RE: Standards hierarchy
Jim: There are conflicts between product standards and product family standards. Your opinion is as accurate as the next guy except for your remark concerning the system is out of control. This is a as accurate an one can get. As for standing too close to the microwave, this to will stop after the pending EMF requirements are imposed. Enjoy the wonderful world of standards conformance. Dave George Unisys Corp. 2476 Swedesford Road Malvern, PA 19355 Tel: 1-610-648-3653 Fax: 1-610-695-4700 -Original Message- From: Jim Eichner [mailto:jim.eich...@xantrex.com] Sent: Wednesday, October 04, 2000 8:39 PM To: 'EMC-PSTC - forum' Subject: RE: Standards hierarchy OK now I'm really confused. It suddenly hit me that I thought publication in the OJ conferred presumption of conformity with the essential requirements!!! End of sentence, full stop. Silly me, I must stop standing so close to the microwave. Are we really in a situation where there are standards being published in the OJ that do NOT address all of the essential requirements and are therefore not sufficient on their own? This seems to be what Gert's Mr. DeVre is saying, and if so the system is downright out of control. I assert that despite Mr. DeVre's comments, a standard that has been published in the OJ as applicable under the EMC Directive gives presumption of conformity with the essential requirements of that directive, and is therefore, by definition, sufficient without the use of further standards. Am I wrong!? Further comments please! Thanks, Jim Suddenly flipping burgers for $5/hr doesn't sound so bad. -Original Message- From: eric.lif...@ni.com [mailto:eric.lif...@ni.com] Sent: Wednesday, October 04, 2000 11:49 AM To: CE-test - Gert Gremmen Ing. - CE-mark more ... Cc: Maxwell, Chris; 'Jim Eichner'; 'EMC-PSTC - forum' Subject: RE: Standards hierarchy Gert et al, [Critical comments re CEN removed in an attempt to maintain a professional attitude.] Can't we just recind all of these silly redundant product family standards if they are truely just informative supplements to the Generics? I'm getting tired of retesting and then rewriting hundreds of DoCs. Regards, Eric Lifsey Compliance Manager (And a miserable author of about 400 DoCs.) National Instruments Please respond to CE-test - Gert Gremmen Ing. - CE-mark more ... cet...@cetest.nl To: Maxwell, Chris chr...@gnlp.com, 'Jim Eichner' jim.eich...@xantrex.com, 'EMC-PSTC - forum' emc-p...@majordomo.ieee.org cc:(bcc: Eric Lifsey/AUS/NIC) Subject: RE: Standards hierarchy I remember to have contributed to this discussion before, and I have asked this question at the time to Robert DeVre, who is actually the EMC-consultant of the European Committee. His opinion -close to European law- (abbreviated) : == Any product or product family standard that tries to exclude any category of tests (f or categories see f.a. the generic) is actually creating a non-compliance situation for the equipment in question, as it does not comply to the essential requirements of the EMC-directive. == Do not forget that complying to a standard creates only presumption of conformity to the essential requirements. The standard writing committee did bad service to the market creating a standard trying to create an escape route. The EC ( by voice of Mr. DeVre) has contacted CENELEC to make this standard comply with the Essential requirements of the EMC-directive. Please note that there is a report available to all national committees that are charged with standards writing, that explains to what requirements future harmonized standards should comply to be acceptable to the EC and create (true) presumption of compliance for users actually using them. This technical report is numbered R210-001 (at least the version I have in front of me) and is issued by the CENELEC. It's purpose is to advise standard writing committees in: - advice on the application of generic and basic emc standards - advise on the preparation of product family or dedicated product emc standards. Please note that the compliance for product standards to this report is part of the agreement that CENELEC will prepare standards for the EC to comply with EMCD. (as CENELEC is private and EMCD is law) This report has a summary of phenomena that product and product family standards should cover: creating limits, or create a decent rationale why not. In addition: for assessment of compliance with the EMC -directive, the product family standards take precedence over the generic standards partially or totally according to the EMC domains covered. Uncovered or excluded phenomena are thus still susceptible to generic standard test requirements !!! Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business
RE: Standards hierarchy
In the instance of EN 61000-3-2 and EN 61000-3-3, we MUST look to regulatory authorities to make the decision. I think the basis of the whole argument is this: For many products covered by these standards, the essential requirements as listed by many competent EMC engineers would not include EN 61000-3-2 and EN 61000-3-3. In their eyes it only increases product cost and complexity with minimal product reliability and/or safety benefit. Other competent engineers would disagree. Apparantly, standards writing committees for IEC and CENELEC have stumbled over the same problem. The authors of EN 61326-1 (and apparatantly some other product standards) did not feel that the essential requirements for Class A Test and Measurement equipment included EN 61000-3-2 and EN 61000-3-3. The authors of EN 61000-3-2 and EN 61000-3-3 disagreed. According to standards hierarchy, the authors of EN 61000-3-2 and -3-3 win out. That's great, but it doesn't clear up the conflicting standards and we've already seen that it isn't clearly solved by essential requirements type thinking. I think that the essential requirements