Re: [PSES] CE Marking Provoqium
CE marking allows a product to be imported/cross borders without barrier. If something is assembled and sold inside the same EU country (the product never crosses borders), who is responsible for CE enforcement? Is it only complaint-based, or are there authorities who scan the marketplace? Pat Lawler EMC engineer On Thu, Aug 23, 2012 at 12:18 PM, John Woodgate j...@jmwa.demon.co.uk wrote: In message OF0A9DF6FC.3AF371A2-ON88257A63.005D9B3C-88257A63.005E0795@US.Schneider-E lectric.com, dated Thu, 23 Aug 2012, ralph.mcdiar...@schneider-electric.com writes: I'm surprised that customs are looking for the CE mark. I didn't think it was necessary for import, I thought it was only needed if the product was placed on the market or put into service in an EU country. It would require CE mark on the packaging; something else I didn't think was necessary. Customs look for it where it enters the EU, and, to varying extents, when it crosses state borders. I don't think you can get something into Germany or Austria without a CE mark, if it should have one. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
In message CAMsB7HRrCqmceSpy_3NDmBmutgoU3p1udWJ1j1YAL4TyYE=m...@mail.gmail.com, dated Sat, 25 Aug 2012, Pat Lawler plawl...@gmail.com writes: CE marking allows a product to be imported/cross borders without barrier. Correct. If something is assembled and sold inside the same EU country (the product never crosses borders), who is responsible for CE enforcement? Is it only complaint-based, or are there authorities who scan the marketplace? It varies. Most members states have adopted a 'complaint-driven' policy, but Germany and Austria (and maybe others) practise active market surveillance. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Is it CE Marked product sufficient to be imported/cross borders without barrier? It may mislead non technical people to believe CE mark is the only requirements for EU. What about REACH, Food Contact Materials, Packaging packaging waste, energy label, etc. directives/regulations? Is there any way to clarify the mandatory requirements to avoid confusion? Scott On 26/8/12 12:34 AM, Pat Lawler plawl...@gmail.com wrote: CE marking allows a product to be imported/cross borders without barrier. If something is assembled and sold inside the same EU country (the product never crosses borders), who is responsible for CE enforcement? Is it only complaint-based, or are there authorities who scan the marketplace? Pat Lawler EMC engineer On Thu, Aug 23, 2012 at 12:18 PM, John Woodgate j...@jmwa.demon.co.uk wrote: In message OF0A9DF6FC.3AF371A2-ON88257A63.005D9B3C-88257A63.005E0795@US.Schneider-E lectric.com, dated Thu, 23 Aug 2012, ralph.mcdiar...@schneider-electric.com writes: I'm surprised that customs are looking for the CE mark. I didn't think it was necessary for import, I thought it was only needed if the product was placed on the market or put into service in an EU country. It would require CE mark on the packaging; something else I didn't think was necessary. Customs look for it where it enters the EU, and, to varying extents, when it crosses state borders. I don't think you can get something into Germany or Austria without a CE mark, if it should have one. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
I'm surprised that customs are looking for the CE mark. I didn't think it was necessary for import, I thought it was only needed if the product was placed on the market or put into service in an EU country. It would require CE mark on the packaging; something else I didn't think was necessary. ___ Ralph McDiarmid | Schneider Electric | Solar Business | CANADA | Regulatory Compliance Engineering From: John Woodgate j...@jmwa.demon.co.uk To: EMC-PSTC@LISTSERV.IEEE.ORG Date: 08/18/2012 10:51 PM Subject: Re: [PSES] CE Marking Provoqium In message 1284c8ec9fbe4d24b6397106a3caa...@tamuracorp.com, dated Sat, 18 Aug 2012, Brian Oconnell oconne...@tamuracorp.com writes: Note that the U.S. OSHA has (figuratively) declared war on the self-declaration process, and has specifically published stuff saying that the 'CE' does not indicate the any specific safety compliance. Well, it doesn't; it's not intended to. Nor did any of the former national safety marks, such as SEMKO. The Declaration of Conformity indicates the specific safety compliance. The CE mark is an indication to customs officers and market surveillance officers that a DoC exists and the product should be admitted to the EU, cross national borders within it and can be offered for sale. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com __ This email has been scanned by the Symantec Email Security.cloud service. __ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
In message OF0A9DF6FC.3AF371A2-ON88257A63.005D9B3C-88257A63.005E0795@US.Schneider-E lectric.com, dated Thu, 23 Aug 2012, ralph.mcdiar...@schneider-electric.com writes: I'm surprised that customs are looking for the CE mark. I didn't think it was necessary for import, I thought it was only needed if the product was placed on the market or put into service in an EU country. It would require CE mark on the packaging; something else I didn't think was necessary. Customs look for it where it enters the EU, and, to varying extents, when it crosses state borders. I don't think you can get something into Germany or Austria without a CE mark, if it should have one. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Could a self-declaration 'system' function well in North America without public safety reduction? For just discrete, narrow classes of goods? You would probably see an initial increase in non-compliant products. However, this being the U.S., that would correspond to an increase in lawsuits against the manufacturers. Patty Knudsen Product Safety Engineering 17095 Via del Campo San Diego, CA 92127 858-485-3748 Teradata Labs patricia.knud...@teradata.com teradata.com Facebook -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Sunday, August 19, 2012 1:03 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium Significance of CE mark to EU customs/surveillance is obvious and not point (other than my head). Need to understand why there are different or no surveillance systems in place in North America, and if product compliance regulations are different because of regional market demands or political control issues or cultural philosophies. Could a self-declaration 'system' function well in North America without public safety reduction? For just discrete, narrow classes of goods? Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Saturday, August 18, 2012 10:43 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium In message 1284c8ec9fbe4d24b6397106a3caa...@tamuracorp.com, dated Sat, 18 Aug 2012, Brian Oconnell oconne...@tamuracorp.com writes: Note that the U.S. OSHA has (figuratively) declared war on the self-declaration process, and has specifically published stuff saying that the 'CE' does not indicate the any specific safety compliance. Well, it doesn't; it's not intended to. Nor did any of the former national safety marks, such as SEMKO. The Declaration of Conformity indicates the specific safety compliance. The CE mark is an indication to customs officers and market surveillance officers that a DoC exists and the product should be admitted to the EU, cross national borders within it and can be offered for sale. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
To add to the discussion, I believe that in 2009, the Province of Ontario, Canada intended to initiate a program forcing manufacturing electrical products to register with the Province, for a yearly fee. This was in addition to the third-party approvals held by most products. The program seemed to evaporate before implementation. IIRC, they were concerned with the number of non-approved and unsafe products that were being seen in the marketplace. This seems to indicate that the current system is not as effective as they would like in promoting the safety of products. Current surveillance budgets may not be adequate to catch these questionable products. Best Regards, Brian C. Brian Ceresney, CTech. Regulatory Team Lead, Delta-Q Technologies Corp. 3755 Willingdon Ave., Burnaby, BC Canada V5G 3H3 Tel: 604-566-8827 www.delta-q.com bceres...@delta-q.com Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Knudsen, Patricia Sent: Tuesday, August 21, 2012 12:02 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] CE Marking Provoqium Could a self-declaration 'system' function well in North America without public safety reduction? For just discrete, narrow classes of goods? You would probably see an initial increase in non-compliant products. However, this being the U.S., that would correspond to an increase in lawsuits against the manufacturers. Patty Knudsen Product Safety Engineering 17095 Via del Campo San Diego, CA 92127 858-485-3748 Teradata Labs patricia.knud...@teradata.com teradata.com Facebook -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Sunday, August 19, 2012 1:03 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium Significance of CE mark to EU customs/surveillance is obvious and not point (other than my head). Need to understand why there are different or no surveillance systems in place in North America, and if product compliance regulations are different because of regional market demands or political control issues or cultural philosophies. Could a self-declaration 'system' function well in North America without public safety reduction? For just discrete, narrow classes of goods? Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Saturday, August 18, 2012 10:43 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium In message 1284c8ec9fbe4d24b6397106a3caa...@tamuracorp.com, dated Sat, 18 Aug 2012, Brian Oconnell oconne...@tamuracorp.com writes: Note that the U.S. OSHA has (figuratively) declared war on the self-declaration process, and has specifically published stuff saying that the 'CE' does not indicate the any specific safety compliance. Well, it doesn't; it's not intended to. Nor did any of the former national safety marks, such as SEMKO. The Declaration of Conformity indicates the specific safety compliance. The CE mark is an indication to customs officers and market surveillance officers that a DoC exists and the product should be admitted to the EU, cross national borders within it and can be offered for sale. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http
