Re: [PSES] PLC password

[Richard Nute]

 

Hi Steve:

 

A possible analogy might be providing a 3-to-2-wire adaptor for your product.  
Clearly, doing so results in a misuse of the product (operating a Class 1 
product without a ground).  Safety standards require the product be safe in the 
event of misuse.  

 

Giving the password to a customer results, in my opinion, in misuse of the 
product, which, according to many safety standards, is a condition which must 
be safe.  

 

Providing a password to one customer means that all customers may get the 
password from the first customer.  Your manufacturer loses control of the 
password and might as well not use a password.  

 

Best regards,

Rich

  

 

From: sgbrody  
Sent: Thursday, June 1, 2023 3:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] PLC password

 

I have been asked if there is a standard, or comments within s standard, that 
discusses giving a customer the password to allow them to reprogram the PLC 
when they remove a device and the light curtain that protected it.

 

I believe, that other than it being a terrible idea, that it would probably 
invalidate any approvals the end product had.

 

The customer is asking for a document that supports my opinion.

 

I dud suggest that we send a service person to do the change, and not give up 
the pw.

 

Thoughts?

 

 

 

Sent from my T-Mobile 5G Device

 

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Re: [PSES] PLC password

[John Mcbain]

The keys to product modification in the field vs. maintaining certification
are -
(a) Is the field modification acceptable to the certifying body?
Ordinarily, certification is only for the product as built and shipped from
the factory, along with applicable assembly and installation instructions.
Field modification without prior approval usually would be considered to
invalidate the existing certification, unless the modification is trivial
for safety purposes. If the factory inspector from the certifying body
would accept the same modification done in the factory without comment,
then you may be OK.
(b) Who has responsibility - manufacturer, importer, distributor or
user/customer?  The certification from the manufacturer will cover a
specific construction, configuration and usage. However, an end user
certainly can get certification for machinery that has been considerably
modified from what the manufacturer provided.  Of course that would require
a new DofC and CE Marking.
But if the manufacturer provides the means to do the modification, then the
manufacturer apparently is accepting responsibility - even if the
modification has not been accepted by the certifying body and therefore
invalidates the certification!

Best regards,
John McBain


On Fri, Jun 2, 2023 at 9:33 AM Lauren Crane <
1afd08519f18-dmarc-requ...@listserv.ieee.org> wrote:

> Hi Steve,
>
>
>
> My Friday 2c…
>
>
>
> There is a trend of “right to repair” legislation that might
> contraindicate that position to some extent. See e.g.
> https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023PC0155
>
>
>
> It seems odd that the approval of a product would depend on the whether
> the end user can modify the product or not. There isn’t a certified item I
> have that I can’t modify in some dangerous way. There is an important
> difference between de-certification of a product unit because it has been
> modified vs. de-certification of a product line because it can be modified.
>
>
>
> Best Regards,
>
> -Lauren
>
>
>
> *From:* sgbrody 
> *Sent:* Thursday, June 1, 2023 5:51 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] PLC password
>
>
>
>
>
> *External Email:* Do NOT reply, click on links, or open attachments
> *unless* you recognize the sender and know the content is safe. If you
> believe this email may be unsafe, please click on the “Report Phishing”
> button on the top right of Outlook.
>
>
>
> I have been asked if there is a standard, or comments within s standard,
> that discusses giving a customer the password to allow them to reprogram
> the PLC when they remove a device and the light curtain that protected it.
>
>
>
> I believe, that other than it being a terrible idea, that it would
> probably invalidate any approvals the end product had.
>
>
>
> The customer is asking for a document that supports my opinion.
>
>
>
> I dud suggest that we send a service person to do the change, and not give
> up the pw.
>
>
>
> Thoughts?
>
>
>
>
>
>
>
> Sent from my T-Mobile 5G Device
>
>
>
> -
> 
>
> 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:
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> This message is from the IEEE Product 

Re: [PSES] PLC password

[Charlie Blackham]

Lauren

The Right to Repair legislation only covers certain consumer products as per 
Annex II and doesn't cover machinery such as this.

Best regards
Charlie

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

From: Lauren Crane <1afd08519f18-dmarc-requ...@listserv.ieee.org>
Sent: Friday, June 2, 2023 5:33 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] PLC password

Hi Steve,

My Friday 2c...