type of solution only works when you could ask 100 EMC engineers about a requirement and get the same answer more than, say, 95 times. This standard does not fall into that category (as witnessed by all of the confusion). I would assert that the argument over this standard has precipitated because most EMC engineers DO UNDERSTAND essential requirements. This is what leads them to question the standards. As a design engineer, I do not have the power to go to my power supply manufacturers and demand power factor corrected power supplies. My power supply manufacturers are very cost competetive and will wait for a VERY clear system of regulatory mandates before they take the risk of increasing the cost and complexity of their power supplies. Also in our cost competetive market we cannot always afford a custom power supply. It seems to me that the confusion and fighting over this standard initially slowed down the availability of power factor corrected supplies which put an availability crunch on quite a few designers. That is where a clear regulatory mandate would help. In the end, I don't think that we're waiting for the regulatory agencies to make our decisions for us. I think we're waiting for them to make their own decisions for themselves (with our input). When they are clear in their decisions, it helps to level the competetive playing field among products. When they take on the authority of regulation, they take on the responsibility of being clear in their mandates. (Anybody else who is a parent would understand that one.) I feel better. This will be my last email regarding this thread (promise) (collective applauase from the group) Have a good one :-) Chris -Original Message- From: Wagner, John P (John) [SMTP:johnwag...@avaya.com] Sent: Wednesday, October 11, 2000 10:55 AM To: 'EMC-PSTC - forum'; 'Jim Eichner' Subject: RE: Standards hierarchy I'd like to throw my two cents worth in here. First, compliance with a national/international standard or regulatory regime does not guarantee adequate product performance or safety. That is the responsibility of the manufacturer. The standard(s) gives guidance to achieve that acceptable level of performance and compliance with it acceptable to a regulatory regime or authority provides a legal basis to market the product. Don't look to regulatory authorities to manage your compliance or EMC/Safety design goals. John P. Wagner AVAYA Communication 11900 N. Pecos St, Room 2F58 Denver CO 80234 email: johnwag...@avaya.com phone: 303 538-4241 fax: 303 538-5211 -- From: Jim Eichner[SMTP:jim.eich...@xantrex.com] Reply To: Jim Eichner Sent: Tuesday, October 10, 2000 4:45 PM To: 'EMC-PSTC - forum' Subject:RE: Standards hierarchy To summarize and conclude this thread: 1. If you ignore all consideration except the rules for CE Marking and the EMC Directive, and if you have a product family standard that does not call out any other standards (for example EN61000-3-2), and if that product family standard has been published in the OJ, then it would seem that you are in compliance with the EMC Directive if you apply only that standard (since it provides a presumption of conformity). 2. Doing the above would be a bad idea because... a) The EC has not got it's act together. With one hand they publish a standard in the OJ and with the other hand they say the standard isn't sufficient. According to what Gert said, it sounds like the EC will be working with CENELEC to correct this situation, so it is short sighted to take the easy road now if you'll just have to take the longer road later anyway. b) There may be real world problems (and in the worst case a product safety hazard) associated
RE: Standards hierarchy
I'd like to throw my two cents worth in here. First, compliance with a national/international standard or regulatory regime does not guarantee adequate product performance or safety. That is the responsibility of the manufacturer. The standard(s) gives guidance to achieve that acceptable level of performance and compliance with it acceptable to a regulatory regime or authority provides a legal basis to market the product. Don't look to regulatory authorities to manage your compliance or EMC/Safety design goals. John P. Wagner AVAYA Communication 11900 N. Pecos St, Room 2F58 Denver CO 80234 email: johnwag...@avaya.com phone: 303 538-4241 fax: 303 538-5211 -- From: Jim Eichner[SMTP:jim.eich...@xantrex.com] Reply To: Jim Eichner Sent: Tuesday, October 10, 2000 4:45 PM To: 'EMC-PSTC - forum' Subject: RE: Standards hierarchy To summarize and conclude this thread: 1. If you ignore all consideration except the rules for CE Marking and the EMC Directive, and if you have a product family standard that does not call out any other standards (for example EN61000-3-2), and if that product family standard has been published in the OJ, then it would seem that you are in compliance with the EMC Directive if you apply only that standard (since it provides a presumption of conformity). 