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] <mailto:[email protected]> http://www.motorola.com/globalcompliance/ <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] <mailto:[email protected]> http://www.motorola.com/globalcompliance/ <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] <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] <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. 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