Re: [PSES] CE Marking Provoqium
Brian – When ice storms took out the power lines in the Montreal metro area, a number of US generator manufacturers donated use of truck scale generators to get locals up on at least a subsistence level of power. These trucks were denied entry into Canada because they didn't bear CSA marks, though they did bear an NRTL mark. Even though you mentioned Ontario, I'm not convinced it was unsafe or unlabeled product being brought into the province by normal importation routes that drove the Ontario revenue enhancement product registration scheme. If this was truly a problem, it would have been required at the Federal level. Peter Tarver From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Tuesday, August 21, 2012 12:25 To add to the discussion, I believe that in 2009, the Province of Ontario, Canada intended to initiate a program forcing manufacturing electrical products to register with the Province, for a yearly fee. This was in addition to the third-party approvals held by most products. The program seemed to evaporate before implementation. IIRC, they were concerned with the number of non- approved and unsafe products that were being seen in the marketplace. This seems to indicate that the current system is not as effective as they would like in promoting the safety of products. Current surveillance budgets may not be adequate to catch these questionable products. This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
The working documents providing background info on the registration scheme that were posted on the Ontario website, touched on the plan and it's relation as a source of revenue to fund the activities if I recall correctly. There has been activity at the federal level to address consumer product safety...not sure if enforcement will still be left to the Provinces and Territories to enact. Kaz Gawrzyjal From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Peter Tarver Sent: Tuesday, August 21, 2012 3:53 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] CE Marking Provoqium Brian - When ice storms took out the power lines in the Montreal metro area, a number of US generator manufacturers donated use of truck scale generators to get locals up on at least a subsistence level of power. These trucks were denied entry into Canada because they didn't bear CSA marks, though they did bear an NRTL mark. Even though you mentioned Ontario, I'm not convinced it was unsafe or unlabeled product being brought into the province by normal importation routes that drove the Ontario revenue enhancement product registration scheme. If this was truly a problem, it would have been required at the Federal level. Peter Tarver From: Brian Ceresney [mailto:bceres...@delta-q.commailto:bceres...@delta-q.com] Sent: Tuesday, August 21, 2012 12:25 To add to the discussion, I believe that in 2009, the Province of Ontario, Canada intended to initiate a program forcing manufacturing electrical products to register with the Province, for a yearly fee. This was in addition to the third-party approvals held by most products. The program seemed to evaporate before implementation. IIRC, they were concerned with the number of non- approved and unsafe products that were being seen in the marketplace. This seems to indicate that the current system is not as effective as they would like in promoting the safety of products. Current surveillance budgets may not be adequate to catch these questionable products. This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
In message 4532b7d6b39370164f98f16a9a6a3...@mail.gmail.com, dated Tue, 21 Aug 2012, Peter Tarver ptar...@enphaseenergy.com writes: When ice storms took out the power lines in the Montreal metro area, a number of US generator manufacturers donated use of truck scale generators to get locals up on at least a subsistence level of power. These trucks were denied entry into Canada because they didn't bear CSA marks, though they did bear an NRTL mark. The ice and snow didn't have a CSA mark, I suppose. Why weren't they denied entry? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
All, This is pretty interesting, since CBSA (Canadian Border Services Agency, formerly Customs), does not have the authority to inspect for regulatory compliance. If this is true, the CBSA Agents were acting well outside their authority. Only the AHJ, in this case Hydro Québec, has the authority to enforce regulatory compliance for this equipment. -- Doug Nix, A.Sc.T. 2012 Chapter Chair IEEE Engineering Human Environment Joint Chapter Toronto Section, Ontario, Canada http://ewh.ieee.org/r7/toronto/chapters/humanenv.htm d...@ieee.org mobile (519) 729-5704 home (519) 650-5979 fax (519) 653-1318 Find me LinkedIn at http://www.linkedin.com/in/dougnix Want to meet? http://tungle.me/dougnix Fostering Technological Innovation and Excellence for the Benefit of Humanity. On 21-August-2012, at 17:16, John Woodgate wrote: In message 4532b7d6b39370164f98f16a9a6a3...@mail.gmail.com, dated Tue, 21 Aug 2012, Peter Tarver ptar...@enphaseenergy.com writes: When ice storms took out the power lines in the Montreal metro area, a number of US generator manufacturers donated use of truck scale generators to get locals up on at least a subsistence level of power. These trucks were denied entry into Canada because they didn't bear CSA marks, though they did bear an NRTL mark. The ice and snow didn't have a CSA mark, I suppose. Why weren't they denied entry? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Canada excels at domestic ice and snow production and doesn't need to import them. Domestic prices are already so low that Canada doesn't have to impose excessive tariffs or regulations on imported ice and snow. 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. -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Tuesday, August 21, 2012 2:16 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: CE Marking Provoqium In message 4532b7d6b39370164f98f16a9a6a3...@mail.gmail.com, dated Tue, 21 Aug 2012, Peter Tarver ptar...@enphaseenergy.com writes: When ice storms took out the power lines in the Montreal metro area, a number of US generator manufacturers donated use of truck scale generators to get locals up on at least a subsistence level of power. These trucks were denied entry into Canada because they didn't bear CSA marks, though they did bear an NRTL mark. The ice and snow didn't have a CSA mark, I suppose. Why weren't they denied entry? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
I heard that Canada sneaks excess ice into the USA by floating it across the Great Lakes. And as for their snow, well, the border is completely unprotected. Ed Price El Cajon, CA USA The opinions expressed are my own and do not necessarily reflect those of the other voices in my head. -Original Message- From: Ted Eckert [mailto:ted.eck...@microsoft.com] Sent: Tuesday, August 21, 2012 3:45 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium Canada excels at domestic ice and snow production and doesn't need to import them. Domestic prices are already so low that Canada doesn't have to impose excessive tariffs or regulations on imported ice and snow. 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. -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Tuesday, August 21, 2012 2:16 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: CE Marking Provoqium In message 4532b7d6b39370164f98f16a9a6a3...@mail.gmail.com, dated Tue, 21 Aug 2012, Peter Tarver ptar...@enphaseenergy.com writes: When ice storms took out the power lines in the Montreal metro area, a number of US generator manufacturers donated use of truck scale generators to get locals up on at least a subsistence level of power. These trucks were denied entry into Canada because they didn't bear CSA marks, though they did bear an NRTL mark. The ice and snow didn't have a CSA mark, I suppose. Why weren't they denied entry? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
The NRTLs have responsibility. OSHA regularly each NRTLs to determine if the NRTL is properly capable of assessing products to the standards for which OSHA has authorized the NRTL. If the NRTL fails the audit, it loses its standing as an NRTL. It will then lose customers and revenue. If the NRTL is found to be willingly issuing improper approvals, it can face criminal charges. The NRTL is subject to criminal law, not tort law. I have seen a number of cases where OSHA has sanctioned an NRTL because the NRTL has not adequately demonstrated that it could test to the standards it claimed it could. There also isn't a significant amount an NRTL could say in court. The NRTL can state that the samples they originally tested were compliant and that the samples reviewed during an inspection were compliant, but the NRTL cannot make any statement about the particular item that caused the problem. Unless the plaintiff's lawyer can show that his client's product had a serial number showing it was the exact sample specifically reviewed by an NRTL inspector during an audit, the NRTL cannot state that this particular sample was built correctly. The NRTL can state that the manufacturer has the capability to produce a compliant sample, but not that the manufacturer makes every sample properly. I would also state that just because the NRTL doesn't send their employees to testify in product liability suits doesn't absolve them of responsibility under tort law. An NRTL could be sued directly. If the NRTL were to recklessly issue approvals, and products with its approval were implicated in safety incidents, U.S. law would allow law suits directly against that NRTL. I don't think any NRTL wants to face a class action lawsuit in a U.S. court. 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. -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Saturday, August 18, 2012 10:48 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: CE Marking Provoqium In message e9c52f9e77c43c49a56a22691b3680be1300e...@tk5ex14mbxc301.redmond.corp.mic rosoft.com, dated Sat, 18 Aug 2012, Ted Eckert ted.eck...@microsoft.com writes: First, none of them will stand behind a customer in court. If you have an NRTL Listed system, and it fails, it is fully your responsibility. So the NRTLs have power without responsibility. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Significance of CE mark to EU customs/surveillance is obvious and not point (other than my head). Need to understand why there are different or no surveillance systems in place in North America, and if product compliance regulations are different because of regional market demands or political control issues or cultural philosophies. Could a self-declaration 'system' function well in North America without public safety reduction? For just discrete, narrow classes of goods? Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Saturday, August 18, 2012 10:43 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium In message 1284c8ec9fbe4d24b6397106a3caa...@tamuracorp.com, dated Sat, 18 Aug 2012, Brian Oconnell oconne...@tamuracorp.com writes: Note that the U.S. OSHA has (figuratively) declared war on the self-declaration process, and has specifically published stuff saying that the 'CE' does not indicate the any specific safety compliance. Well, it doesn't; it's not intended to. Nor did any of the former national safety marks, such as SEMKO. The Declaration of Conformity indicates the specific safety compliance. The CE mark is an indication to customs officers and market surveillance officers that a DoC exists and the product should be admitted to the EU, cross national borders within it and can be offered for sale. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