2. Doing the above would be a bad idea because... a) The EC has not got it's act together. With one hand they publish a standard in the OJ and with the other hand they say the standard isn't sufficient. According to what Gert said, it sounds like the EC will be working with CENELEC to correct this situation, so it is short sighted to take the easy road now if you'll just have to take the longer road later anyway. b) There may be real world problems (and in the worst case a product safety hazard) associated with an EMC phenomenon addressed by other standards but omitted by your product family standard. In such a situation, liability may be increased by not having applied the other standards, even though technically you didn't have to. c) You are flying in the face of standard practice (pun intended). Diligent compliance people are doing the right thing and applying all the standards that apply, rather than putting on the blinkers and just using their product family standard (however technically correct or incorrect that may be). I'd add a statement to Gert's closing comment that the concept of essential requirements has not been fully understood yet. I'd echo say the concept of product family standards has not been fully understood yet. The Europa web site list of harmonized standards is full of wording that implies that single standards give presumption of conformity with the EMC Directive's essential requirements. There is nothing to indicate that in many (most?) situations it will take a group of standards to fully cover all the essential requirements. If anyone from the EC or CENELEC has been following this thread, it would be very helpful to get some clarification as to the current and future right way to deal with this issue. Regards, Jim Eichner Sr. Regulatory Compliance Engineer Mobile Markets Xantrex Technology Inc. Email: jim.eich...@xantrex.com Website: www.xantrex.com Any opinions expressed are those of my invisible friend, who really exists but is not, by himself, sufficient to give presumption of...oh never mind. -Original Message- From: CE-test - Gert Gremmen Ing. - CE-mark more ... [mailto:cet...@cetest.nl] Sent: Thursday, October 05, 2000 5:20 AM To: Jim Eichner; 'EMC-PSTC - forum' Subject: RE: Standards hierarchy Hello Jim, group You are fully right. A standard not covering a certain EMC subject, or whitening it out due to whatever reason but physical/technical (such as a filament lamp not being susceptible) still owes the presumption of compliance but the presumption will not hold in court. After all , presumption is not proof !! BTW it happens all the time that we are needing more then one emc standard . For ITE we need 4: EN 55022 / EN 55024 / EN 61000-3-2 / EN 61000-3-4. We automatically add the other 3 as we conclude that the first one did not cover certain phenomena. What's new here is that the EC does not recognize the right of OJEC published standards to white out certain test requirements because some lobby decided that it was not in their interest to cover this. In fact the EC is targeting the CENELEC for creating insufficient quality standards (in this case) and not you as a manufacturer presuming compliance. Therefore, you will get away with such a standard - for the time being. I think the principal of essential requirements has still not been fully understood !! Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http
RE: Standards hierarchy
Exactly, CENELEC has a full blown case of conflicting standards. Gert has gone the extra step to contact Mr DeVre. This provides us with another piece of information. But it doesn't give us CENELEC's official position. I consider it equivalent to getting the opinion of one justice of the Supreme Court. It's a great piece of information, but it's not law. I can follow his reasoning, and I think I should, just to be on the safe side. The problem is, it doesn't provide a long term solution to the existing standards discrepancy. That's why I beleive that CENELEC or one of their technical committes should pull their heads out of.. um ... the sand...and issue a simple press release to give an official position. Along with that, I would like to see them decide on a clear cut path to end these discrepancies. Either they decide to amend EN 61326-1 (and other conflicting standards) or they decide to move EN 61000-3-2 and -3 back to Basic Standards. That's the only true solution that would prevent us from needing to revisit this problem again. We should expect these types of discrepancies to occur. So many documents are published in the OJ that it's almost impossible to get them all to co-exist without conflicting requirements. That's why we can use the opinions of the Mr DeVre's and other Competent Bodies of the world to help with interpretation in order to clear up the confusion, temporarily. However, I think CENELEC needs to address these discrepancies as they are found. I believe that that's why Amendments were invented. Later -Original Message- From: Jim Eichner [SMTP:jim.eich...@xantrex.com] Sent: Wednesday, October 04, 2000 8:39 PM To: 'EMC-PSTC - forum' Subject: RE: Standards hierarchy OK now I'm really confused. It suddenly hit me that I thought publication in the OJ conferred presumption of conformity with the essential requirements!!! End of sentence, full stop. Silly me, I must stop standing so close to the microwave. Are we really in a situation where there are standards being published in the OJ that do NOT address all of the essential requirements and are therefore not sufficient on their own? This seems to be what Gert's Mr. DeVre is saying, and if so the system is downright out of control. I assert that despite Mr. DeVre's comments, a standard that has been published in the OJ as applicable under the EMC Directive gives presumption of conformity with the essential requirements of that directive, and is therefore, by definition, sufficient without the use of further standards. Am I wrong!? Further comments please! Thanks, Jim Suddenly flipping burgers for $5/hr doesn't sound so bad. -Original Message- From: eric.lif...@ni.com [mailto:eric.lif...@ni.com] Sent: Wednesday, October 04, 2000 11:49 AM To: CE-test - Gert Gremmen Ing. - CE-mark more ... Cc: Maxwell, Chris; 'Jim Eichner'; 'EMC-PSTC - forum' Subject: RE: Standards hierarchy Gert et al, [Critical comments re CEN removed in an attempt to maintain a professional attitude.] Can't we just recind all of these silly redundant product family standards if they are truely just informative supplements to the Generics? I'm getting tired of retesting and then rewriting hundreds of DoCs. Regards, Eric Lifsey Compliance Manager (And a miserable author of about 400 DoCs.) National Instruments Please respond to CE-test - Gert Gremmen Ing. - CE-mark more ... cet...