Re: [PSES] CB Philosophy Questions
Subject: [PSES] CB Philosophy Questions Hello All, Thanks to everyone who responded, especially for the sage advice. Of the various facets of the Regulatory Compliance field, I find that international approvals seem to be the most difficult. Best Regards, Brian Ceresney Regulatory Lead Delta-Q Technologies Corp. Phone: +1.604.566.8827 Note: The comments here represent my opinions, not those of Delta-Q Technologies. . - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.orgmailto:sdoug...@ieee.org Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CB Philosophy Questions
I know that for the Chinese CCC mark the CQC accredited labs will not accept a generic “various” description for their critical components lists. What we have done in our CB reports to satisfy them is list a component as “Model XYZ or equivalent” in the CB critical components list. The China lab will still insist on only listing the specific part #, like Model XYZ, in their critical components list but at least now they don’t hassle us over the descriptions in the CB report critical components list. They even required us to be specific about the pcb Mfg on the critical components list which is usually accepted as being listed as “Various” by other countries. From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] Sent: Thursday, April 30, 2015 10:17 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CB Philosophy Questions All, You may want to reach out to the National Committee in your Country, For the US National Committee (USNC), the best point of contact would be Joel Solis at NEMA who serves as the Secretary. They might be able to bring this up at a future CB Scheme meeting and encourage all countries to establish similar guidelines for mentioning alternate components in CB reports. Brian is correct about the NRTL Program removing component standards from its list of appropriate test standards. The NRTL Program was never intended to include components as it only applies to end products used in the workplace, but over the years, some predominantly component standards were added to the list, and OSHA is in the process of removing those standards. That said, NRTLs will still be allowed to accept component certifications from others when evaluating end products. Kevin Robinson a.k.a The OSHA NRTL Director Guy :-) robinson.ke...@dol.govmailto:robinson.ke...@dol.gov On Thu, Apr 30, 2015 at 9:21 PM, Brian Oconnell oconne...@tamuracorp.commailto:oconne...@tamuracorp.com wrote: Doug, Thanks, will look for this stuff. The only stuff seen to date for component evaluation is in UL PAGs, CSA informs, and the IECEE CTL stuff. Are these component acceptance 'guides' part of the National Differences in a TRF, or regulatory law administered by the state? According to the OSHA guy that is the NRTL program director, they are in process of removing component standards from their official listing (do a search on the EMC-PSTC listserv archives for his comments). Do not understand Having a CB report is not a foregone guarantee that it will always be accepted. Do you mean that the TRF was rejected because of poor component descriptions, or that changes to the C/C table in the TRF was rejected, or something else? Brian -Original Message- From: dougp01 [mailto:doug...@gmail.commailto:doug...@gmail.com] Sent: Thursday, April 30, 2015 5:53 PM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CB Philosophy Questions Brian I suggest you reference the IECEE website and read through the component acceptance requirements for each target country, including the USA. I haven't checked but there may also be such a document for the -2-29 you mention. These can be found in the same general area as the national differences documents. Both are interesting reading. If you are not able to access these contact your certifying agency and they should be willing to supply copies. As for what is typical in each country, I have learned that this is variable. In general the office tasked with reviewing and accepting your CB report definitely feels they have the authority to do as they please. And to a large extent this is true. Having a CB report is not a foregone guarantee that it will always be accepted. Regards, - doug Douglas Powell http://www.linkedin.com/in/dougp01 Original Message From: Brian Oconnell Sent: Thursday, April 30, 2015 6:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Brian Oconnell Subject: Re: [PSES] CB Philosophy Questions In both procedural controls and scoped test standards, North America (NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar where state-enforced codes do not contradict the scoped standard. It has been several years since the NRTLs and other test agencies have routinely accepted a blanket 'equivalent' in the C/C table of submitted reports for all components. Typically stuff such as components that not across mains, or are not bridging insulation or a safety boundary can be cited in general terms with no particular mfr name or part no. The issue is that the agency assessment engineer cannot be certain which characteristics of a component are important to something on the C/C table. So they test your box with the assumption that the design team has verified performance only for the particular combination of stuff on the BoM and the board layout that was submitted for assessment. The other issue is that there is no formal IEC or SCC
Re: [PSES] CB Philosophy Questions