There are many classes of products that are under a self-declaration system in the United States. This includes products such as toys and clothing. For some textile products, the manufacturer or importer must register with some states, but the products do not need to be third-party reviewed. Other areas are the complete opposite. In some areas of food production, USDA inspectors are present during operations at food processing plants. Third-party inspections are not seen as sufficient under the current regulations. 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. -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Sunday, August 19, 2012 1:03 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: CE Marking Provoqium Significance of CE mark to EU customs/surveillance is obvious and not point (other than my head). Need to understand why there are different or no surveillance systems in place in North America, and if product compliance regulations are different because of regional market demands or political control issues or cultural philosophies. Could a self-declaration 'system' function well in North America without public safety reduction? For just discrete, narrow classes of goods? Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Saturday, August 18, 2012 10:43 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium In message 1284c8ec9fbe4d24b6397106a3caa...@tamuracorp.com, dated Sat, 18 Aug 2012, Brian Oconnell oconne...@tamuracorp.com writes: Note that the U.S. OSHA has (figuratively) declared war on the self-declaration process, and has specifically published stuff saying that the 'CE' does not indicate the any specific safety compliance. Well, it doesn't; it's not intended to. Nor did any of the former national safety marks, such as SEMKO. The Declaration of Conformity indicates the specific safety compliance. The CE mark is an indication to customs officers and market surveillance officers that a DoC exists and the product should be admitted to the EU, cross national borders within it and can be offered for sale. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
While the US has a confusing patchwork of jurisdictions, Federal, State and local, for product safety, there is action to stop counterfeit marking of products sold. See for example, http://www.esfi.org/index.cfm/page/Consumer-Safety-Alert:-Counterfeit-Electrical-Products/cdid/10361/pid/3001 http://www.cpsc.gov/ABOUT/Cpsia/sect218.html and also http://www.cpsc.gov/businfo/intl/market_en.pdf Cortland Richmond On 8/19/2012 1602, Brian Oconnell wrote: Significance of CE mark to EU customs/surveillance is obvious and not point (other than my head). Need to understand why there are different or no surveillance systems in place in North America, and if product compliance regulations are different because of regional market demands or political control issues or cultural philosophies. Could a self-declaration 'system' function well in North America without public safety reduction? For just discrete, narrow classes of goods? Brian - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Indeed, when they 47 CFR, provide the schedule for penalties and payments, and collect on these. it is law. But does 29 CFR provide the same for anybody outside of 1910? It seems a manufacture falls into the CSPA? where failure to report yourself of getting caught costs a lot... but it is after the fact. There is still no before the fact, as in registering radios, and DoC for ITE and verifying other equipment that the FCC has. Where does the CFR require an NRTL cert outside of 1910 commercial locations? or even by convoluted path to make a requirement for safety certs by 3rd party labs? ps. your business will suffer greatly if you don't, but that is a business issue. From: Peter Tarver ptar...@ieee.org To: eMC-PSTC@LISTSERV.IEEE.ORG Sent: Saturday, August 18, 2012 1:39 AM Subject: Re: [PSES] CE Marking Provoqium Date sent: Fri, 17 Aug 2012 20:40:49 From: Dward dw...@pctestlab.com Let's not confuse a CFR with law. While a Code of Federal Regulations may be backed up by a law, they are in themselves not law. While not law in a technical sense, Congress, upon creation the bureaucracies of the Executive Branch, bestowed upon them the authority that any regulations they pass shall have the power of law. Essentially Congress ceded their power to the Executive agencies they created so Congress could spend their time on more worthy pursuits, such as pointing fingers at one another in front of fawning/deriding press and enriching themselves and their campaign donors. Peter Tarver - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Commercial, safety of workers, under labor laws. This gets a business a whole lot of regulations for labor safety! Do we only market our products to business? (I do at this time.) Is there a specific law or regulation or anything else that says all and any products marketed to anyone in the USA has to safety marked by an NRTL? From: Brian Oconnell oconne...@tamuracorp.com To: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Friday, August 17, 2012 7:08 PM Subject: RE: [PSES] CE Marking Provoqium 29 CFR 1910 -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Bill Owsley Sent: Friday, August 17, 2012 3:51 PM To: ralph.mcdiar...@schneider-electric.com; Pearson, John Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium In the USA, I think there is no law requiring safety approval. But local AHJ's, authorities having jurisdiction, and insurance providers, etc. can require as a business item, that devices are 'approved' That 'requirement' won't change because it is not regulated by the government. Unless we want more laws! There are plenty of items available that not labelled with an NRTL mark. And a lot with counterfeit marks. From: ralph.mcdiar...@schneider-electric.com ralph.mcdiar...@schneider-electric.com To: Pearson, John john.pear...@polycom.com Cc: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Friday, August 17, 2012 1:16 PM Subject: Re: [PSES] CE Marking Provoqium At least it is a self-declaration process for safety and for EMC. In the USA and Canada, you must get product certified by a 3rd party for product safety. No option but to drag a product to a local test house (UL, CSA ETL, etc) and wait for them to fit you in to their schedule. I'd like to see the CE mark approach used here, but unlikely to happen in this century. ___ Ralph McDiarmid | Schneider Electric | Solar Business | CANADA | Regulatory Compliance Engineering From: Pearson, John john.pear...@polycom.com To: EMC-PSTC@LISTSERV.IEEE.ORG Date: 08/17/2012 07:15 AM Subject: Re: [PSES] CE Marking Provoqium Hi For the sake of discussion, I would like to open up for debate the suggestion the EU process is one of the most unreasonably excessive in the world. With the exception of China and Brazil this is the one major region that imposes retrospective recertification costs due to the introduction of new Safety and EMC standards on an existing design. I would like to suggest that the dates of cessation of conformity impose a requirement to reassess (test if necessary depending on the variance to the old standard) which achieves little and costs manufacturers unnecessarily. Can we discuss? Thanks John John Pearson, Senior Director, Corporate Product Compliance Polycom | Singleton Court Business Centre, Wonastow Road Ind. Est., Monmouth, UK, NP25 5JA | T: +44-(0)1753-723165 | M: +44-(0)7968-064105 This communication (including any attachments) may contain privileged or confidential information of Polycom and is intended for a specific individual. If you are not the intended recipient, you should delete this communication, including any attachments without reading or saving them in any manner and you are hereby notified that any disclosure, copying, or distribution of this communication, or the taking of any action based on it, is strictly prohibited. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sykes, Bob Sent: 17 August 2012 14:11 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix CE = Check Everything or Compliance Expensive ...It's Friday -Bob -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sundstrom, Michael Sent: Friday, August 17, 2012 8:45 AM To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix And here all these years I thought it meant: Compliance Extraordinary... Michael Sundstrom OHD TREQ Dallas Electronic Lab Analyst EMC Lead (214) 579 6312 office (940) 390 3644 cell KB5UKT -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Thursday, August 16, 2012 4:50 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix The CE marking remains the same. The meaning is 'Caveat Emptor' ;-) Regards, Lauren Crane KLA-Tencor -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Thursday, August 16, 2012 2:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix Conformité Européenne -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Doug Powell Sent: Thursday, August 16, 2012 2:30 PM To: peter_kelle...@dell.com Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix And the CE mark, what happens to it? CE = Communauté Européenne -- Thanks, -doug
Re: [PSES] CE Marking Provoqium