@cetest.nl To: Maxwell, Chris chr...@gnlp.com, 'Jim Eichner' jim.eich...@xantrex.com, 'EMC-PSTC - forum' emc-p...@majordomo.ieee.org cc:(bcc: Eric Lifsey/AUS/NIC) Subject: RE: Standards hierarchy I remember to have contributed to this discussion before, and I have asked this question at the time to Robert DeVre, who is actually the EMC-consultant of the European Committee. His opinion -close to European law- (abbreviated) : == Any product or product family standard that tries to exclude any category of tests (f or categories see f.a. the generic) is actually creating a non-compliance situation for the equipment in question, as it does not comply to the essential requirements of the EMC-directive. == Do not forget that complying to a standard creates only presumption of conformity to the essential requirements. The standard writing committee did bad service to the market creating a standard trying to create an escape route. The EC ( by voice of Mr. DeVre) has contacted CENELEC to make this standard comply with the Essential requirements of the EMC-directive. Please note that there is a report available to all national committees that are charged with standards writing, that explains to what requirements future harmonized standards should comply to be acceptable to the EC and create (true) presumption of compliance for users actually using them. This technical report is numbered R210
RE: Standards hierarchy
I support your belief, Jim. The safeguard clause provides the member states with the ability to halt a product from being placed on the market due to a faulty standard. If that happens the Commission must quickly consult with all parties and make a decision of the status of the standard. I have not heard of this action ever being taken. Richard Woods -- From: Jim Eichner [SMTP:jim.eich...@xantrex.com] Sent: Wednesday, October 04, 2000 8:39 PM To: 'EMC-PSTC - forum' Subject: RE: Standards hierarchy OK now I'm really confused. It suddenly hit me that I thought publication in the OJ conferred presumption of conformity with the essential requirements!!! End of sentence, full stop. Silly me, I must stop standing so close to the microwave. Are we really in a situation where there are standards being published in the OJ that do NOT address all of the essential requirements and are therefore not sufficient on their own? This seems to be what Gert's Mr. DeVre is saying, and if so the system is downright out of control. I assert that despite Mr. DeVre's comments, a standard that has been published in the OJ as applicable under the EMC Directive gives presumption of conformity with the essential requirements of that directive, and is therefore, by definition, sufficient without the use of further standards. Am I wrong!? Further comments please! Thanks, Jim Suddenly flipping burgers for $5/hr doesn't sound so bad. -Original Message- From: eric.lif...@ni.com [mailto:eric.lif...@ni.com] Sent: Wednesday, October 04, 2000 11:49 AM To: CE-test - Gert Gremmen Ing. - CE-mark more ... Cc: Maxwell, Chris; 'Jim Eichner'; 'EMC-PSTC - forum' Subject: RE: Standards hierarchy Gert et al, [Critical comments re CEN removed in an attempt to maintain a professional attitude.] Can't we just recind all of these silly redundant product family standards if they are truely just informative supplements to the Generics? I'm getting tired of retesting and then rewriting hundreds of DoCs. Regards, Eric Lifsey Compliance Manager (And a miserable author of about 400 DoCs.) National Instruments Please respond to CE-test - Gert Gremmen Ing. - CE-mark more ... cet...@cetest.nl To: Maxwell, Chris chr...@gnlp.com, 'Jim Eichner' jim.eich...@xantrex.com, 'EMC-PSTC - forum' emc-p...@majordomo.ieee.org cc:(bcc: Eric Lifsey/AUS/NIC) Subject: RE: Standards hierarchy I remember to have contributed to this discussion before, and I have asked this question at the time to Robert DeVre, who is actually the EMC-consultant of the European Committee. His opinion -close to European law- (abbreviated) : == Any product or product family standard that tries to exclude any category of tests (f or categories see f.a. the generic) is actually creating a non-compliance situation for the equipment in question, as it does not comply to the essential requirements of the EMC-directive. == Do not forget that complying to a standard creates only presumption of conformity to the essential requirements. The standard writing committee did bad service to the market creating a standard trying to create an escape route. The EC ( by voice of Mr. DeVre) has contacted CENELEC to make this standard comply with the Essential requirements of the EMC-directive. Please note that there is a report available to all national committees that are charged with standards writing, that explains to what requirements future harmonized standards should comply to be acceptable to the EC and create (true) presumption of compliance for users actually using them. This technical report is numbered R210-001 (at least the version I have in front of me) and is issued by the CENELEC. It's purpose is to advise standard writing committees in: - advice on the application of generic and basic emc standards - advise on the preparation of product family or dedicated product emc standards. Please note that the compliance for product standards to this report is part of the agreement that CENELEC will prepare standards for the EC to comply with EMCD. (as CENELEC is private and EMCD is law) This report has a summary of phenomena that product and product family standards should cover: creating limits, or create a decent rationale why not. In addition: for assessment of compliance
RE: Standards hierarchy