In message cy1pr0701mb188350deb98388a86224efe8e3...@cy1pr0701mb1883.namprd07.prod.o utlook.com, dated Thu, 30 Apr 2015, Brian Ceresney bceres...@delta-q.com writes: When our CB report was issued, the engineer was not willing to add wording to the Critical Components list to allow alternate components(X, Y caps, opto-isolators) with equivalent ratings and Regulatory Approvals to be added, with the implication being that this addition was not allowed by the authorities. It is often necessary to have an explicit list of alternative critical components - manufacturer and type number at least, maybe more. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CB Philosophy Questions
Brian I suggest you reference the IECEE website and read through the component acceptance requirements for each target country, including the USA. I haven't checked but there may also be such a document for the -2-29 you mention. These can be found in the same general area as the national differences documents. Both are interesting reading. If you are not able to access these contact your certifying agency and they should be willing to supply copies. As for what is typical in each country, I have learned that this is variable. In general the office tasked with reviewing and accepting your CB report definitely feels they have the authority to do as they please. And to a large extent this is true. Having a CB report is not a foregone guarantee that it will always be accepted. Regards, - doug Douglas Powell http://www.linkedin.com/in/dougp01 Original Message From: Brian Oconnell Sent: Thursday, April 30, 2015 6:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Brian Oconnell Subject: Re: [PSES] CB Philosophy Questions In both procedural controls and scoped test standards, North America (NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar where state-enforced codes do not contradict the scoped standard. It has been several years since the NRTLs and other test agencies have routinely accepted a blanket 'equivalent' in the C/C table of submitted reports for all components. Typically stuff such as components that not across mains, or are not bridging insulation or a safety boundary can be cited in general terms with no particular mfr name or part no. The issue is that the agency assessment engineer cannot be certain which characteristics of a component are important to something on the C/C table. So they test your box with the assumption that the design team has verified performance only for the particular combination of stuff on the BoM and the board layout that was submitted for assessment. The other issue is that there is no formal IEC or SCC or OSHA standard or regulation that defines how to assess an equivalent component, or whom in the company shall be the qualified signatory for equivalent item approval (exceptions for programs such as CSA cat cert and others). Do not agree with much of the shenanigans employed by the various agencies to effectively control market share through pseudo-engineering principles, but do agree in principle with the reductions in 'equivalent' components allowed on the critical component table. Brian From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Thursday, April 30, 2015 4:09 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CB Philosophy Questions Greetings, Compliance Experts, I'm finding myself in a curious situation, and wondering if you have had similar experiences, and may have some advice to share. We are in the process of using a CB report for an industrial battery charger( to IEC60335-2-29) to obtain an in-country certification in an Asian country, and have run into an interesting difficulty. When our CB report was issued, the engineer was not willing to add wording to the Critical Components list to allow alternate components(X, Y caps, opto-isolators) with equivalent ratings and Regulatory Approvals to be added, with the implication being that this addition was not allowed by the authorities. As expected, two years later, we are going through one country's approval process, using our CB report, and the national regulatory organization has decided that the use of a different brand of opto-isolator and X/Y capacitor is a non-compliance, as they are not specifically in the CB report. (The electrical, environmental ratings, and the regulatory approvals are equivalent to the original components). a.) Are these attitudes typical in the CB world? b.) Can anybody explain the apparent reticence of CB testing labs to allow alternate components in a CB report? c.) Is it likely that a National Body will eventually compromise, and use engineering judgement in accepting alternate components? Or is this usually a firm no? The North American NRTL organizations are proactive in allowing equivalently rated and approved components to be sourced in a product, and frequently state this in their reports. IMHO, it seems a bit archaic to not account for second-sourcing of common off-the-shelf critical components such as these. d.) Is there a philosophical or historical difference between the two systems(CB and NRTL) that accounts for this difference in approaches? Thanks in advance for your attention- your response is appreciated. Brian Ceresney Regulatory Lead Delta-Q Technologies Corp. - 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
Re: [PSES] CB Philosophy Questions
