
Ken Kapur
Director, Compliance
Thermo Fisher Scientific
Mobile: 408-685-1454



From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Monday, February 04, 2019 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.


We need to get a Mutual Recognition Agreement as soon as possible. I'm 
surprised that the UK Gov document doesn't even mention the possibility. It 
ought to be very easy, because on March 28 the UK NBs were accredited to EU and 
they didn't suddenly become incompetent on March 29. The problem is pure petty 
bureaucracy (and spite!).

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates 
www.woodjohn.uk

Rayleigh, Essex UK
On 2019-02-04 14:37, Mark Bailey wrote:
All,

Just received the following link from a colleague, using the UKCA marking if 
the UK leaves the EU without a deal. Links to part of the “[PSES] Brexit 
requirements for UK manufacturers” a couple of weeks ago.

Re: [PSES] UK Gov Using The UKCA Mark

[John Woodgate]

I don't know. Maybe the UK has an MRA with the US, independent of any 
EU-US MRA.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-02-05 10:40, Payne, Glyn wrote:


Hi John,

Won’t the lack of a MRA with the US effect the FCC SDoC route when 
getting emission scans done in labs that are accredited by UKAS?


Regards,

Glyn Payne

Validation and Compliance Engineer

**

*Solid State Logic - UK Headquarters*

www.solidstatelogic.com 

Facebook  : Twitter 
 : Youtube 



25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK

t: +44 1865 664894 | m: +44 7989 163937

*From: *John Woodgate 
*Reply-To: *John Woodgate 
*Date: *Tuesday, 5 February 2019 at 10:23
*To: *
*Subject: *Re: [PSES] UK Gov Using The UKCA Mark

Goods arriving in the UK should not be in trouble. UK recognizes the 
CE Mark on March 29 and there is no reason to stop recognizing it on 
March 30.  Goods leaving the UK for the EU are in a different position 
IF a UK-only Notified Body is involved in determining compliance. For 
many products, there is no need for Notified Body involvement, and 
many Notified Bodies are not UK-only but widely-based in the western 
world.


This scenario applies only if there is a 'no-deal' Brexit, and in that 
case it is up to the UK and EU to decide /independently/ what marking 
to accept and for how long.  We can hope that common sense will 
prevail, but it might not.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk  
Rayleigh, Essex UK

On 2019-02-05 09:59, Scott Xe wrote:

I fully agree on the Ken's concern. How can the manufactures
change the logos and relevant documents of the goods arrive in the
UK post Brexit of 30/03/2019?  UK will suffer short of goods in
next few months.  Does UK plan to cope with it?

Regards,

Scott

On Tue, 5 Feb 2019 at 01:51, Kapur, Ken
mailto:ken.ka...@thermofisher.com>>
wrote:

Hi John,

These new requirements with the UKCA mark will be a
significant burden on industry, if a MRA can be established,
it would help significantly. There are still lot’s of
questions about the UKCA marking and how it gets implemented. 
Considering a no-deal Brexit: getting any relabeling to happen
will definitely take a lot of time.  Hopefully, there will be
no new testing and existing standards would be accepted.

Will there be an 18 month transition? Will there be a
different set of requirements for products shipping EU to UK
versus from other countries?

Best Regards,

*Ken Kapur*

Director, Compliance

Thermo Fisher Scientific

Mobile: 408-685-1454

*From:*John Woodgate [mailto:j...@woodjohn.uk
]
*Sent:* Monday, February 04, 2019 8:42 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG

*Subject:* Re: [PSES] UK Gov Using The UKCA Mark

*CAUTION:*This email originated from outside of the
organization. Do not click links or open attachments unless
you recognize the sender and know the content is safe.

We need to get a Mutual Recognition Agreement as soon as
possible. I'm surprised that the UK Gov document doesn't even
mention the possibility. It ought to be very easy, because on
March 28 the UK NBs were accredited to EU and they didn't
suddenly become incompetent on March 29. The problem is pure
petty bureaucracy (and spite!).

