Guys,
     
     It is true that compliance with applicable directives is 
     required. However for Telecom Terminal Equipment, is there some 
     demarcation of the CO and behind which Telecom Approval is not 
     required as per US Federal Regulations, CFR 47 parts 68.2 and 
     68.3?
     
     This demarcation exists because, these regulations are in place 
     to protect the network. The providers can attach what they like 
     to their own network within their own CO, it is expected that 
     they know what they are doing with this equipment and will take 
     the necessary precautions. They don't expect the same of You or 
     I.
     
     Cheers,
     
     Colin. 


______________________________ Reply Separator _________________________________
Subject: Re: CO placed reqs.
Author:  Non-HP-RCTOWNER ([email protected]) at HP-UnitedKingdom,mimegw6
List-Post: [email protected]
Date:    11/3/98 5:30 PM


Vic,
Would you please clarify your point in paragraph #4 below, wherein you 
state, "In Europe, as in North America, Telephone Operating companies have 
their
own specifications for Central Office equipment.  Such equipment is not 
subject to regulation in either Europe or North America and need not be 
marked."
My understanding from reading the Directives (EMC and Low Voltage are 
particular to this discourse, I think) is that they apply to ALL equipment 
being placed on the market or into service within the confines of the EU.
 My interpretation on this matter would then be products placed into service
in CO's in Europe must meet, as a minimum, the essential requirements -- 
standards be damned, of course -- of the EMC Directive and LVD.  Additional 
requirements for meeting standards may be placed on the equipment by local 
authorities under the aegis of "Telecommunications Equipment Specific 
Requirements" on the lack of a cohesive Telecom Directive.
In particular I'm thinking about this from an enforcement authorities 
perspective.  Minimal Telco expertise and miminal investigative resources 
force them -- regardless of circumstances -- to evaluations of compliance 
with the lowest common denominator:  CE Marking.
     
Your thoughts?
     
Rick Towner
     
     
 ----------
From: Victor L. Boersma
To: INTERNET:[email protected]
Subject: Re: CO placed reqs.
List-Post: [email protected]
Date: Monday, November 02, 1998 7:56PM
     
> > I was wondering if there were equivalent requirements in Europe to 
> > Bellcores req. for CO placed equipment?
> > Also, are they harmonized (such as CE mark)?
     
Standards 101
     
The CE marking is affixed to equipment that meets the essential 
requirements of applicable Directives.
     
There are no Directives for Central Office equipment.
     
In Europe, there is a determined effort to "harmonize" standards amongst 
the member states.  If equipment meets the requirements of harmonized 
standards that are published in the Official Journal, such equipment is 
"deemed" to meet the essential requirements of the applicable Directives.
     
In Europe, as in North America, Telephone Operating companies have their 
own specifications for Central Office equipment.  Such equipment is not 
subject to regulation in either Europe or North America and need not be 
marked.
If the customer wants marking, that is fine, it is a customer requirement, 
not a legal requirement.
     
The Bellcore NEBBS are purchasing requirements written by Bellcore for 
clients who want to use them.  There is no requirement that the Bellcore 
clients buy to those specs, if they don't want to or don't need to.
     
France Telecom and others have their internal specs for CO equipment.  The 
requirements in those specs are negotiable (even if they won't tell you 
that the first day).  Ofcourse, if you can meet them and don't have to 
negotiate, youcan get a better price.
     
While certain aspects of the Central Office equipment from different 
vendors are harmonzed in North America, the requirements certainly are not 
and the equipment used is built deliberatedly so that the customer has a 
choice between the equipment of one vendor over that of another.
     
Ciao,
     
     
Vic

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