Hello Jim, group You are fully right. A standard not covering a certain EMC subject, or whitening it out due to whatever reason but physical/technical (such as a filament lamp not being susceptible) still owes the presumption of compliance but the presumption will not hold in court. After all , presumption is not proof !! BTW it happens all the time that we are needing more then one emc standard . For ITE we need 4: EN 55022 / EN 55024 / EN 61000-3-2 / EN 61000-3-4. We automatically add the other 3 as we conclude that the first one did not cover certain phenomena. What's new here is that the EC does not recognize the right of OJEC published standards to white out certain test requirements because some lobby decided that it was not in their interest to cover this. In fact the EC is targeting the CENELEC for creating insufficient quality standards (in this case) and not you as a manufacturer presuming compliance. Therefore, you will get away with such a standard - for the time being. I think the principal of essential requirements has still not been fully understood !! Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === -Original Message- From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of Jim Eichner Sent: Thursday, October 05, 2000 2:39 AM To: 'EMC-PSTC - forum' Subject: RE: Standards hierarchy OK now I'm really confused. It suddenly hit me that I thought publication in the OJ conferred presumption of conformity with the essential requirements!!! End of sentence, full stop. Silly me, I must stop standing so close to the microwave. Are we really in a situation where there are standards being published in the OJ that do NOT address all of the essential requirements and are therefore not sufficient on their own? This seems to be what Gert's Mr. DeVre is saying, and if so the system is downright out of control. I assert that despite Mr. DeVre's comments, a standard that has been published in the OJ as applicable under the EMC Directive gives presumption of conformity with the essential requirements of that directive, and is therefore, by definition, sufficient without the use of further standards. Am I wrong!? Further comments please! Thanks, Jim Suddenly flipping burgers for $5/hr doesn't sound so bad. -Original Message- From: eric.lif...@ni.com [mailto:eric.lif...@ni.com] Sent: Wednesday, October 04, 2000 11:49 AM To: CE-test - Gert Gremmen Ing. - CE-mark more ... Cc: Maxwell, Chris; 'Jim Eichner'; 'EMC-PSTC - forum' Subject: RE: Standards hierarchy Gert et al, [Critical comments re CEN removed in an attempt to maintain a professional attitude.] Can't we just recind all of these silly redundant product family standards if they are truely just informative supplements to the Generics? I'm getting tired of retesting and then rewriting hundreds of DoCs. Regards, Eric Lifsey Compliance Manager (And a miserable author of about 400 DoCs.) National Instruments Please respond to CE-test - Gert Gremmen Ing. - CE-mark more ... cet...@cetest.nl To: Maxwell, Chris chr...@gnlp.com, 'Jim Eichner' jim.eich...@xantrex.com, 'EMC-PSTC - forum' emc-p...@majordomo.ieee.org cc:(bcc: Eric Lifsey/AUS/NIC) Subject: RE: Standards hierarchy I remember to have contributed to this discussion before, and I have asked this question at the time to Robert DeVre, who is actually the EMC-consultant of the European Committee. His opinion -close to European law- (abbreviated) : == Any product or product family standard that tries to exclude any category of tests (f or categories see f.a. the generic) is actually creating a non-compliance situation for the equipment in question, as it does not comply to the essential requirements of the EMC-directive. == Do not forget that complying to a standard creates only presumption of conformity to the essential requirements. The standard writing committee did bad service to the market creating a standard trying to create an escape route. The EC ( by voice of Mr. DeVre) has contacted CENELEC to make this standard comply with the Essential requirements of the EMC-directive. Please note that there is a report available to all national committees that are charged with standards writing, that explains to what requirements future harmonized standards should comply to be acceptable to the EC and create (true) presumption of compliance for users actually using them. This technical report is numbered R210-001 (at least the version I have in front of me) and is issued by the CENELEC. It's purpose is to advise standard writing committees in: - advice on the application of generic and basic emc standards - advise on the preparation of product family or dedicated product emc
RE: Standards hierarchy
OK now I'm really confused. It suddenly hit me that I thought publication in the OJ conferred presumption of conformity with the essential requirements!!! End of sentence, full stop. Silly me, I must stop standing so close to the microwave. Are we really in a situation where there are standards being published in the OJ that do NOT address all of the essential requirements and are therefore not sufficient on their own? This seems to be what Gert's Mr. DeVre is saying, and if so the system is downright out of control. I assert that despite Mr. DeVre's comments, a standard that has been published in the OJ as applicable under the EMC Directive gives presumption of conformity with the essential requirements of that directive, and is therefore, by definition, sufficient without the use of further standards. Am I wrong!? Further comments please! Thanks, Jim Suddenly flipping burgers for $5/hr doesn't sound so bad. -Original Message- From: eric.lif...@ni.com [mailto:eric.lif...