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk



Rayleigh, Essex UK

On 2019-02-04 14:37, Mark Bailey wrote:

All,

Just received the following link from a colleague, using
the UKCA marking if the UK leaves the EU without a deal.
Links to part of the “[PSES] Brexit requirements for UK
manufacturers” a couple of weeks ago.


https://www.gov.uk/government/publications/prepare-to-use-the-ukca-mark-after-brexit/using-the-ukca-marking-if-the-uk-leaves-the-eu-without-a-deal

Re: [PSES] UK Gov Using The UKCA Mark

[Michael Derby]

Hello Glyn,

 

There’s no requirement for a lab to be accredited or listed when performing 
sDoC testing for the FCC (similar to the old Verification requirements).   So, 
it should not affect sDoC testing at all.

 

There is a requirement for a test lab to be accredited and listed for testing 
which will lead to certification, though.   As soon as BREXIT happens (assuming 
it happens), I am sure UKAS will apply for permission to accredit test labs in 
a non-MRA country (the UK).

Presently I believe they cannot apply for permission to do that, because the UK 
is still in the EU at this time.

But as was mentioned before with the MRAs, I’m sure they’ve at least drafted 
their application.   :)

 

 

Michael.

 

 

Michael Derby 

Senior Regulatory Engineer 

Director 

ACB Europe 

 

Join ACB for a training seminar in Copenhagen on 6 and 7 March or Milan on 5 
and 6 June, 2019:  
https://acbcert.com/seminars/2019-Wireless-Approvals-Workshop/2019-Wireless-Approvals-Workshop.html

 

 

Certification Resource for the Wireless Industry 

Web:   www.acbcert.com   

  

e-mail:  micha...@acbcert.com 

Mobile phone:   (+44) 7939 880829   (UK area code) 

Corporate office phone: USA:   (+1) 703 847 4700 

 

 

 

 

 

From: Payne, Glyn [mailto:0d283c0acebb-dmarc-requ...@listserv.ieee.org] 
Sent: 05 February 2019 10:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Hi John,

 

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

 

Regards,

 

Glyn Payne

 

Validation and Compliance Engineer

 

Solid State Logic - UK Headquarters

 

  www.solidstatelogic.com

 

  Facebook :  
 Twitter :  
 Youtube

 

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK 

 

t: +44 1865 664894 | m: +44 7989 163937

 

 

From: John Woodgate mailto:j...@woodjohn.uk> >
Reply-To: John Woodgate mailto:j...@woodjohn.uk> >
Date: Tuesday, 5 February 2019 at 10:23
To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world. 

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk  
Rayleigh, Essex UK

On 2019-02-05 09:59, Scott Xe wrote:

I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it? 

 

Regards,

 

Scott

 

 

On Tue, 5 Feb 2019 at 01:51, Kapur, Ken mailto:ken.ka...@thermofisher.com> > wrote:

Hi John,

These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any relabeling to happen will definitely 
take a lot of time.  Hopefully, there will be no new testing and existing 
standards would be accepted.

 

Will there be an 18 month transition? Will there be a different set of 
requirements for products shipping EU to UK versus from other countries?

 

 

Best Regards,

Ken Kapur

Director, Compliance

Thermo Fisher Scientific

Mobile: 408-685-1454

 

 

 

From: John Woodgate [mailto:j...@woodjohn.uk  ] 
Sent: Monday, February 04, 2019 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

 

We need to get a Mutual Recognition Agreement as soon as possible. I'm 
surprised that the UK Gov document doesn't even mention the possibility. It 
ought to be very easy, because on March 28 the UK NBs were accredited to EU and 
they didn't suddenly become incompetent on March 29. The problem is pure petty 
bureaucracy (and spite!).

Best wishes
John Woodgate OOO-Own Opinions Only
J M 

Re: [PSES] UK Gov Using The UKCA Mark

[Payne, Glyn]

Hi John,

 

Won’t the lack of a MRA with the US effect the FCC SDoC route when getting 
emission scans done in labs that are accredited by UKAS?