In message !!AAAYAJBbQmYH6FNPl0oV0KGUzsyChQAAEFWDfmYRsYJMlAsxE qSKmE4BAA==@blueyonder.co.uk, dated Sat, 18 Aug 2012, John Allen john_e_al...@blueyonder.co.uk writes: NRTLs inspect from 2 to 4 times a year, often on an unannounced basis, and that does keep manufacturers ?on their toes? I wouldn't call that 'far' more frequent, and that sort of control can be deadly - see below. and, for those NRTLs which have detailed product files against which to inspect, the chances of finding non-compliant variations is (or at least should be) much higher. The point is that this is 'after the event' control. According to our records, you were using the XY23B part, but we see that you are now using the XY23C, which is not yet approved by us, from sometime after our last inspection four months ago. We have to withdraw certification from your whole production since that inspection date until every unit you have in stock or can recover is examined and modified to conform. That will be $100 000 penalty, please. (OK, I don't know the exact procedures in case of this sort of violation, and maybe I shall never have to learn, but I hope you see what I mean.) With self-certification, the appropriate action is to determine whether the product is still compliant when the XY23C is introduced, or when the substitution is discovered, with tests if necessary, and if it is, no further action is necessary. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
John Whilst I accept the validity of some of the argument below, I have to say that whilst - particularly for the smaller manufacturers - the concept of actively looking for issues with existing products and then correcting them, it can often be more a matter (and particularly in the current business climate) of keeping your head above water by shipping as much product as possible and with fingers a bit crossed that you have got those right. Compliance control during production is a major issue for small companies, particularly as they are often introducing new features, or having to replace non-available components with those they can actually get, because they have far less clout with their suppliers. That, together with often small development teams, mean that the focus is on the now and the future and not on what happened before - and a lot of use is made of leverage from older products, and that can easily result in compliance drift in the wrong direction. As for the issue that factory inspections only picking problems after the fact, then surely it is better to do that than not to do it at all - and these do mean that the manufacturer becomes more aware of the types of deficiencies that can and do occur, and be able to prevent/minimise them in the future. I know these views have drifted somewhat away from my initially-stated scepticism on the gains from 3rd party certification over SDoC, but there is a place for both. My comment leads back to the question of whether one is actually better, or should I say more effective, than the other - and basically I think my answer would be no, but when applied together, they both play a significant part in overall good product compliance. I also think that this is particularly true for importers of products made in the Far East where importer may actually have very little real control on the items he actually receives into the EU because he is relying on the supplier to get it right but without any assurance that the latter actually is doing that. That is where genuine 3rd party certification can assist him and, should counterfeit products actually get through the net, then the false application of 3rd party certification marks could make a difference - because the relevant certification organisations may well then take direct legal action against the original suppliers in their home countries (as well as the unfortunate importer!). Anyway, just more views to fuel the fires of this rather interesting thread! :-) John Allen Compliance With Experience Ltd. W.London, UK -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: 18 August 2012 08:57 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium In message !!AAAYAJBbQmYH6FNPl0oV0KGUzsyChQAAEFWDfmYRsYJMlAsxE qSKmE4BAA==@blueyonder.co.uk, dated Sat, 18 Aug 2012, John Allen john_e_al...@blueyonder.co.uk writes: NRTLs inspect from 2 to 4 times a year, often on an unannounced basis, and that does keep manufacturers ?on their toes? I wouldn't call that 'far' more frequent, and that sort of control can be deadly - see below. and, for those NRTLs which have detailed product files against which to inspect, the chances of finding non-compliant variations is (or at least should be) much higher. The point is that this is 'after the event' control. According to our records, you were using the XY23B part, but we see that you are now using the XY23C, which is not yet approved by us, from sometime after our last inspection four months ago. We have to withdraw certification from your whole production since that inspection date until every unit you have in stock or can recover is examined and modified to conform. That will be $100 000 penalty, please. (OK, I don't know the exact procedures in case of this sort of violation, and maybe I shall never have to learn, but I hope you see what I mean.) With self-certification, the appropriate action is to determine whether the product is still compliant when the XY23C is introduced, or when the substitution is discovered, with tests if necessary, and if it is, no further action is necessary. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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
Re: [PSES] CE Marking Provoqium
In my view the European system is much more flexible for manufacturers and free from bureaucracy in its most basic form. I also find the NRTLs reasonably accessible. The most inaccessible is the IECEE CB scheme which does not allow testing at independent labs under any of the frameworks. The scheme does allow supervised manufacturer testing. One would have thought that it would be a small step to allow an SMT type process at an independent test lab even with full witnessing of the test by an NCB/CBTL. This places smaller manufacturers in countries without a local CBTL at a disadvantage. BTW, has a new word, Provoqium, been invented? I can't find it in any dictionary. Comes up as a variation of provoke. Best regards John McAuley * DISCLAIMER: The information contained in this e-mail may be confidential and is intended solely for the use of the named addressee. Access, copying or re-use of the e-mail or any information contained therein by any other person is not authorised. If you are not the intended recipient please notify us immediately by returning the e-mail to the originator _ From: Peter Tarver [mailto:ptar...@enphaseenergy.com] Sent: 17 August 2012 21:57 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium There are several NRTLs in the US. Pick your poison. With some, you pays yer money and you takes yer chances. Peter Tarver From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Friday, August 17, 2012 10:41 I agree with you Ralph. I'd like to see that type of approach here as well. It would help to remove the (almost) monopolies that exist for North American safety compliance. Brian C. This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Just ensure the updated mandatory Essential Requirements. They are:- CE Marking LVD EMC ErP RoHS Recast WEEE Recast Regards, Scott On 17/8/12 11:31 PM, John Cotman john.cot...@conformance.co.uk wrote: The CE marking process includes mandatory Essential Requirements, (written into law), which change infrequently, and to support them, voluntary standards, which are constantly being updated. There is nothing in these standards which brings about a cessation of conformity with Essential Requirements, and therefore nothing which automatically mandates retesting. The cessation dates are of the Presumption of conformity, not the conformity itself. After that date, you cannot presume that you conform, but most of the time, when you analyse the effect of an amendment, you still will. The alternative approach, which would be to write the standards into the law, would be very much more onerous and inflexible. John C From: Pearson, John [mailto:john.pear...@polycom.com] Sent: 17 August 2012 15:13 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium Hi For the sake of discussion, I would like to open up for debate the suggestion the EU process is one of the most unreasonably excessive in the world. With the exception of China and Brazil this is the one major region that imposes retrospective recertification costs due to the introduction of new Safety and EMC standards on an existing design. I would like to suggest that the dates of cessation of conformity impose a requirement to reassess (test if necessary depending on the variance to the old standard) which achieves little and costs manufacturers unnecessarily. Can we discuss? Thanks John John Pearson, Senior Director, Corporate Product Compliance Polycom | Singleton Court Business Centre, Wonastow Road Ind. Est., Monmouth, UK, NP25 5JA | T: +44-(0)1753-723165 | M: +44-(0)7968-064105 This communication (including any attachments) may contain privileged or confidential information of Polycom and is intended for a specific individual. If you are not the intended recipient, you should delete this communication, including any attachments without reading or saving them in any manner and you are hereby notified that any disclosure, copying, or distribution of this communication, or the taking of any action based on it, is strictly prohibited. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sykes, Bob Sent: 17 August 2012 14:11 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix CE = Check Everything or Compliance Expensive ...It's Friday -Bob -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] mailto:%5bmailto:emc-p...@ieee.org%5d On Behalf Of Sundstrom, Michael Sent: Friday, August 17, 2012 8:45 AM To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix And here all these years I thought it meant: Compliance Extraordinary... Michael Sundstrom OHD TREQ Dallas Electronic Lab Analyst EMC Lead (214) 579 6312 office (940) 390 3644 cell KB5UKT -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] mailto:%5bmailto:lauren.cr...@kla-tencor.com%5d Sent: Thursday, August 16, 2012 4:50 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix The CE marking remains the same. The meaning is 'Caveat Emptor' ;-) Regards, Lauren Crane KLA-Tencor -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] mailto:%5bmailto:oconne...@tamuracorp.com%5d Sent: Thursday, August 16, 2012 2:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix Conformité Européenne -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] mailto:%5bmailto:emc-p...@ieee.org%5d On Behalf Of Doug Powell Sent: Thursday, August 16, 2012 2:30 PM To: peter_kelle...@dell.com Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix And the CE mark, what happens to it? CE = Communauté Européenne -- Thanks, -doug Douglas E Powell doug...@gmail.com http://www.linkedin.com/in/dougp01 On 8/16/12, peter_kelle...@dell.com peter_kelle...@dell.com wrote: EU = European Union EC = European Community The Treaty of Lisbon which came into force in in December 2009 provided for the absorption of the entity known as the European Community by the European Union. Regards Peter. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] mailto:%5bmailto:emc-p...@ieee.org%5d On Behalf Of Scott Xe Sent: 16 August 2012 15:37 To: EMC-PSTC