Optos are an excellent example. There are a myriad of parameters that will allow the safe operation of a typical power supply that are not considered in certs per IEC60747-5-x and UL1577. Stuff such as CTR drift within the rated temperature range, themal de-rate for linear optos, frequency BW per capacitance per temperature, and the Bugs Bunny factor. And a 'shallow' assessment will only indicate equivalent ratings and test certs to same standards. Brian From: Ted Eckert [mailto:ted.eck...@microsoft.com] Sent: Thursday, April 30, 2015 5:14 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CB Philosophy Questions Hello Brian, Most CB Test Laboratories (CBTLs) will allow and accept the use of the term interchangeable for some components. However, there are a few CBTLs that will not accept this term and they require each and every alternate source to be explicitly listed. If you indicated to your test lab that your CB report would be used for approval in one of these countries, your CB test lab may have proactively prevented you from including interchangeable in the report. Many manufacturers will structure the components list in their CB report to use the term interchangeable where appropriate and allowed. The manufacturer will then create a specific list of critical components for those countries that require the extra detail. The CB report is then used to provide the test data and construction review and the amended critical components list is used to meet the stricter component requirements. CBTLs are not required to accept alternate components that are not on the critical components list. It is up to the discretion of the test lab to determine if an alternate is acceptable. Each CBTL will have limits on which component types are eligible for generic descriptions. Most will allow generic descriptions for printed circuit boards with only the temperature and flame ratings specified. Many will allow generic descriptions for X and Y capacitors. I would not expect a CBTL to allow generic descriptions for optocouplers as there is often more to be controlled. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer, the CB test laboratories I work with or the CB test laboratories I don't work with. From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Thursday, April 30, 2015 4:09 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CB Philosophy Questions Greetings, Compliance Experts, I'm finding myself in a curious situation, and wondering if you have had similar experiences, and may have some advice to share. We are in the process of using a CB report for an industrial battery charger( to IEC60335-2-29) to obtain an in-country certification in an Asian country, and have run into an interesting difficulty. When our CB report was issued, the engineer was not willing to add wording to the Critical Components list to allow alternate components(X, Y caps, opto-isolators) with equivalent ratings and Regulatory Approvals to be added, with the implication being that this addition was not allowed by the authorities. As expected, two years later, we are going through one country's approval process, using our CB report, and the national regulatory organization has decided that the use of a different brand of opto-isolator and X/Y capacitor is a non-compliance, as they are not specifically in the CB report. (The electrical, environmental ratings, and the regulatory approvals are equivalent to the original components). a.) Are these attitudes typical in the CB world? b.) Can anybody explain the apparent reticence of CB testing labs to allow alternate components in a CB report? c.) Is it likely that a National Body will eventually compromise, and use engineering judgement in accepting alternate components? Or is this usually a firm no? The North American NRTL organizations are proactive in allowing equivalently rated and approved components to be sourced in a product, and frequently state this in their reports. IMHO, it seems a bit archaic to not account for second-sourcing of common off-the-shelf critical components such as these. d.) Is there a philosophical or historical difference between the two systems(CB and NRTL) that accounts for this difference in approaches? Thanks in advance for your attention- your response is appreciated. Brian Ceresney - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics
Re: [PSES] CB Philosophy Questions
Brian, Rules for component acceptance are submitted by each country to the IEC, archived in the IECEE website and posted in the same general area as national differences. You could simply try a Google search. These documents are supposed to be official but I have found your mileage may vary. For example, both the national differences and component acceptance documents for some Arab nations are fairly incomplete and you have to go to that authority to learn what's actually needed. I am not accusing them of any under the table stuff, it's just that they don't always have clear definitions and one CB reviewer may have preferences over another. That said, having a CB report is still a viable option, if only to get you started in the process. Definitely ask your CB third party agency for assistance in this. Try to get the original documents and not just the summarized ones they may try to give you. Best, Doug Original Message From: Brian Oconnell Sent: Thursday, April 30, 2015 7:22 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Brian Oconnell Subject: Re: [PSES] CB Philosophy Questions Doug, Thanks, will look for this stuff. The only stuff seen to date for component evaluation is in UL PAGs, CSA informs, and the IECEE CTL stuff. Are these component acceptance 'guides' part of the National Differences in a TRF, or regulatory law administered by the state? According to the OSHA guy that is the NRTL program director, they are in process of removing component standards from their official listing (do a search on the EMC-PSTC listserv archives for his comments). Do not understand Having a CB report is not a foregone guarantee that it will always be accepted. Do you mean that the TRF was rejected because of poor component descriptions, or that changes to the C/C table in the TRF was rejected, or something else? Brian -Original Message- From: dougp01 [mailto:doug...