 

Regards,

 

Glyn Payne

 

Validation and Compliance Engineer

 

Solid State Logic - UK Headquarters

 

www.solidstatelogic.com

 

Facebook : Twitter : Youtube

 

25 Spring Hill Road | Begbroke | Oxfordshire | OX5 1RU | UK 

 

t: +44 1865 664894 | m: +44 7989 163937

 

 

From: John Woodgate 
Reply-To: John Woodgate 
Date: Tuesday, 5 February 2019 at 10:23
To: 
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

Goods arriving in the UK should not be in trouble. UK recognizes the CE Mark on 
March 29 and there is no reason to stop recognizing it on March 30.  Goods 
leaving the UK for the EU are in a different position IF a UK-only Notified 
Body is involved in determining compliance. For many products, there is no need 
for Notified Body involvement, and many Notified Bodies are not UK-only but 
widely-based in the western world. 

This scenario applies only if there is a 'no-deal' Brexit, and in that case it 
is up to the UK and EU to decide independently what marking to accept and for 
how long.  We can hope that common sense will prevail, but it might not.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-02-05 09:59, Scott Xe wrote:

I fully agree on the Ken's concern.  How can the manufactures change the logos 
and relevant documents of the goods arrive in the UK post Brexit of 30/03/2019? 
 UK will suffer short of goods in next few months.  Does UK plan to cope with 
it? 

 

Regards,

 

Scott

 

 

On Tue, 5 Feb 2019 at 01:51, Kapur, Ken  wrote:

Hi John,

These new requirements with the UKCA mark will be a significant burden on 
industry, if a MRA can be established, it would help significantly. There are 
still lot’s of questions about the UKCA marking and how it gets implemented.  
Considering a no-deal Brexit: getting any relabeling to happen will definitely 
take a lot of time.  Hopefully, there will be no new testing and existing 
standards would be accepted.

 

Will there be an 18 month transition? Will there be a different set of 
requirements for products shipping EU to UK versus from other countries?

 

 

Best Regards,

Ken Kapur

Director, Compliance

Thermo Fisher Scientific

Mobile: 408-685-1454

 

 

 

From: John Woodgate [mailto:j...@woodjohn.uk] 
Sent: Monday, February 04, 2019 8:42 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] UK Gov Using The UKCA Mark

 

CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

 

We need to get a Mutual Recognition Agreement as soon as possible. I'm 
surprised that the UK Gov document doesn't even mention the possibility. It 
ought to be very easy, because on March 28 the UK NBs were accredited to EU and 
they didn't suddenly become incompetent on March 29. The problem is pure petty 
bureaucracy (and spite!).
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-02-04 14:37, Mark Bailey wrote:

All,

 

Just received the following link from a colleague, using the UKCA marking if 
the UK leaves the EU without a deal. Links to part of the “[PSES] Brexit 
requirements for UK manufacturers” a couple of weeks ago.

 

https://www.gov.uk/government/publications/prepare-to-use-the-ukca-mark-after-brexit/using-the-ukca-marking-if-the-uk-leaves-the-eu-without-a-deal

 

BR

Mark Bailey

IMPORTANT NOTICE: This e-mail message is intended to be received only by 
persons entitled to receive the confidential information it may contain. E-mail 
messages to clients of Telensa may contain information that is confidential and 
legally privileged. Please do not read, copy, forward, or store this message 
unless you are an intended recipient of it. If you have received this message 
in error, please forward it to the sender and delete it completely from your 
computer system. -


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 


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-


This message 

Re: [PSES] UK Gov Using The UKCA Mark

[John Woodgate]

Goods arriving in the UK should not be in trouble. UK recognizes the CE 
Mark on March 29 and there is no reason to stop recognizing it on March 
30.  Goods leaving the UK for the EU are in a different position IF a 
UK-only Notified Body is involved in determining compliance. For many 
products, there is no need for Notified Body involvement, and many 
Notified Bodies are not UK-only but widely-based in the western world.


This scenario applies only if there is a 'no-deal' Brexit, and in that 
case it is up to the UK and EU to decide /independently/ what marking to 
accept and for how long.  We can hope that common sense will prevail, 
but it might not.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-02-05 09:59, Scott Xe wrote:
I fully agree on the Ken's concern.  How can the manufactures change 
the logos and relevant documents of the goods arrive in the UK post 
Brexit of 30/03/2019?  UK will suffer short of goods in next few 
months.  Does UK plan to cope with it?