Re: [PSES] CE Marking Provoqium
In message 037701cd7d34$3926d4f0$ab747ed0$@mcauley, dated Sat, 18 Aug 2012, John McAuley john.mcau...@cei.ie writes: BTW, has a new word, ?Provoqium?, been invented? I can?t find it in any dictionary. Comes up as a variation of provoke. The spelling is 'unorfadox'! Provoquium would be legitimate classical Latin, from provoco, provocare - to challenge, provoke or bring about. The 'ium' suffix is for 'a place where...', as in 'auditorium', and the modulation of 'provocium' to 'provoquium' is conventional. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
29CFR1910 applies only to the EMPLOYER and there is no requirement for OSHA purposes for a manufacturer to have their product certified by an NRTL before marketing it or selling it. The employee using the product however has the burden of demonstrating that the product meets the definition of acceptable, and for mass produced products, the easiest way for an employer to meet this requirement is to purchase NRTL certified equipment. CPSC has no requirements for certification of electrical products (unless they are considered a toy), however a few years ago CPSC staff recommended that electrical products be certified by an NRTL. Most major retailers also want NRTL approval on products they sell. While these are not law, if you want to sell your product to consumers through major retail outlets, you are almost required to have your product certified by an NRTL. Kevin Robinson On Aug 18, 2012, at 2:42 AM, Bill Owsley wdows...@yahoo.com wrote: Indeed, when they 47 CFR, provide the schedule for penalties and payments, and collect on these. it is law. But does 29 CFR provide the same for anybody outside of 1910? It seems a manufacture falls into the CSPA? where failure to report yourself of getting caught costs a lot... but it is after the fact. There is still no before the fact, as in registering radios, and DoC for ITE and verifying other equipment that the FCC has. Where does the CFR require an NRTL cert outside of 1910 commercial locations? or even by convoluted path to make a requirement for safety certs by 3rd party labs? ps. your business will suffer greatly if you don't, but that is a business issue. From: Peter Tarver ptar...@ieee.org To: eMC-PSTC@LISTSERV.IEEE.ORG Sent: Saturday, August 18, 2012 1:39 AM Subject: Re: [PSES] CE Marking Provoqium Date sent: Fri, 17 Aug 2012 20:40:49 From: Dward dw...@pctestlab.com Let's not confuse a CFR with law. While a Code of Federal Regulations may be backed up by a law, they are in themselves not law. While not law in a technical sense, Congress, upon creation the bureaucracies of the Executive Branch, bestowed upon them the authority that any regulations they pass shall have the power of law. Essentially Congress ceded their power to the Executive agencies they created so Congress could spend their time on more worthy pursuits, such as pointing fingers at one another in front of fawning/deriding press and enriching themselves and their campaign donors. Peter Tarver - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html
Re: [PSES] CE Marking Provoqium
Date sent: Sat, 18 Aug 2012 08:56:30 +0100 Send reply to: John Woodgate j...@jmwa.demon.co.uk In message !!AAAYAJBbQmYH6FNPl0oV0KGUzsyChQAAEFWDfmYRsYJMlAsxE qSKmE4BAA==@blueyonder.co.uk, dated Sat, 18 Aug 2012, John Allen john_e_al...@blueyonder.co.uk writes: NRTLs inspect from 2 to 4 times a year, often on an unannounced basis, and that does keep manufacturers ?on their toes? I wouldn't call that 'far' more frequent, and that sort of control can be deadly - see below. 100% to 400% more often. How often would give you confidence? As a former NRTL (noninspecting) employee, I was subjected to noise from some manufacturer's about how intrusive quarterly inspections were. I suspect there's no system that will satisfy all players. With self-certification, the appropriate action is to determine whether the product is still compliant when the XY23C is introduced, or when the substitution is discovered, with tests if necessary, and if it is, no further action is necessary. At another former employer, I heard a story of a moderately large piece of rack mountable equipment designed by an European subsidiary intended for the European market that could not be brought into compliance with radiated emissions limits using standardized test methods without significant revisit to the drawing board. Their solution? Place the unit on its back. Et voila! A self certification was emitted. I would not call this company small. I could speculate as to what other special considerations might have been found self certifiable. I'd like to hear other stories of the self certification regime. Peter Tarver - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
In message 502fb647.26423.642b...@ptarver.ieee.org, dated Sat, 18 Aug 2012, Peter Tarver ptar...@ieee.org writes: 100% to 400% more often. How often would give you confidence? Actually it's 100% to 300%, but never mind. It's not about confidence, it's whether another approach is better. As a former NRTL (noninspecting) employee, I was subjected to noise from some manufacturer's about how intrusive quarterly inspections were. Yes, they are; my point is that they aren't a good way to control conformity either. I suspect there's no system that will satisfy all players. I'm sure we can agree on that! With self-certification, the appropriate action is to determine whether the product is still compliant when the XY23C is introduced, or when the substitution is discovered, with tests if necessary, and if it is, no further action is necessary. At another former employer, I heard a story of a moderately large piece of rack mountable equipment designed by an European subsidiary intended for the European market that could not be brought into compliance with radiated emissions limits using standardized test methods without significant revisit to the drawing board. Their solution? Place the unit on its back. Et voila! A self certification was emitted. If the product was going to Germany or Austria, there is a risk that the product would be rejected by active surveillance. In other countries, it would only be rejected if it actually caused interference. Autre pays, autre moeurs. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Nothing I say necessarily reflects the policy of my employer. I shall endeavor to be more precise, or go home and bother other people. The CFR is Administrative Law, and is has been reinforced as such by several SCOTUS rulings, where the 'informed discretion' of agencies is the basis to make regulations that are enforceable via the original act(s). As Dennis Ward noted, the basis of these regulations must be supported by enacted statute. For non-Americans reading this drivel, when you see 'xyz CFR abc', the reference is regulations, which is administrative law. When the notation is 'xy USC abc', the reference is literal statutes, which is legislated law. The essential relationship is that the USC typically has no implementation until the CFR is published. Back to OT - Note that the U.S. OSHA has (figuratively) declared war on the self-declaration process, and has specifically published stuff saying that the 'CE' does not indicate the any specific safety compliance. Follow the money. Look at filing reports for lobbyists and political campaigns and you will see how and why, and whom are the power brokers that influence the U.S. federal government's product compliance policy and law. Brian -Original Message- From: Dward [mailto:dw...@pctestlab.com] Sent: Friday, August 17, 2012 8:41 PM To: oconne...@tamuracorp.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] CE Marking Provoqium Let's not confuse a CFR with law. While a Code of Federal Regulations may be backed up by a law, they are in themselves not law. It is like CFR 47 for telecom. The only teeth it has is contained in the telecommuncations act of 1934 updated in 1999. Outside this law, the CFR has no teeth whatsoever. Also, let's remember that OSHA is the OCCUPATIONAL Safety and Health Administration formed by the OSHA act of 1970 and as such ONLY has regulatory power as it pertains to the work environment. And while the OSHA act of 1970 is law, CFR29 is not. It has no authority to do more. Thanks -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Friday, August 17, 2012 4:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium The assertions were In the USA, I think there is no law requiring safety approval. But local AHJ's, authorities having jurisdiction, and insurance providers, etc. can require as a business item, that devices are 'approved' That 'requirement' won't change because it is not regulated by the government. My reply was simply 29 CFR 1910. While local AHJs may or may not require certification for equipment and materials in both residential and commercial, the federal code is a statute; it is not policy. There is are federal 'laws' that require safety certification for equipment used on commercial sites. And the federal laws indicate that while local authorities can pass policy or code to regulate safety of equipment, the requirements of local code for the workplace must at least meet federal law. I have had this problem with each new manager or executive - There is no law requiring any of this. Ok, we will just sell this 500kVA, 477V transformer for use in private homes only... Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Peter Tarver Sent: Friday, August 17, 2012 4:17 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] CE Marking Provoqium which only applies to the work place. From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Friday, August 17, 2012 16:09 29 CFR 1910 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Disclaimer: I'm not arguing for one system or another. I'm only trying to provide a bit more background for the differences in the two systems based on personal experience. I've worked with both systems for a while, and I've had my share of problems with NRTLs. I also recognize that my opinions may not be shared by everybody. However, I'm interested in a good discussion and I'm open to alternate views. Read on and then fire away. One of the reasons third-party certification persists in the United States is because there is very little market surveillance. Electrical inspectors may check for a third-party approval if the inspector is closing out an electrical permit. However, this doesn't always happen. Consumer products almost never get checked unless there is a reported problem. Retailers may enforce their own standards, and most large retailers will require manufacturers to have third-party approval before the retailer will carry the product. Smaller stores often don't have any requirements and electronics that have never been tested can easily be purchased in the United States. The United States also generally enforces electrical codes at the city or county level. There are cases where cities have their own code or you may have rules common state-wide. The federal requirements were partly imposed because there was such a disparity in practice from one jurisdiction to another. Employees in one state or city might have local inspectors who ensure that there is a safe workplace while employees in another jurisdiction might be exposed to far more hazardous equipment. In my opinion, if the United States switched to a self-declaration system, greater market surveillance would be required to prevent unscrupulous manufacturers from selling their products. I see far more product recalls on the EU RAPEX site than from the CPSC. Let me add a few items about the Nationally Recognized Test Laboratories (NRTLs). I've worked with quite a few of them and they all have a few things in common. First, none of them will stand behind a customer in court. If you have an NRTL Listed system, and it fails, it is fully your responsibility. The NRTL operating agreements and contracts provide liability protection. The manufacturer agrees to take full responsibility when they sign the contract with the NRTL. If your product fails, you are responsible. Companies can use NRTL Listing to show that they did due diligence in trying to design a safe product, but NRTL Listing won't get you much more in court. Under the U.S. system, the manufacturer and their liability insurance carrier feel the responsibility and they pay if something goes wrong. The NRTL Listing is only another piece of evidence you have to try to convince the jury to see things your way. Second, I've never had a significant problem when an alternate part was used in manufacturing before the NRTL report could be updated properly. At a previous employer, a sourcing manager would occasionally find a cheaper part. The review system wasn't prefect and parts could be put into production without notifying the safety engineering department. When the NRTL found it during an inspection, hassles were minimal. The NRTL inspector could make the determination on the spot that the new part was as acceptable as the old part. In that case, the manufacturer was given a fixed amount of time to update their report, but no production was held up. If the NRTL inspector couldn't make the determination, I was able to work quickly with the NRTL engineering office to show that the new part was acceptable. This could usually be completed within 24 hours. The NRTL would restrict shipments from the factory of the products with their mark until the issue was resolved. However, production! could continue. I've never worked for a company where a component substitution could result in a potential hazard, so I can't comment on that from personal experience. However, if that should happen, the NRTL can determine what level of rework is required. If there is no significant hazard, the NRTL may require rework to current inventory and new production. If the hazard is more significant, the NRTL might request some type of field action. However, in this case, the NRTL might actually be preventing potentially hazardous products from being shipped. This system does raise the cost of using alternate components. If you find a part that is better due to cost, quality or performance, you still have to pay a fee to demonstrate this to the NRTL. This does affect the company's ability to make nimble changes and that is definitely a drawback. The NRTL inspections are also based on the risk. For most product types, the NRTLs will inspect about 4 times a year. However, if a manufacturer repeatedly has problems, the NRTL will typically increase the frequency of the inspections. If the problems are not resolved in a satisfactory timeframe, the NRTL
Re: [PSES] CE Marking Provoqium
In message 1284c8ec9fbe4d24b6397106a3caa...@tamuracorp.com, dated Sat, 18 Aug 2012, Brian Oconnell oconne...@tamuracorp.com writes: Note that the U.S. OSHA has (figuratively) declared war on the self-declaration process, and has specifically published stuff saying that the 'CE' does not indicate the any specific safety compliance. Well, it doesn't; it's not intended to. Nor did any of the former national safety marks, such as SEMKO. The Declaration of Conformity indicates the specific safety compliance. The CE mark is an indication to customs officers and market surveillance officers that a DoC exists and the product should be admitted to the EU, cross national borders within it and can be offered for sale. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
In message e9c52f9e77c43c49a56a22691b3680be1300e...@tk5ex14mbxc301.redmond.corp.mic rosoft.com, dated Sat, 18 Aug 2012, Ted Eckert ted.eck...@microsoft.com writes: First, none of them will stand behind a customer in court. If you have an NRTL Listed system, and it fails, it is fully your responsibility. So the NRTLs have power without responsibility. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Hi For the sake of discussion, I would like to open up for debate the suggestion the EU process is one of the most unreasonably excessive in the world. With the exception of China and Brazil this is the one major region that imposes retrospective recertification costs due to the introduction of new Safety and EMC standards on an existing design. I would like to suggest that the dates of cessation of conformity impose a requirement to reassess (test if necessary depending on the variance to the old standard) which achieves little and costs manufacturers unnecessarily. Can we discuss? Thanks John John Pearson, Senior Director, Corporate Product Compliance Polycom | Singleton Court Business Centre, Wonastow Road Ind. Est., Monmouth, UK, NP25 5JA | T: +44-(0)1753-723165 | M: +44-(0)7968-064105 This communication (including any attachments) may contain privileged or confidential information of Polycom and is intended for a specific individual. If you are not the intended recipient, you should delete this communication, including any attachments without reading or saving them in any manner and you are hereby notified that any disclosure, copying, or distribution of this communication, or the taking of any action based on it, is strictly prohibited. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sykes, Bob Sent: 17 August 2012 14:11 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix CE = Check Everything or Compliance Expensive ...It's Friday -Bob -Original Message- From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of Sundstrom, Michael Sent: Friday, August 17, 2012 8:45 AM To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix And here all these years I thought it meant: Compliance Extraordinary... Michael Sundstrom OHD TREQ Dallas Electronic Lab Analyst EMC Lead (214) 579 6312 office (940) 390 3644 cell KB5UKT -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]mailto:[mailto:lauren.cr...@kla-tencor.com] Sent: Thursday, August 16, 2012 4:50 PM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix The CE marking remains the same. The meaning is 'Caveat Emptor' ;-) Regards, Lauren Crane KLA-Tencor -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com]mailto:[mailto:oconne...@tamuracorp.com] Sent: Thursday, August 16, 2012 2:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix Conformité Européenne -Original Message- From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org]On Behalf Of Doug Powell Sent: Thursday, August 16, 2012 2:30 PM To: peter_kelle...@dell.commailto:peter_kelle...@dell.com Cc: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix And the CE mark, what happens to it? CE = Communauté Européenne -- Thanks, -doug Douglas E Powell doug...@gmail.commailto:doug...@gmail.com http://www.linkedin.com/in/dougp01 On 8/16/12, peter_kelle...@dell.commailto:peter_kelle...@dell.com peter_kelle...@dell.commailto:peter_kelle...@dell.com wrote: EU = European Union EC = European Community The Treaty of Lisbon which came into force in in December 2009 provided for the absorption of the entity known as the European Community by the European Union. Regards Peter. From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org]mailto:[mailto:emc-p...@ieee.org] On Behalf Of Scott Xe Sent: 16 August 2012 15:37 To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: EC vs EU suffix The EU regulations/decisions/directives published after 2010 have a suffix of EU rather than EC. Is there any particular reason for this change? Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher:
Re: [PSES] CE Marking Provoqium
In message 04cab9802ba27a409548dd47de1da7ef266d35e...@slomailprd01.polycom.com, dated Fri, 17 Aug 2012, Pearson, John john.pear...@polycom.com writes: For the sake of discussion, I would like to open up for debate the suggestion the EU process is one of the most unreasonably excessive in the world. We can establish some initial facts and questions: 1. Revisions of requirements are based in international or regional standards, developed in essentially inclusive forums. 2. Are US regulatory requirements developed in equally inclusive fora? 3. Revisions are very rarely about making requirements more stringent, and these days any proposed need for that has to be really proven. 4. Revisions are mostly about embracing new technologies, improved methods of measurement and more insightful principles (like hazard-based safety assessment). 5. Dissatisfaction with new requirements often stems from not participating in the discussions processes leading up to them. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
At least it is a self-declaration process for safety and for EMC. In the USA and Canada, you must get product certified by a 3rd party for product safety. No option but to drag a product to a local test house (UL, CSA ETL, etc) and wait for them to fit you in to their schedule. I'd like to see the CE mark approach used here, but unlikely to happen in this century. ___ Ralph McDiarmid | Schneider Electric | Solar Business | CANADA | Regulatory Compliance Engineering From: Pearson, John john.pear...@polycom.com To: EMC-PSTC@LISTSERV.IEEE.ORG Date: 08/17/2012 07:15 AM Subject: Re: [PSES] CE Marking Provoqium Hi For the sake of discussion, I would like to open up for debate the suggestion the EU process is one of the most unreasonably excessive in the world. With the exception of China and Brazil this is the one major region that imposes retrospective recertification costs due to the introduction of new Safety and EMC standards on an existing design. I would like to suggest that the dates of cessation of conformity impose a requirement to reassess (test if necessary depending on the variance to the old standard) which achieves little and costs manufacturers unnecessarily. Can we discuss? Thanks John John Pearson, Senior Director, Corporate Product Compliance Polycom | Singleton Court Business Centre, Wonastow Road Ind. Est., Monmouth, UK, NP25 5JA | T: +44-(0)1753-723165 | M: +44-(0)7968-064105 This communication (including any attachments) may contain privileged or confidential information of Polycom and is intended for a specific individual. If you are not the intended recipient, you should delete this communication, including any attachments without reading or saving them in any manner and you are hereby notified that any disclosure, copying, or distribution of this communication, or the taking of any action based on it, is strictly prohibited. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sykes, Bob Sent: 17 August 2012 14:11 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix CE = Check Everything or Compliance Expensive ...It's Friday -Bob -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sundstrom, Michael Sent: Friday, August 17, 2012 8:45 AM To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix And here all these years I thought it meant: Compliance Extraordinary... Michael Sundstrom OHD TREQ Dallas Electronic Lab Analyst EMC Lead (214) 579 6312 office (940) 390 3644 cell KB5UKT -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Thursday, August 16, 2012 4:50 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix The CE marking remains the same. The meaning is 'Caveat Emptor' ;-) Regards, Lauren Crane KLA-Tencor -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Thursday, August 16, 2012 2:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix Conformité Européenne -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Doug Powell Sent: Thursday, August 16, 2012 2:30 PM To: peter_kelle...@dell.com Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix And the CE mark, what happens to it? CE = Communauté Européenne -- Thanks, -doug Douglas E Powell doug...@gmail.com http://www.linkedin.com/in/dougp01 On 8/16/12, peter_kelle...@dell.com peter_kelle...@dell.com wrote: EU = European Union EC = European Community The Treaty of Lisbon which came into force in in December 2009 provided for the absorption of the entity known as the European Community by the European Union. Regards Peter. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Scott Xe Sent: 16 August 2012 15:37 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: EC vs EU suffix The EU regulations/decisions/directives published after 2010 have a suffix of EU rather than EC. Is there any particular reason for this change? Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators
Re: [PSES] CE Marking Provoqium
'Natural EOL', per term in post by John Pearson, for the EU would have to be codified (in a directive?) because this tends to vary from one CAB to another. Many agencies immediately withdraw the cert when version of the standard used in the test report is obsoleted by OJ. More laws? For North America, 'Natural EOL' is seldom regulated so becomes a point of policy for NRTLs and SCCs. Some agencies will allow a product to be listed and bear their mark to an obsolete version almost indefinitely. More laws? Brian - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
There are several NRTLs in the US. Pick your poison. With some, you pays yer money and you takes yer chances. Peter Tarver *From:* Brian Ceresney [mailto:bceres...@delta-q.com] *Sent:* Friday, August 17, 2012 10:41 I agree with you Ralph. I’d like to see that type of approach here as well. It would help to remove the (almost) monopolies that exist for North American safety compliance. Brian C. This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Which takes us pretty neatly back to Caveat Emptor. Mebbe them 'uropeen's are on to something! Have a good weekend, all. Nick. On 17 Aug 2012, at 21:57, Peter Tarver wrote: There are several NRTLs in the US. Pick your poison. With some, you pays yer money and you takes yer chances. Peter Tarver From: Brian Ceresney [mailto:bceres...@delta-q.com] Sent: Friday, August 17, 2012 10:41 I agree with you Ralph. I’d like to see that type of approach here as well. It would help to remove the (almost) monopolies that exist for North American safety compliance. Brian C. This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: nick.willi...@conformance.co.uk - Conformance Ltd - Product safety, approvals and CE-marking consultants The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk Registered in England, Company No. 3478646 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
In message ad0d0935-99b5-41d4-a644-177bfc31d...@conformance.co.uk, dated Fri, 17 Aug 2012, Nick Williams nick.willi...@conformance.co.uk writes: Mebbe them 'uropeen's are on to something! There's a fundamental reason for self-certification. If a certification body takes responsibility for compliance for a significant number of clients, its liabilities at law are huge. Some 30 years ago, it was suggested that such bodies should carry insurance of 70 million Euros. Also, annual inspections are nowhere near enough for an independent body to properly monitor whether what is being made is actually conforming, and that requires repeated test charges. With self-certification, the manufacturer's product liability insurance provides the necessary security, and the manufacturer 'feels', as well as is, responsible for the conformity of the product. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Instead of saying that the government is doing too little, too late or too much, too early, say they've got is exactly right, thus throwing them into total confusion. 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
In the USA, I think there is no law requiring safety approval. But local AHJ's, authorities having jurisdiction, and insurance providers, etc. can require as a business item, that devices are 'approved' That 'requirement' won't change because it is not regulated by the government. Unless we want more laws! There are plenty of items available that not labelled with an NRTL mark. And a lot with counterfeit marks. From: ralph.mcdiar...@schneider-electric.com ralph.mcdiar...@schneider-electric.com To: Pearson, John john.pear...@polycom.com Cc: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Friday, August 17, 2012 1:16 PM Subject: Re: [PSES] CE Marking Provoqium At least it is a self-declaration process for safety and for EMC. In the USA and Canada, you must get product certified by a 3rd party for product safety. No option but to drag a product to a local test house (UL, CSA ETL, etc) and wait for them to fit you in to their schedule. I'd like to see the CE mark approach used here, but unlikely to happen in this century. ___ Ralph McDiarmid | Schneider Electric | Solar Business | CANADA | Regulatory Compliance Engineering From: Pearson, John john.pear...@polycom.com To: EMC-PSTC@LISTSERV.IEEE.ORG Date: 08/17/2012 07:15 AM Subject: Re: [PSES] CE Marking Provoqium Hi For the sake of discussion, I would like to open up for debate the suggestion the EU process is one of the most unreasonably excessive in the world. With the exception of China and Brazil this is the one major region that imposes retrospective recertification costs due to the introduction of new Safety and EMC standards on an existing design. I would like to suggest that the dates of cessation of conformity impose a requirement to reassess (test if necessary depending on the variance to the old standard) which achieves little and costs manufacturers unnecessarily. Can we discuss? Thanks John John Pearson, Senior Director, Corporate Product Compliance Polycom|Singleton Court Business Centre, Wonastow Road Ind. Est., Monmouth, UK, NP25 5JA|T: +44-(0)1753-723165|M: +44-(0)7968-064105 This communication (including any attachments) may contain privileged or confidential information of Polycom and is intended for a specific individual. If you are not the intended recipient, you should delete this communication, including any attachments without reading or saving them in any manner and you are hereby notified that any disclosure, copying, or distribution of this communication, or the taking of any action based on it, is strictly prohibited. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sykes, Bob Sent: 17 August 2012 14:11 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix CE = Check Everything or Compliance Expensive ...It's Friday -Bob -Original Message- From: emc-p...@ieee.org[mailto:emc-p...@ieee.org]On Behalf Of Sundstrom, Michael Sent: Friday, August 17, 2012 8:45 AM To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix And here all these years I thought it meant: Compliance Extraordinary... Michael Sundstrom OHD TREQ Dallas Electronic Lab Analyst EMC Lead (214) 579 6312 office (940) 390 3644 cell KB5UKT -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Thursday, August 16, 2012 4:50 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix The CE marking remains the same. The meaning is 'Caveat Emptor' ;-) Regards, Lauren Crane KLA-Tencor -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Thursday, August 16, 2012 2:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix Conformité Européenne -Original Message- From: emc-p...@ieee.org[mailto:emc-p...@ieee.org]On Behalf Of Doug Powell Sent: Thursday, August 16, 2012 2:30 PM To: peter_kelle...@dell.com Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix And the CE mark, what happens to it? CE = Communauté Européenne -- Thanks, -doug Douglas E Powell doug...@gmail.com http://www.linkedin.com/in/dougp01 On 8/16/12, peter_kelle...@dell.competer_kelle...@dell.com wrote: EU = European Union EC = European Community The Treaty of Lisbon which came into force in in December 2009 provided for the absorption of the entity known as the European Community by the European Union. Regards Peter. From: emc-p...@ieee.org[mailto:emc-p...@ieee.org]On Behalf Of Scott Xe Sent: 16 August 2012 15:37 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: EC vs EU suffix The EU regulations/decisions/directives published after