There is a trend of "right to repair" legislation that might contraindicate 
that position to some extent. See e.g.  
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023PC0155

It seems odd that the approval of a product would depend on the whether the end 
user can modify the product or not. There isn't a certified item I have that I 
can't modify in some dangerous way. There is an important difference between 
de-certification of a product unit because it has been modified vs. 
de-certification of a product line because it can be modified.

Best Regards,
-Lauren

From: sgbrody mailto:sgbr...@comcast.net>>
Sent: Thursday, June 1, 2023 5:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] PLC password



External Email: Do NOT reply, click on links, or open attachments unless you 
recognize the sender and know the content is safe. If you believe this email 
may be unsafe, please click on the "Report Phishing" button on the top right of 
Outlook.


I have been asked if there is a standard, or comments within s standard, that 
discusses giving a customer the password to allow them to reprogram the PLC 
when they remove a device and the light curtain that protected it.

I believe, that other than it being a terrible idea, that it would probably 
invalidate any approvals the end product had.

The customer is asking for a document that supports my opinion.

I dud suggest that we send a service person to do the change, and not give up 
the pw.

Thoughts?



Sent from my T-Mobile 5G Device

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

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List rules: http://www.ieee-pses.org/listrules.html

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Re: [PSES] PLC password

[Lauren Crane]

Hi Steve,

My Friday 2c...

There is a trend of "right to repair" legislation that might contraindicate 
that position to some extent. See e.g.  
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023PC0155

It seems odd that the approval of a product would depend on the whether the end 
user can modify the product or not. There isn't a certified item I have that I 
can't modify in some dangerous way. There is an important difference between 
de-certification of a product unit because it has been modified vs. 
de-certification of a product line because it can be modified.

Best Regards,
-Lauren

From: sgbrody 
Sent: Thursday, June 1, 2023 5:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] PLC password



External Email: Do NOT reply, click on links, or open attachments unless you 
recognize the sender and know the content is safe. If you believe this email 
may be unsafe, please click on the "Report Phishing" button on the top right of 
Outlook.


I have been asked if there is a standard, or comments within s standard, that 
discusses giving a customer the password to allow them to reprogram the PLC 
when they remove a device and the light curtain that protected it.

I believe, that other than it being a terrible idea, that it would probably 
invalidate any approvals the end product had.

The customer is asking for a document that supports my opinion.

I dud suggest that we send a service person to do the change, and not give up 
the pw.

Thoughts?



Sent from my T-Mobile 5G Device

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
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Re: [PSES] PLC password

[Douglas Nix]

Hi Steve,

ISO 12100 speaks to protecting various modes of operation with an authorization 
method like a password, key, or RFID fob.

When it comes to the kinds of modifications you are describing, my question 
would be “what goes in place of the removed device and safeguard?” You would 
need to look at the risk assessment to determine the impact, and since you 
mention a light curtain, that will also affect the functional safety aspects of 
the machine, including the safety-related programming.

All of this needs some careful consideration, IMO.

-- 
Doug Nix
d...@mac.com

"Sit, walk, or run, but don't wobble." -- Zen Proverb




> On Jun 1, 2023, at 18:51, sgbrody  wrote:
> 
> I have been asked if there is a standard, or comments within s standard, that 
> discusses giving a customer the password to allow them to reprogram the PLC 
> when they remove a device and the light curtain that protected it.
> 
> I believe, that other than it being a terrible idea, that it would probably 
> invalidate any approvals the end product had.
> 
> The customer is asking for a document that supports my opinion.
> 
> I dud suggest that we send a service person to do the change, and not give up 
> the pw.
> 
> Thoughts?
> 
> 
> 
> Sent from my T-Mobile 5G Device
> 
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc 
> discussion list. To post a message to the list, send your e-mail to 
> mailto:emc-p...@ieee.org>>
> 
> All emc-pstc postings are archived and searchable on the web at: 
> http://www.ieee-pses.org/emc-pstc.html
> 
> Website: http://www.ieee-pses.org/
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> unsubscribe) 
> List rules: http://www.ieee-pses.org/listrules.html
> 
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> 
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> 
> To unsubscribe from the EMC-PSTC list, click the following link: 
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> 


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