@ni.com] Sent: Wednesday, October 04, 2000 11:49 AM To: CE-test - Gert Gremmen Ing. - CE-mark more ... Cc: Maxwell, Chris; 'Jim Eichner'; 'EMC-PSTC - forum' Subject: RE: Standards hierarchy Gert et al, [Critical comments re CEN removed in an attempt to maintain a professional attitude.] Can't we just recind all of these silly redundant product family standards if they are truely just informative supplements to the Generics? I'm getting tired of retesting and then rewriting hundreds of DoCs. Regards, Eric Lifsey Compliance Manager (And a miserable author of about 400 DoCs.) National Instruments Please respond to CE-test - Gert Gremmen Ing. - CE-mark more ... cet...@cetest.nl To: Maxwell, Chris chr...@gnlp.com, 'Jim Eichner' jim.eich...@xantrex.com, 'EMC-PSTC - forum' emc-p...@majordomo.ieee.org cc:(bcc: Eric Lifsey/AUS/NIC) Subject: RE: Standards hierarchy I remember to have contributed to this discussion before, and I have asked this question at the time to Robert DeVre, who is actually the EMC-consultant of the European Committee. His opinion -close to European law- (abbreviated) : == Any product or product family standard that tries to exclude any category of tests (f or categories see f.a. the generic) is actually creating a non-compliance situation for the equipment in question, as it does not comply to the essential requirements of the EMC-directive. == Do not forget that complying to a standard creates only presumption of conformity to the essential requirements. The standard writing committee did bad service to the market creating a standard trying to create an escape route. The EC ( by voice of Mr. DeVre) has contacted CENELEC to make this standard comply with the Essential requirements of the EMC-directive. Please note that there is a report available to all national committees that are charged with standards writing, that explains to what requirements future harmonized standards should comply to be acceptable to the EC and create (true) presumption of compliance for users actually using them. This technical report is numbered R210-001 (at least the version I have in front of me) and is issued by the CENELEC. It's purpose is to advise standard writing committees in: - advice on the application of generic and basic emc standards - advise on the preparation of product family or dedicated product emc standards. Please note that the compliance for product standards to this report is part of the agreement that CENELEC will prepare standards for the EC to comply with EMCD. (as CENELEC is private and EMCD is law) This report has a summary of phenomena that product and product family standards should cover: creating limits, or create a decent rationale why not. In addition: for assessment of compliance with the EMC -directive, the product family standards take precedence over the generic standards partially or totally according to the EMC domains covered. Uncovered or excluded phenomena are thus still susceptible to generic standard test requirements !!! Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === -Original Message- From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of Maxwell, Chris Sent: Tuesday, October 03, 2000 9:57 PM To: 'Jim Eichner'; 'EMC-PSTC - forum' Subject: RE: Standards hierarchy Jim, Yes, I'm sure that there was a collective groan when you mentioned EN 61000-3-2 and EN 61000-3-3 in your email. I wasn't part of it. I'm glad to see that someone else is still questioning what's going on with this standard. I think that your understanding of Basic Standards, Product Family Standards and Generic Standards is about as good as anybody's. I started a thread similar to this some
RE: Standards hierarchy
Gert et al, [Critical comments re CEN removed in an attempt to maintain a professional attitude.] Can't we just recind all of these silly redundant product family standards if they are truely just informative supplements to the Generics? I'm getting tired of retesting and then rewriting hundreds of DoCs. Regards, Eric Lifsey Compliance Manager (And a miserable author of about 400 DoCs.) National Instruments Please respond to CE-test - Gert Gremmen Ing. - CE-mark more ... cet...@cetest.nl To: Maxwell, Chris chr...@gnlp.com, 'Jim Eichner' jim.eich...@xantrex.com, 'EMC-PSTC - forum' emc-p...@majordomo.ieee.org cc:(bcc: Eric Lifsey/AUS/NIC) Subject: RE: Standards hierarchy I remember to have contributed to this discussion before, and I have asked this question at the time to Robert DeVre, who is actually the EMC-consultant of the European Committee. His opinion -close to European law- (abbreviated) : == Any product or product family standard that tries to exclude any category of tests (f or categories see f.a. the generic) is actually creating a non-compliance situation for the equipment in question, as it does not comply to the essential requirements of the EMC-directive. == Do not forget that complying to a standard creates only presumption of conformity to the essential requirements. The standard writing committee did bad service to the market creating a standard trying to create an escape route. The EC ( by voice of Mr. DeVre) has contacted CENELEC to make this standard comply with the Essential requirements of the EMC-directive. Please note that there is a report available to all national committees that are charged with standards writing, that explains to what requirements future harmonized standards should comply to be acceptable to the EC and create (true) presumption of compliance for users actually using them. This technical report is numbered R210-001 (at least the version I have in front of me) and is issued by the CENELEC. It's purpose is to advise standard writing committees in: - advice on the application of generic and basic emc standards - advise on the preparation of product family or dedicated product emc standards. Please note that the compliance for product standards to this report is part of the agreement that CENELEC will prepare standards for the EC to comply with EMCD. (as CENELEC is private and EMCD is law) This report has a summary of phenomena that product and product family standards should cover: creating limits, or create a decent rationale why not. In addition: for assessment of compliance with the EMC -directive, the product family standards take precedence over the generic standards partially or totally according to the EMC domains covered. Uncovered or excluded phenomena are thus still susceptible to generic standard test requirements !!! Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === -Original Message- From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of Maxwell, Chris Sent: Tuesday, October 03, 2000 9:57 PM To: 'Jim Eichner'; 'EMC-PSTC - forum' Subject: RE: Standards hierarchy Jim, Yes, I'm sure that there was a collective groan when you mentioned EN 61000-3-2 and EN 61000-3-3 in your email. I wasn't part of it. I'm glad to see that someone else is still questioning what's going on with this standard. I think that your understanding of Basic Standards, Product Family Standards and Generic Standards is about as good as anybody's. I started a thread similar to this some months ago. I may not be able to answer your question directly, but I can outline the response that I got so that maybe you can draw some parallels to your own situation. The last time I summarized the responses I got, I received some ridicule. Being the youngest of 11 children, I've taken my share of that and I've learned not to let it get in my way. So ... My company is in a similar situation with EN 61326-1 versus EN 61000-3-2 and 61000-3-3. EN 61326-1 is a product family standard covering test and measurement equipment.EN 61326-1 specifically includes EN 61000-3-2 and EN 61000-3-3 in the requirements for its Class B (residential) equipment. EN 61326-1 specifically excludes EN 61000-3-2 and EN 61000-3-3 from the requirements for its Class A (non-residential) equipment. The last time we discussed this, the responses I got were: (paraphrased to protect the innocent) FROM A PERSON AT A TEST LAB: EN 61000-3-2 and -3-3 are Product Standards which apply and are enforced upon any equipment falling under their scope. They cannot be excluded by a product family standard (such as EN 61326-1) with a narrower scope. FROM ONE OF THE PEOPLE ON THE PANEL THAT WROTE EN 61326-1: EN
RE: Standards hierarchy
I remember to have contributed to this discussion before, and I have asked this question at the time to Robert DeVre, who is actually the EMC-consultant of the European Committee. His opinion -close to European law- (abbreviated) : == Any product or product family standard that tries to exclude any category of tests (f or categories see f.a. the generic) is actually creating a non-compliance situation for the equipment in question, as it does not comply to the essential requirements of the EMC-directive. == Do not forget that complying to a standard creates only presumption of conformity to the essential requirements. The standard writing committee did bad service to the market creating a standard trying to create an escape route. The EC ( by voice of Mr. DeVre) has contacted CENELEC to make this standard comply with the Essential requirements of the EMC-directive. Please note that there is a report available to all national committees that are charged with standards writing, that explains to what requirements future harmonized standards should comply to be acceptable to the EC and create (true) presumption of compliance for users actually using them. This technical report is numbered R210-001 (at least the version I have in front of me) and is issued by the CENELEC. It's purpose is to advise standard writing committees in: - advice on the application of generic and basic emc standards - advise on the preparation of product family or dedicated product emc standards. Please note that the compliance for product standards to this report is part of the agreement that CENELEC will prepare standards for the EC to comply with EMCD. (as CENELEC is private and EMCD is law) This report has a summary of phenomena that product and product family standards should cover: creating limits, or create a decent rationale why not. In addition: for assessment of compliance with the EMC -directive, the product family standards take precedence over the generic standards partially or totally according to the EMC domains covered. Uncovered or excluded phenomena are thus still susceptible to generic standard test requirements !!! Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === -Original Message- From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of Maxwell, Chris Sent: Tuesday, October 03, 2000 9:57 PM To: 'Jim Eichner'; 'EMC-PSTC - forum' Subject: RE: Standards hierarchy Jim, Yes, I'm sure that there was a collective groan when you mentioned EN 61000-3-2 and EN 61000-3-3 in your email. I wasn't part of it. I'm glad to see that someone else is still questioning what's going on with this standard. I think that your understanding of Basic Standards, Product Family Standards and Generic Standards is about as good as anybody's. I started a thread similar to this some months ago. I may not be able to answer your question directly, but I can outline the response that I got so that maybe you can draw some parallels to your own situation. The last time I summarized the responses I got, I received some ridicule. Being the youngest of 11 children, I've taken my share of that and I've learned not to let it get in my way. So ... My company is in a similar situation with EN 61326-1 versus EN 61000-3-2 and 61000-3-3. EN 61326-1 is a product family standard covering test and measurement equipment.EN 61326-1 specifically includes EN 61000-3-2 and EN 61000-3-3 in the requirements for its Class B (residential) equipment. EN 61326-1 specifically excludes EN 61000-3-2 and EN 61000-3-3 from the requirements for its Class A (non-residential) equipment. The last time we discussed this, the responses I got were: (paraphrased to protect the innocent) FROM A PERSON AT A