Re: [PSES] CE Marking Provoqium
29 CFR 1910 -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Bill Owsley Sent: Friday, August 17, 2012 3:51 PM To: ralph.mcdiar...@schneider-electric.com; Pearson, John Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium In the USA, I think there is no law requiring safety approval. But local AHJ's, authorities having jurisdiction, and insurance providers, etc. can require as a business item, that devices are 'approved' That 'requirement' won't change because it is not regulated by the government. Unless we want more laws! There are plenty of items available that not labelled with an NRTL mark. And a lot with counterfeit marks. From: ralph.mcdiar...@schneider-electric.com ralph.mcdiar...@schneider-electric.com To: Pearson, John john.pear...@polycom.com Cc: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Friday, August 17, 2012 1:16 PM Subject: Re: [PSES] CE Marking Provoqium At least it is a self-declaration process for safety and for EMC. In the USA and Canada, you must get product certified by a 3rd party for product safety. No option but to drag a product to a local test house (UL, CSA ETL, etc) and wait for them to fit you in to their schedule. I'd like to see the CE mark approach used here, but unlikely to happen in this century. ___ Ralph McDiarmid | Schneider Electric | Solar Business | CANADA | Regulatory Compliance Engineering From: Pearson, John john.pear...@polycom.com To: EMC-PSTC@LISTSERV.IEEE.ORG Date: 08/17/2012 07:15 AM Subject: Re: [PSES] CE Marking Provoqium Hi For the sake of discussion, I would like to open up for debate the suggestion the EU process is one of the most unreasonably excessive in the world. With the exception of China and Brazil this is the one major region that imposes retrospective recertification costs due to the introduction of new Safety and EMC standards on an existing design. I would like to suggest that the dates of cessation of conformity impose a requirement to reassess (test if necessary depending on the variance to the old standard) which achieves little and costs manufacturers unnecessarily. Can we discuss? Thanks John John Pearson, Senior Director, Corporate Product Compliance Polycom | Singleton Court Business Centre, Wonastow Road Ind. Est., Monmouth, UK, NP25 5JA | T: +44-(0)1753-723165 | M: +44-(0)7968-064105 This communication (including any attachments) may contain privileged or confidential information of Polycom and is intended for a specific individual. If you are not the intended recipient, you should delete this communication, including any attachments without reading or saving them in any manner and you are hereby notified that any disclosure, copying, or distribution of this communication, or the taking of any action based on it, is strictly prohibited. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sykes, Bob Sent: 17 August 2012 14:11 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix CE = Check Everything or Compliance Expensive ...It's Friday -Bob -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Sundstrom, Michael Sent: Friday, August 17, 2012 8:45 AM To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC vs EU suffix And here all these years I thought it meant: Compliance Extraordinary... Michael Sundstrom OHD TREQ Dallas Electronic Lab Analyst EMC Lead (214) 579 6312 office (940) 390 3644 cell KB5UKT -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Thursday, August 16, 2012 4:50 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix The CE marking remains the same. The meaning is 'Caveat Emptor' ;-) Regards, Lauren Crane KLA-Tencor -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Thursday, August 16, 2012 2:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix Conformité Européenne -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Doug Powell Sent: Thursday, August 16, 2012 2:30 PM To: peter_kelle...@dell.com Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC vs EU suffix And the CE mark, what happens to it? CE = Communauté Européenne -- Thanks, -doug Douglas E Powell doug...@gmail.com http://www.linkedin.com/in/dougp01 On 8/16/12, peter_kelle...@dell.com peter_kelle...@dell.com wrote: EU = European Union EC = European Community The Treaty of Lisbon which came into force in in December 2009 provided for the absorption of the entity known as the European Community by the European Union. Regards Peter. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Scott Xe Sent: 16 August 2012 15:37 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: EC vs EU
Re: [PSES] CE Marking Provoqium
which only applies to the work place. From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Friday, August 17, 2012 16:09 29 CFR 1910 This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
The assertions were In the USA, I think there is no law requiring safety approval. But local AHJ's, authorities having jurisdiction, and insurance providers, etc. can require as a business item, that devices are 'approved' That 'requirement' won't change because it is not regulated by the government. My reply was simply 29 CFR 1910. While local AHJs may or may not require certification for equipment and materials in both residential and commercial, the federal code is a statute; it is not policy. There is are federal 'laws' that require safety certification for equipment used on commercial sites. And the federal laws indicate that while local authorities can pass policy or code to regulate safety of equipment, the requirements of local code for the workplace must at least meet federal law. I have had this problem with each new manager or executive - There is no law requiring any of this. Ok, we will just sell this 500kVA, 477V transformer for use in private homes only... Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Peter Tarver Sent: Friday, August 17, 2012 4:17 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] CE Marking Provoqium which only applies to the work place. From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Friday, August 17, 2012 16:09 29 CFR 1910 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Let's not confuse a CFR with law. While a Code of Federal Regulations may be backed up by a law, they are in themselves not law. It is like CFR 47 for telecom. The only teeth it has is contained in the telecommuncations act of 1934 updated in 1999. Outside this law, the CFR has no teeth whatsoever. Also, let's remember that OSHA is the OCCUPATIONAL Safety and Health Administration formed by the OSHA act of 1970 and as such ONLY has regulatory power as it pertains to the work environment. And while the OSHA act of 1970 is law, CFR29 is not. It has no authority to do more. Thanks -Original Message- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Friday, August 17, 2012 4:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking Provoqium The assertions were In the USA, I think there is no law requiring safety approval. But local AHJ's, authorities having jurisdiction, and insurance providers, etc. can require as a business item, that devices are 'approved' That 'requirement' won't change because it is not regulated by the government. My reply was simply 29 CFR 1910. While local AHJs may or may not require certification for equipment and materials in both residential and commercial, the federal code is a statute; it is not policy. There is are federal 'laws' that require safety certification for equipment used on commercial sites. And the federal laws indicate that while local authorities can pass policy or code to regulate safety of equipment, the requirements of local code for the workplace must at least meet federal law. I have had this problem with each new manager or executive - There is no law requiring any of this. Ok, we will just sell this 500kVA, 477V transformer for use in private homes only... Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Peter Tarver Sent: Friday, August 17, 2012 4:17 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] CE Marking Provoqium which only applies to the work place. From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Friday, August 17, 2012 16:09 29 CFR 1910 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] CE Marking Provoqium
Date sent: Fri, 17 Aug 2012 20:40:49 From: Dward dw...@pctestlab.com Let's not confuse a CFR with law. While a Code of Federal Regulations may be backed up by a law, they are in themselves not law. While not law in a technical sense, Congress, upon creation the bureaucracies of the Executive Branch, bestowed upon them the authority that any regulations they pass shall have the power of law. Essentially Congress ceded their power to the Executive agencies they created so Congress could spend their time on more worthy pursuits, such as pointing fingers at one another in front of fawning/deriding press and enriching themselves and their campaign donors. Peter Tarver - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