Regards,

Scott


On Tue, 5 Feb 2019 at 01:51, Kapur, Ken > wrote:


Hi John,

These new requirements with the UKCA mark will be a significant
burden on industry, if a MRA can be established, it would help
significantly. There are still lot’s of questions about the UKCA
marking and how it gets implemented.  Considering a no-deal
Brexit: getting any relabeling to happen will definitely take a
lot of time.  Hopefully, there will be no new testing and existing
standards would be accepted.

Will there be an 18 month transition? Will there be a different
set of requirements for products shipping EU to UK versus from
other countries?

Best Regards,

*Ken Kapur*

Director, Compliance

Thermo Fisher Scientific

Mobile: 408-685-1454

*From:*John Woodgate [mailto:j...@woodjohn.uk
]
*Sent:* Monday, February 04, 2019 8:42 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG 
*Subject:* Re: [PSES] UK Gov Using The UKCA Mark

*CAUTION:*This email originated from outside of the organization.
Do not click links or open attachments unless you recognize the
sender and know the content is safe.

We need to get a Mutual Recognition Agreement as soon as possible.
I'm surprised that the UK Gov document doesn't even mention the
possibility. It ought to be very easy, because on March 28 the UK
NBs were accredited to EU and they didn't suddenly become
incompetent on March 29. The problem is pure petty bureaucracy
(and spite!).

Best wishes

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk  


Rayleigh, Essex UK

On 2019-02-04 14:37, Mark Bailey wrote:

All,

Just received the following link from a colleague, using the
UKCA marking if the UK leaves the EU without a deal. Links to
part of the “[PSES] Brexit requirements for UK manufacturers”
a couple of weeks ago.


https://www.gov.uk/government/publications/prepare-to-use-the-ukca-mark-after-brexit/using-the-ukca-marking-if-the-uk-leaves-the-eu-without-a-deal



BR

Mark Bailey

IMPORTANT NOTICE: This e-mail message is intended to be
received only by persons entitled to receive the confidential
information it may contain. E-mail messages to clients of
Telensa may contain information that is confidential and
legally privileged. Please do not read, copy, forward, or
store this message unless you are an intended recipient of it.
If you have received this message in error, please forward it
to the sender and delete it completely from your computer
system. -


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 mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web
at: http://www.ieee-pses.org/emc-pstc.html

Re: [PSES] [BULK] [PSES] Economical operator name & postal address on EEEproducts

[John Woodgate]

The responsibilities of importers and authorized representative 
specified in Directives and Regulations are insufficient to qualify as 
'responsible person', because the 'responsible person' has to know that 
no changes have been made to the product that would affect its 
compliance. In other words, that person must have access to all the 
manufacturing data for the product.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-02-05 09:44, Scott Xe wrote:


Dear Brian,

Thanks for your useful info!  Must the responsible person be in EU/EEA 
countries?  Otherwise the responsible person will fall into the 
importers or authorized resprentatives who is in EU/EEA countries?


Regards,

Scott

Scott,

The short answer to your question is, the name and address of the 
responsible party for placing a product on the EU market is required 
to be on the products.  EU documents often refer to the responsible 
party as the “Manufacturer” even though the responsible party may not 
have manufactured the product.


Read the “Blue Guide” on the implementation of the EU products rules 
2016/C 272/01 (unless there is a newer version).  It does a good job 
explaining the many possible roles and players under the New 
Legislative Form.


The Other Brian

*From:*Scott Xe [mailto:scott...@gmail.com]
*Sent:* Saturday, February 02, 2019 3:19 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [BULK] [PSES] Economical operator name & postal address on 
EEE products

*Importance:* Low

Regarding the name & address on EEE products in EU market, should they 
be the manufacturers, importers or authorized representatives and 
which regulation does call for it?


Thanks and regards,

Scott

-


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 mailto: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:
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  *LECO Corporation Notice:*This communication may contain
  confidential information intended for the named recipient(s)
  only. If you received this by mistake, please destroy it and
  notify us of the error. Thank you.