@gmail.com] Sent: Thursday, April 30, 2015 5:53 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CB Philosophy Questions Brian I suggest you reference the IECEE website and read through the component acceptance requirements for each target country, including the USA. I haven't checked but there may also be such a document for the -2-29 you mention. These can be found in the same general area as the national differences documents. Both are interesting reading. If you are not able to access these contact your certifying agency and they should be willing to supply copies. As for what is typical in each country, I have learned that this is variable. In general the office tasked with reviewing and accepting your CB report definitely feels they have the authority to do as they please. And to a large extent this is true. Having a CB report is not a foregone guarantee that it will always be accepted. Regards, - doug Douglas Powell http://www.linkedin.com/in/dougp01 Original Message From: Brian Oconnell Sent: Thursday, April 30, 2015 6:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Brian Oconnell Subject: Re: [PSES] CB Philosophy Questions In both procedural controls and scoped test standards, North America (NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar where state-enforced codes do not contradict the scoped standard. It has been several years since the NRTLs and other test agencies have routinely accepted a blanket 'equivalent' in the C/C table of submitted reports for all components. Typically stuff such as components that not across mains, or are not bridging insulation or a safety boundary can be cited in general terms with no particular mfr name or part no. The issue is that the agency assessment engineer cannot be certain which characteristics of a component are important to something on the C/C table. So they test your box with the assumption that the design team has verified performance only for the particular combination of stuff on the BoM and the board layout that was submitted for assessment. The other issue is that there is no formal IEC or SCC or OSHA standard or regulation that defines how to assess an equivalent component, or whom in the company shall be the qualified signatory for equivalent item approval (exceptions for programs such as CSA cat cert and others). Do not agree with much of the shenanigans employed by the various agencies to effectively control market share through pseudo-engineering principles, but do agree in principle with the reductions in 'equivalent' components allowed on the critical component table. Brian From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Thursday, April 30, 2015 4:09 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CB Philosophy Questions Greetings, Compliance Experts, I'm finding myself in a curious situation, and wondering if you have had similar experiences, and may have some advice to share. We are in the process of using a CB report for an industrial
Re: [PSES] CB Philosophy Questions
Try this link http://members.iecee.org/iecee/ieceemembers.nsf/ACRFList?readform Doug. Original Message From: dougp01 Sent: Thursday, April 30, 2015 7:50 PM To: oconne...@tamuracorp.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CB Philosophy Questions Brian, Rules for component acceptance are submitted by each country to the IEC, archived in the IECEE website and posted in the same general area as national differences. You could simply try a Google search. These documents are supposed to be official but I have found your mileage may vary. For example, both the national differences and component acceptance documents for some Arab nations are fairly incomplete and you have to go to that authority to learn what's actually needed. I am not accusing them of any under the table stuff, it's just that they don't always have clear definitions and one CB reviewer may have preferences over another. That said, having a CB report is still a viable option, if only to get you started in the process. Definitely ask your CB third party agency for assistance in this. Try to get the original documents and not just the summarized ones they may try to give you. Best, Doug Original Message From: Brian Oconnell Sent: Thursday, April 30, 2015 7:22 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Brian Oconnell Subject: Re: [PSES] CB Philosophy Questions Doug, Thanks, will look for this stuff. The only stuff seen to date for component evaluation is in UL PAGs, CSA informs, and the IECEE CTL stuff. Are these component acceptance 'guides' part of the National Differences in a TRF, or regulatory law administered by the state? According to the OSHA guy that is the NRTL program director, they are in process of removing component standards from their official listing (do a search on the EMC-PSTC listserv archives for his comments). Do not understand Having a CB report is not a foregone guarantee that it will always be accepted. Do you mean that the TRF was rejected because of poor component descriptions, or that changes to the C/C table in the TRF was rejected, or something else? Brian -Original Message- From: dougp01 [mailto:doug...