TEST LAB: EN 61000-3-2 and -3-3 are Product Standards which apply and are enforced upon any equipment falling under their scope. They cannot be excluded by a product family standard (such as EN 61326-1) with a narrower scope. FROM ONE OF THE PEOPLE ON THE PANEL THAT WROTE EN 61326-1: EN 61326-1 specifically intended to exempt its Class A equipment from EN 61000-3-2 and EN 61000-3-3. FROM AN INNOCENT BYSTANDER: EN 61000-3-2 and EN 61000-3-3 were given Product Family Standard status by a stroke of an editors pen without true CENELEC approval. They were intended to be basic standards. Chaos has ensued. At this point, I was still confused, so I emailed CENELEC using the www.cenelec.be website. FROM CENELEC: Check with ANSI (The American National Standards Institute). So, I followed my instructions: FROM ANSI: (No comment) Well there you have it. (SARCASM ALERT ) I don't understand why anyone would be confused about this standard. What has this pointed me toward? For one thing, it has
RE: Standards hierarchy
Jim, Yes, I'm sure that there was a collective groan when you mentioned EN 61000-3-2 and EN 61000-3-3 in your email. I wasn't part of it. I'm glad to see that someone else is still questioning what's going on with this standard. I think that your understanding of Basic Standards, Product Family Standards and Generic Standards is about as good as anybody's. I started a thread similar to this some months ago. I may not be able to answer your question directly, but I can outline the response that I got so that maybe you can draw some parallels to your own situation. The last time I summarized the responses I got, I received some ridicule. Being the youngest of 11 children, I've taken my share of that and I've learned not to let it get in my way. So ... My company is in a similar situation with EN 61326-1 versus EN 61000-3-2 and 61000-3-3. EN 61326-1 is a product family standard covering test and measurement equipment.EN 61326-1 specifically includes EN 61000-3-2 and EN 61000-3-3 in the requirements for its Class B (residential) equipment. EN 61326-1 specifically excludes EN 61000-3-2 and EN 61000-3-3 from the requirements for its Class A (non-residential) equipment. The last time we discussed this, the responses I got were: (paraphrased to protect the innocent) FROM A PERSON AT A TEST LAB: EN 61000-3-2 and -3-3 are Product Standards which apply and are enforced upon any equipment falling under their scope. They cannot be excluded by a product family standard (such as EN 61326-1) with a narrower scope. FROM ONE OF THE PEOPLE ON THE PANEL THAT WROTE EN 61326-1: EN 61326-1 specifically intended to exempt its Class A equipment from EN 61000-3-2 and EN 61000-3-3. FROM AN INNOCENT BYSTANDER: EN 61000-3-2 and EN 61000-3-3 were given Product Family Standard status by a stroke of an editors pen without true CENELEC approval. They were intended to be basic standards. Chaos has ensued. At this point, I was still confused, so I emailed CENELEC using the www.cenelec.be website. FROM CENELEC: Check with ANSI (The American National Standards Institute). So, I followed my instructions: FROM ANSI: (No comment) Well there you have it. (SARCASM ALERT ) I don't understand why anyone would be confused about this standard. What has this pointed me toward? For one thing, it has led me to appreciate this email group. If it wasn't for the group, I would have simply followed EN 61326-1 and never considered EN 61000-3-2 and 3-3. I may not agree with it, but the only safe path is to design and test our products for the harmonics and flicker standards. This is what I'm preparing to do. However, I really would like to see some direction from CENELEC to clear this up. I think that it would be easy enough. All CENELEC would need to do is make a short press release and hand it to Compliance Engineering, Conformity, Item ... (I apologize to publications I haven't listed). I'm sure they would be glad to print it. By the way, I have kept all of the reponses to my original query. I would be glad to forward them to you if you wish. The opinions expressed in this email are mine and mine alone. I don't think like my employer. If I did, they wouldn't have any use for me. Chris Maxwell, Design Engineer GN Nettest Optical Division 6 Rhoads Drive, Building 4 Utica, NY 13502 PH: 315-797-4449 FAX: 315-797-8024 EMAIL: chr...@gnlp.com -Original Message- From: Jim Eichner [SMTP:jim.eich...@xantrex.com] Sent: Monday, October 02, 2000 8:00 PM To: 'EMC-PSTC - forum' Subject: Standards hierarchy As relates to the EMC Directive, I am trying to straighten out my thoughts re the different classes of standards. I'll say what I thought was right and then ask my questions and ask for comments: What I thought until now: 1. Basic - underlying standards that have no force themselves but are there to provide test methods and limits or performance criteria for other standards to call out, so that a large number of other standards don't have to repeat and maintain this common material. 2. Generic - standards used in the absence of 3 or 4, that define the required tests and set limits, and may make use of Basic standards for methodology. 3. Product Family - standards that have a scope that covers a family of related equipment, and are mandatory and sufficient only in the absence of 4 below; they define the required tests and set limits, and may make use of Basic standards for methodology. 4. Product Specific - standards that cover a narrowly defined, specific type of equipment, and are therefore mandatory if your product falls within the scope; they define the required tests and set limits, and may make use of Basic standards for methodology. Hierarchy: I thought the situation was that a) you use a Specific standard if there is one, then if not you go for a Family standard, and finally, failing that, you go for the Generic standards b)