**

-


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 mailto: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 mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcantw...@ieee.org>>

For policy questions, send mail to:
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David Heald mailto: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 

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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] UK Gov Using The UKCA Mark

[Scott Xe]

I fully agree on the Ken's concern.  How can the manufactures change the
logos and relevant documents of the goods arrive in the UK post Brexit of
30/03/2019?  UK will suffer short of goods in next few months.  Does UK
plan to cope with it?

Regards,

Scott


On Tue, 5 Feb 2019 at 01:51, Kapur, Ken  wrote:

> Hi John,
>
> These new requirements with the UKCA mark will be a significant burden on
> industry, if a MRA can be established, it would help significantly. There
> are still lot’s of questions about the UKCA marking and how it gets
> implemented.  Considering a no-deal Brexit: getting any relabeling to
> happen will definitely take a lot of time.  Hopefully, there will be no new
> testing and existing standards would be accepted.
>
>
>
> Will there be an 18 month transition? Will there be a different set of
> requirements for products shipping EU to UK versus from other countries?
>
>
>
>
>
> Best Regards,
>
> *Ken Kapur*
>
> Director, Compliance
>
> Thermo Fisher Scientific
>
> Mobile: 408-685-1454
>
>
>
>
>
>
>
> *From:* John Woodgate [mailto:j...@woodjohn.uk]
> *Sent:* Monday, February 04, 2019 8:42 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] UK Gov Using The UKCA Mark
>
>
>
> *CAUTION:* This email originated from outside of the organization. Do not
> click links or open attachments unless you recognize the sender and know
> the content is safe.
>
>
>
> We need to get a Mutual Recognition Agreement as soon as possible. I'm
> surprised that the UK Gov document doesn't even mention the possibility. It
> ought to be very easy, because on March 28 the UK NBs were accredited to EU
> and they didn't suddenly become incompetent on March 29. The problem is
> pure petty bureaucracy (and spite!).
>
> Best wishes
>
> John Woodgate OOO-Own Opinions Only
>
> J M Woodgate and Associates www.woodjohn.uk 
> 
>
> Rayleigh, Essex UK
>
> On 2019-02-04 14:37, Mark Bailey wrote:
>
> All,
>
>
>
> Just received the following link from a colleague, using the UKCA marking
> if the UK leaves the EU without a deal. Links to part of the “[PSES] Brexit
> requirements for UK manufacturers” a couple of weeks ago.
>
>
>
>
> https://www.gov.uk/government/publications/prepare-to-use-the-ukca-mark-after-brexit/using-the-ukca-marking-if-the-uk-leaves-the-eu-without-a-deal
> 
>
>
>
> BR
>
> Mark Bailey
>
> IMPORTANT NOTICE: This e-mail message is intended to be received only by
> persons entitled to receive the confidential information it may contain.
> E-mail messages to clients of Telensa may contain information that is
> confidential and legally privileged. Please do not read, copy, forward, or
> store this message unless you are an intended recipient of it. If you have
> received this message in error, please forward it to the sender and delete
> it completely from your computer system. -
> 
>
> 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)
> 

Re: [PSES] [BULK] [PSES] Economical operator name & postal address on EEEproducts

[Scott Xe]

Dear Brian,

Thanks for your useful info!  Must the responsible person be in EU/EEA 
countries?  Otherwise the responsible person will fall into the importers or 
authorized resprentatives who is in EU/EEA countries?

Regards,

Scott




Scott,

The short answer to your question is, the name and address of the responsible 
party for placing a product on the EU market is required to be on the products. 
 EU documents often refer to the responsible party as the “Manufacturer” even 
though the responsible party may not have manufactured the product.  

Read the “Blue Guide” on the implementation of the EU products rules 2016/C 
272/01 (unless there is a newer version).  It does a good job explaining the 
many possible roles and players under the New Legislative Form.  

The Other Brian

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: Saturday, February 02, 2019 3:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [BULK] [PSES] Economical operator name & postal address on EEE products
Importance: Low

Regarding the name & address on EEE products in EU market, should they be the 
manufacturers, importers or authorized representatives and which regulation 
does call for it?

Thanks and regards,

Scott

-

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 

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 
Mike Cantwell  
For policy questions, send mail to:
Jim Bacher 
David Heald  

LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you. 


-

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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: