Dear Colin,
TTE to be approved are, according to the wording used in the Korean ministry
decree:
1- Equipment which can be connected directly to a demarcation point of backbone
communication network.
2- Equipment not directly connected to a demarcation point of backbone
communication network, and which can cause harm to the backbone communication
network:
2.1) TTE which can be used separately without the system. (if the TTE has to be
bundle to the system, then has to be approved as part as the system's type
approval)
2.2) TTE for Integrated Service Digital Network (ISDN)
2.3) Digital communications devices directly connected to Channel Service Units
("CSU")
3- TTE directly connected to the demarcation point of a transmission network
All these 3 points are explained at the RRL website:
http://approval.rrl.go.kr/eng/sec01_02_1.html
The text of the decrees are at: http://approval.rrl.go.kr/eng/erow1.html
So I believe the point of the dicussion is to precise at which point(s) only
can your equipement be used (intentionally or unintentionally).
Hope this helps
Alain Sam-Lai
Gigabyte Technolgy
mailto:[email protected]
-----Original Message-----
From: [email protected] [mailto:[email protected]]
Sent: Thursday, October 03, 2002 6:32 PM
To: [email protected]; [email protected]; [email protected]
Cc: [email protected]
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Hi All,
I have some Network Equipment with DS1 and E1/T1 interfaces, it is for use
within the Telco Central Office and while I believe it to be outwith the scope
of the R&TTE I find that in Korea this type of interface requires a Telecom
type approval (according to the Korean Test Lab - Estech Co,Ltd).
I am trying to argue the point, but have not read the regulations (I'm trying
to get a translation) and therefore can't put this into context. Has anyone
else experienced similar requirements for Korea?
Thanks and regards.
Colin McGeechan
Product Regulations Specialist
Telecomms Networks Test Division
Agilent Technologies UK Limited
West Lothian
Scotland EH30 9TG
+44 (0)131 331 7196 Tel
3132196 TN
+44 (0)131 331 6075 Fax
www.agilent.com
Registered Office: Eskdale Road, Winnersh Triangle, Wokingham, Berkshire, RG41
5DZ. Registered Number: 03809903 England
-----Original Message-----
From: Joe Finlayson [mailto:[email protected]]
Sent: 02 October 2002 19:56
To: TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Roger,
Thanks for the contact. I will do just that and post the response
from Mr. Bogers. Anyone want to bet a beer on this one?? ;-)
Thx,
Joe
-----Original Message-----
From: Roger Magnuson [mailto:[email protected]]
Sent: Wednesday, October 02, 2002 2:07 PM
To: Joe Finlayson; 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS
Newsgroup'
Cc: Roger Magnuson
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Joe et al,
It seems a little overambitious to declare it under R&TTE as Network Equipment
did not even require type approval under the old TTE Directive. If you need a
comment right from the source I suggest you contact Mark Bogers
([email protected]), he is the contact point for R&TTE issues.
Roger Magnuson
TGC Communication AB
-----Original Message-----
From: [email protected] [mailto:[email protected]]On
Behalf Of Joe Finlayson
Sent: den 2 oktober 2002 19:09
To: 'Clement Dave-LDC009'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Dave,
My position was based on my particular interface (in this case also E1)
and, based on my interpretation, concluded that it does not fall under the
scope of the R&TTE Directive. Based on your examples below, I can see that
apparently there are PSTN interfaces that can be classified as SELV. We
definitely seem to have a divided field here. I've seen posts stating
"Absolutely R&TTE" as well as "Absolutely not R&TTE".
Is there anyone out there who was involved in the draft of the R&TTE that
can comment on the intent?
Thx,
Joe
-----Original Message-----
From: Clement Dave-LDC009 [mailto:[email protected]]
Sent: Wednesday, October 02, 2002 11:47 AM
To: 'Joe Finlayson'; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Joe,
Maybe I have missed something here but how does the TNV-X vs SELV from a safety
perspective define if the product falls under the R&TTE Directive?
Many telcom interfaces are SELV from a safety perspective and clearly fall
under the R&TTE Directive. For example; V.11/V.24/V.35/X.21 when connected to
WAN services via a CSU/DSU and ISDN Basic Rate S/T.
Also, I believe Peter's original post stated intrabuilding and did not state it
was CO equipment. In any case there are expectations and I believe you are
going to spend more time trying to justify why you did not declare to the R&TTE
than if you just do it. Again because of expectations I would have a TBR12/13
test report to back up the declaration even if it's no longer mandatory. NOTE:
meeting the over voltage requirements of these standards has nothing to do with
the classification of the port from a safety standpoint since the surges are
applied to the AC mains (not even applicable ifDC powered)
Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:[email protected] http://www.motorola.com/globalcompliance/
-----Original Message-----
From: Joe Finlayson [mailto:[email protected]]
Sent: Wednesday, October 02, 2002 9:29 AM
To: Clement Dave-LDC009; TREG Newsgroup; 'EMC PSTC'; 'NEBS Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Dave,
Please reference the subject title of this thread. My position is that by
declaring compliance to the R&TTE Directive, we would then be stating that we
have designed to and/or are capable of connecting to the PSTN. This would
contradict our IEC 60950 SELV classification and would then change our
classification to TNV-X (depending on the interface). That would open up a
whole new can of worms and is a good example of how declaring blindly could
leave you in an undesirable situation.
Thx,
Joe
-----Original Message-----
From: Clement Dave-LDC009 [mailto:[email protected]]
Sent: Wednesday, October 02, 2002 9:05 AM
To: 'Joe Finlayson'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
This whole discussion is some what of a moot point. Under the R&TTE directive
there are no mandatory telecom standards anyway.
Dave Clement
Motorola Inc.
Test Lab Services
Homologation Engineering
20 Cabot Blvd.
Mansfield, MA 02048
P:508-851-8259
F:508-851-8512
C:508-725-9689
mailto:[email protected] http://www.motorola.com/globalcompliance/
-----Original Message-----
From: Joe Finlayson [mailto:[email protected]]
Sent: Wednesday, October 02, 2002 8:53 AM
To: 'Pausch, Robert'; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Hi Robert,
I'm glad to see you're still in the game. I think the issue here is that
"terminal equipment" is that which connects directly or indirectly to the PSTN.
This type of product does neither as it installed in the Central Office and is
NOT in free circulation on the market in the EU (only available to Network
Operators).
Thx,
Joe
-----Original Message-----
From: Pausch, Robert [mailto:[email protected]]
Sent: Wednesday, October 02, 2002 4:05 AM
To: Joe Finlayson; TREG Newsgroup
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Joe,
my position is that the RTTE directive does apply for all types of radio or
terminal equipment unless it has been excluded by article 1(2) or annex I and
is in free circulation on the market in the EU. However, the RTTE does only
specify the essential requirements in article 3 which equipment has to comply
with. It does not regard any specific standard like E1.
Peter,
I think You must declare conformity to the RTT directive. What is the point not
to do it?
Regards
Robert
Robert Pausch, Regulatory Compliance Engineer
and Compliance Project Manager
Hewlett-Packard EMEA, Einsteinring 30, 85609 Dornach, Germany
Tel: +49 (89) 9392 2352, FAX: +49 (89) 9392 2336
Mailto: [email protected]
-----Original Message-----
From: Joe Finlayson [mailto:[email protected]]
Sent: Wednesday, October 02, 2002 12:15 AM
To: 'Richard Hughes'; 'EMC PSTC'; 'NEBS Newsgroup'; 'TREG Newsgroup'
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Richard,
Good point - the "directly or indirectly" part grabbed my attention but
that seems too broad a description which could encompass quite a wide range of
equipment. However, the point of discussion here is whether a product
classified as SELV by IEC 60950, Type 2 by GR-1089, etc. and does not connect
(interface) to the "Public" telecommunications network is included in the scope
of the R&TTE Directive. This type of product resides in the network and does
not connect to outside plant conductors - terminates to another piece of
equipment with the proper isolation to outside plant conductors. My
interpretation is that if there is no provision for physical connection to the
PSTN, the R&TTE does not apply.
Any takers??? I'll copy the TREG and NEBS gurus on this one as well.
Thx,
Joe
-----Original Message-----
From: Richard Hughes [mailto:[email protected]]
Sent: Tuesday, October 01, 2002 5:57 PM
To: 'Joe Finlayson'; "EMC-PSTC (E-mail)" <
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Joe,
The R&TTED applies to the following types of equipment:
1) Radio equipment
2) Terminal equipment.
The Directive also contains the following definitions:
'telecommunications terminal equipment' means a product enabling communication
or a relevant component thereof which is intended to be connected directly or
indirectly by any means whatsoever to interfaces of public telecommunications
networks (that is to say, telecommunications networks used wholly or partly for
the provision of publicly available telecommunications services). 'interface'
means
(i) a network termination point, which is a physical connection point at
which a user is provided with access to public telecommunications network,
and/or
(ii) an air interface specifying the radio path between radio equipment
and their technical specifications
It will be seen from the above that the R&TTED is not limited to PSTN since it
is quite possible that a network operator could provide a business with an E1
interface, for instance.
Peter,
It is for the manufacturer to decide to which market, e.g. terminal equipment
or central office equipment only, they whish to sell their product into. EN
60950 has nothing to do with it since this standard can be used to evaluate
either type of product - and other non-telecom ICT products as well of course.
Simplistically, if the product does not have an input or output voltage in the
range 50-1000Vac, 75-1500Vdc then the LVD does not apply {ref. Article 1 of
LVD}. Clearly, if the LVD does apply then certain editions of EN 60950 do
provide a presumption of conformity with the safety objectives of the LVD. If
the LVD does not apply then that should not be taken as an excuse to not comply
with EN 60950, but that's another debate entirely. If the R&TTED applies then
the EMC is not applied as such, because the EMC requirements are then covered
by the R&TTED. However, this is largely an administrative technicality because
Article 3(1)(b) points to the EMC Directive for its essential requirements,
just as Article 3(1)(a) points to the LVD for safety (minus any upper or lower
voltage limit).
Well, that's enough personal opinions expressed on this matter for me...
Richard Hughes
-----Original Message-----
From: Joe Finlayson [mailto:[email protected]]
Sent: 01 October 2002 17:52
To: "EMC-PSTC (E-mail)" <
Subject: RE: RTTE or LVD for Equipment with E1 SELV interface
Peter,
As this product does not connect to the PSTN and is destined for the
Central Office only, I would say the R&TTE Directive does not apply as the
scope does not include Network Equipment. Thx,
Joe
-----Original Message-----
From: Peter Merguerian [mailto:[email protected]]
Sent: Tuesday, October 01, 2002 9:33 AM
To: "EMC-PSTC (E-mail)" <
Subject: RTTE or LVD for Equipment with E1 SELV interface
Dear All,
For an equipment where the E1 has been assessed for SELV under EN 60
950 (ie for intrabuilding use and not subject to overvoltages), does the
equipment fall under the RTTE Directive or can the manufacturer declare
compliance to the LVD and EMC Directives.
If under the RTTE Directive, what telecom standard applies to the E1
intrabuilding interface? This e-mail message may contain privileged or
confidential information. If you are not the intended recipient, you may not
disclose, use, disseminate, distribute, copy or rely upon this message or
attachment in any way. If you received this e-mail message in error, please
return by forwarding the message and its attachments to the sender.
PETER S. MERGUERIAN
Technical Director
I.T.L. (Product Testing) Ltd.
26 Hacharoshet St., POB 211
Or Yehuda 60251, Israel
Tel: + 972-(0)3-5339022 Fax: + 972-(0)3-5339019
Mobile: + 972-(0)54-838175
http://www.itl.co.il
http://www.i-spec.com
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