@gmail.com] Sent: Thursday, April 30, 2015 5:53 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CB Philosophy Questions Brian I suggest you reference the IECEE website and read through the component acceptance requirements for each target country, including the USA. I haven't checked but there may also be such a document for the -2-29 you mention. These can be found in the same general area as the national differences documents. Both are interesting reading. If you are not able to access these contact your certifying agency and they should be willing to supply copies. As for what is typical in each country, I have learned that this is variable. In general the office tasked with reviewing and accepting your CB report definitely feels they have the authority to do as they please. And to a large extent this is true. Having a CB report is not a foregone guarantee that it will always be accepted. Regards, - doug Douglas Powell http://www.linkedin.com/in/dougp01 Original Message From: Brian Oconnell Sent: Thursday, April 30, 2015 6:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Brian Oconnell Subject: Re: [PSES] CB Philosophy Questions In both procedural controls and scoped test standards, North America (NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar where state-enforced codes do not contradict the scoped standard. It has been several years since the NRTLs and other test agencies have routinely accepted a blanket 'equivalent' in the C/C table of submitted reports for all components. Typically stuff such as components that not across mains, or are not bridging insulation or a safety boundary can be cited in general terms with no particular mfr name or part no. The issue is that the agency assessment engineer cannot be certain which characteristics of a component are important to something on the C/C table. So they test your box with the assumption that the design team has verified performance only for the particular combination of stuff on the BoM and the board layout that was submitted for assessment. The other issue is that there is no formal IEC or SCC or OSHA standard or regulation that defines how to assess an equivalent component, or whom in the company shall be the qualified signatory for equivalent item approval (exceptions for programs such as CSA cat cert and others). Do not agree with much of the shenanigans employed by the various agencies to effectively control market share through pseudo-engineering principles, but do agree in principle with the reductions in 'equivalent' components allowed on the critical component table. Brian From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Thursday, April 30, 2015 4:09 PM To: EMC-PSTC@LISTSERV.IEEE.ORG
Re: [PSES] CB Philosophy Questions
In both procedural controls and scoped test standards, North America (NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar where state-enforced codes do not contradict the scoped standard. It has been several years since the NRTLs and other test agencies have routinely accepted a blanket 'equivalent' in the C/C table of submitted reports for all components. Typically stuff such as components that not across mains, or are not bridging insulation or a safety boundary can be cited in general terms with no particular mfr name or part no. The issue is that the agency assessment engineer cannot be certain which characteristics of a component are important to something on the C/C table. So they test your box with the assumption that the design team has verified performance only for the particular combination of stuff on the BoM and the board layout that was submitted for assessment. The other issue is that there is no formal IEC or SCC or OSHA standard or regulation that defines how to assess an equivalent component, or whom in the company shall be the qualified signatory for equivalent item approval (exceptions for programs such as CSA cat cert and others). Do not agree with much of the shenanigans employed by the various agencies to effectively control market share through pseudo-engineering principles, but do agree in principle with the reductions in 'equivalent' components allowed on the critical component table. Brian From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Thursday, April 30, 2015 4:09 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CB Philosophy Questions Greetings, Compliance Experts, I'm finding myself in a curious situation, and wondering if you have had similar experiences, and may have some advice to share. We are in the process of using a CB report for an industrial battery charger( to IEC60335-2-29) to obtain an in-country certification in an Asian country, and have run into an interesting difficulty. When our CB report was issued, the engineer was not willing to add wording to the Critical Components list to allow alternate components(X, Y caps, opto-isolators) with equivalent ratings and Regulatory Approvals to be added, with the implication being that this addition was not allowed by the authorities. As expected, two years later, we are going through one country's approval process, using our CB report, and the national regulatory organization has decided that the use of a different brand of opto-isolator and X/Y capacitor is a non-compliance, as they are not specifically in the CB report. (The electrical, environmental ratings, and the regulatory approvals are equivalent to the original components). a.) Are these attitudes typical in the CB world? b.) Can anybody explain the apparent reticence of CB testing labs to allow alternate components in a CB report? c.) Is it likely that a National Body will eventually compromise, and use engineering judgement in accepting alternate components? Or is this usually a firm no? The North American NRTL organizations are proactive in allowing equivalently rated and approved components to be sourced in a product, and frequently state this in their reports. IMHO, it seems a bit archaic to not account for second-sourcing of common off-the-shelf critical components such as these. d.) Is there a philosophical or historical difference between the two systems(CB and NRTL) that accounts for this difference in approaches? Thanks in advance for your attention- your response is appreciated. Brian Ceresney Regulatory Lead Delta-Q Technologies Corp. - 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 sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CB Philosophy Questions
Doug, Thanks, will look for this stuff. The only stuff seen to date for component evaluation is in UL PAGs, CSA informs, and the IECEE CTL stuff. Are these component acceptance 'guides' part of the National Differences in a TRF, or regulatory law administered by the state? According to the OSHA guy that is the NRTL program director, they are in process of removing component standards from their official listing (do a search on the EMC-PSTC listserv archives for his comments). Do not understand Having a CB report is not a foregone guarantee that it will always be accepted. Do you mean that the TRF was rejected because of poor component descriptions, or that changes to the C/C table in the TRF was rejected, or something else? Brian -Original Message- From: dougp01 [mailto:doug...@gmail.com] Sent: Thursday, April 30, 2015 5:53 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CB Philosophy Questions Brian I suggest you reference the IECEE website and read through the component acceptance requirements for each target country, including the USA. I haven't checked but there may also be such a document for the -2-29 you mention. These can be found in the same general area as the national differences documents. Both are interesting reading. If you are not able to access these contact your certifying agency and they should be willing to supply copies. As for what is typical in each country, I have learned that this is variable. In general the office tasked with reviewing and accepting your CB report definitely feels they have the authority to do as they please. And to a large extent this is true. Having a CB report is not a foregone guarantee that it will always be accepted. Regards, - doug Douglas Powell http://www.linkedin.com/in/dougp01 Original Message From: Brian Oconnell Sent: Thursday, April 30, 2015 6:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Brian Oconnell Subject: Re: [PSES] CB Philosophy Questions In both procedural controls and scoped test standards, North America (NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar where state-enforced codes do not contradict the scoped standard. It has been several years since the NRTLs and other test agencies have routinely accepted a blanket 'equivalent' in the C/C table of submitted reports for all components. Typically stuff such as components that not across mains, or are not bridging insulation or a safety boundary can be cited in general terms with no particular mfr name or part no. The issue is that the agency assessment engineer cannot be certain which characteristics of a component are important to something on the C/C table. So they test your box with the assumption that the design team has verified performance only for the particular combination of stuff on the BoM and the board layout that was submitted for assessment. The other issue is that there is no formal IEC or SCC or OSHA standard or regulation that defines how to assess an equivalent component, or whom in the company shall be the qualified signatory for equivalent item approval (exceptions for programs such as CSA cat cert and others). Do not agree with much of the shenanigans employed by the various agencies to effectively control market share through pseudo-engineering principles, but do agree in principle with the reductions in 'equivalent' components allowed on the critical component table. Brian From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Thursday, April 30, 2015 4:09 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CB Philosophy Questions Greetings, Compliance Experts, I'm finding myself in a curious situation, and wondering if you have had similar experiences, and may have some advice to share. We are in the process of using a CB report for an industrial battery charger( to IEC60335-2-29) to obtain an in-country certification in an Asian country, and have run into an interesting difficulty. When our CB report was issued, the engineer was not willing to add wording to the Critical Components list to allow alternate components(X, Y caps, opto-isolators) with equivalent ratings and Regulatory Approvals to be added, with the implication being that this addition was not allowed by the authorities. As expected, two years later, we are going through one country's approval process, using our CB report, and the national regulatory organization has decided that the use of a different brand of opto-isolator and X/Y capacitor is a non-compliance, as they are not specifically in the CB report. (The electrical, environmental ratings, and the regulatory approvals are equivalent to the original components). a.) Are these attitudes typical in the CB world? b.) Can anybody explain the apparent reticence of CB testing labs to allow alternate components in a CB report? c.) Is it likely that a National Body will eventually compromise, and use engineering
Re: [PSES] CB Philosophy Questions
All, You may want to reach out to the National Committee in your Country, For the US National Committee (USNC), the best point of contact would be Joel Solis at NEMA who serves as the Secretary. They might be able to bring this up at a future CB Scheme meeting and encourage all countries to establish similar guidelines for mentioning alternate components in CB reports. Brian is correct about the NRTL Program removing component standards from its list of appropriate test standards. The NRTL Program was never intended to include components as it only applies to end products used in the workplace, but over the years, some predominantly component standards were added to the list, and OSHA is in the process of removing those standards. That said, NRTLs will still be allowed to accept component certifications from others when evaluating end products. Kevin Robinson a.k.a The OSHA NRTL Director Guy :-) robinson.ke...@dol.gov On Thu, Apr 30, 2015 at 9:21 PM, Brian Oconnell oconne...@tamuracorp.com wrote: Doug, Thanks, will look for this stuff. The only stuff seen to date for component evaluation is in UL PAGs, CSA informs, and the IECEE CTL stuff. Are these component acceptance 'guides' part of the National Differences in a TRF, or regulatory law administered by the state? According to the OSHA guy that is the NRTL program director, they are in process of removing component standards from their official listing (do a search on the EMC-PSTC listserv archives for his comments). Do not understand Having a CB report is not a foregone guarantee that it will always be accepted. Do you mean that the TRF was rejected because of poor component descriptions, or that changes to the C/C table in the TRF was rejected, or something else? Brian -Original Message- From: dougp01 [mailto:doug...@gmail.com] Sent: Thursday, April 30, 2015 5:53 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CB Philosophy Questions Brian I suggest you reference the IECEE website and read through the component acceptance requirements for each target country, including the USA. I haven't checked but there may also be such a document for the -2-29 you mention. These can be found in the same general area as the national differences documents. Both are interesting reading. If you are not able to access these contact your certifying agency and they should be willing to supply copies. As for what is typical in each country, I have learned that this is variable. In general the office tasked with reviewing and accepting your CB report definitely feels they have the authority to do as they please. And to a large extent this is true. Having a CB report is not a foregone guarantee that it will always be accepted. Regards, - doug Douglas Powell http://www.linkedin.com/in/dougp01 Original Message From: Brian Oconnell Sent: Thursday, April 30, 2015 6:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Reply To: Brian Oconnell Subject: Re: [PSES] CB Philosophy Questions In both procedural controls and scoped test standards, North America (NRTL/SCC/NOM) reports and the IECEE CB scheme are becoming more similar where state-enforced codes do not contradict the scoped standard. It has been several years since the NRTLs and other test agencies have routinely accepted a blanket 'equivalent' in the C/C table of submitted reports for all components. Typically stuff such as components that not across mains, or are not bridging insulation or a safety boundary can be cited in general terms with no particular mfr name or part no. The issue is that the agency assessment engineer cannot be certain which characteristics of a component are important to something on the C/C table. So they test your box with the assumption that the design team has verified performance only for the particular combination of stuff on the BoM and the board layout that was submitted for assessment. The other issue is that there is no formal IEC or SCC or OSHA standard or regulation that defines how to assess an equivalent component, or whom in the company shall be the qualified signatory for equivalent item approval (exceptions for programs such as CSA cat cert and others). Do not agree with much of the shenanigans employed by the various agencies to effectively control market share through pseudo-engineering principles, but do agree in principle with the reductions in 'equivalent' components allowed on the critical component table. Brian From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Thursday, April 30, 2015 4:09 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CB Philosophy Questions Greetings, Compliance Experts, I'm finding myself in a curious situation, and wondering if you have had similar experiences, and may have some advice to share. We are in the process of using a CB report for an industrial battery charger( to IEC60335-2-29) to obtain an in-country certification in an Asian
Re: [PSES] CB Philosophy Questions
Hello Brian, Most CB Test Laboratories (CBTLs) will allow and accept the use of the term interchangeable for some components. However, there are a few CBTLs that will not accept this term and they require each and every alternate source to be explicitly listed. If you indicated to your test lab that your CB report would be used for approval in one of these countries, your CB test lab may have proactively prevented you from including interchangeable in the report. Many manufacturers will structure the components list in their CB report to use the term interchangeable where appropriate and allowed. The manufacturer will then create a specific list of critical components for those countries that require the extra detail. The CB report is then used to provide the test data and construction review and the amended critical components list is used to meet the stricter component requirements. CBTLs are not required to accept alternate components that are not on the critical components list. It is up to the discretion of the test lab to determine if an alternate is acceptable. Each CBTL will have limits on which component types are eligible for generic descriptions. Most will allow generic descriptions for printed circuit boards with only the temperature and flame ratings specified. Many will allow generic descriptions for X and Y capacitors. I would not expect a CBTL to allow generic descriptions for optocouplers as there is often more to be controlled. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.commailto:ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer, the CB test laboratories I work with or the CB test laboratories I don't work with. From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Thursday, April 30, 2015 4:09 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CB Philosophy Questions Greetings, Compliance Experts, I'm finding myself in a curious situation, and wondering if you have had similar experiences, and may have some advice to share. We are in the process of using a CB report for an industrial battery charger( to IEC60335-2-29) to obtain an in-country certification in an Asian country, and have run into an interesting difficulty. When our CB report was issued, the engineer was not willing to add wording to the Critical Components list to allow alternate components(X, Y caps, opto-isolators) with equivalent ratings and Regulatory Approvals to be added, with the implication being that this addition was not allowed by the authorities. As expected, two years later, we are going through one country's approval process, using our CB report, and the national regulatory organization has decided that the use of a different brand of opto-isolator and X/Y capacitor is a non-compliance, as they are not specifically in the CB report. (The electrical, environmental ratings, and the regulatory approvals are equivalent to the original components). a.)Are these attitudes typical in the CB world? b.)Can anybody explain the apparent reticence of CB testing labs to allow alternate components in a CB report? c.)Is it likely that a National Body will eventually compromise, and use engineering judgement in accepting alternate components? Or is this usually a firm no? The North American NRTL organizations are proactive in allowing equivalently rated and approved components to be sourced in a product, and frequently state this in their reports. IMHO, it seems a bit archaic to not account for second-sourcing of common off-the-shelf critical components such as these. d.)Is there a philosophical or historical difference between the two systems(CB and NRTL) that accounts for this difference in approaches? Thanks in advance for your attention- your response is appreciated. Brian Ceresney Regulatory Lead Delta-Q Technologies Corp. Phone: +1.604.566.8827 Note: The comments here represent my opinions, not those of Delta-Q Technologies. . - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas sdoug...@ieee.orgmailto:sdoug...@ieee.org Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send
[PSES] CB Philosophy Questions
Greetings, Compliance Experts, I'm finding myself in a curious situation, and wondering if you have had similar experiences, and may have some advice to share. We are in the process of using a CB report for an industrial battery charger( to IEC60335-2-29) to obtain an in-country certification in an Asian country, and have run into an interesting difficulty. When our CB report was issued, the engineer was not willing to add wording to the Critical Components list to allow alternate components(X, Y caps, opto-isolators) with equivalent ratings and Regulatory Approvals to be added, with the implication being that this addition was not allowed by the authorities. As expected, two years later, we are going through one country's approval process, using our CB report, and the national regulatory organization has decided that the use of a different brand of opto-isolator and X/Y capacitor is a non-compliance, as they are not specifically in the CB report. (The electrical, environmental ratings, and the regulatory approvals are equivalent to the original components). a.)Are these attitudes typical in the CB world? b.)Can anybody explain the apparent reticence of CB testing labs to allow alternate components in a CB report? c.) Is it likely that a National Body will eventually compromise, and use engineering judgement in accepting alternate components? Or is this usually a firm no? The North American NRTL organizations are proactive in allowing equivalently rated and approved components to be sourced in a product, and frequently state this in their reports. IMHO, it seems a bit archaic to not account for second-sourcing of common off-the-shelf critical components such as these. d.)Is there a philosophical or historical difference between the two systems(CB and NRTL) that accounts for this difference in approaches? Thanks in advance for your attention- your response is appreciated. Brian Ceresney Regulatory Lead Delta-Q Technologies Corp. Phone: +1.604.566.8827 Note: The comments here represent my opinions, not those of Delta-Q Technologies. . - 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 sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
