Mike Sherman asked for opinions (supported by documents or simply gut feel) to his problem, so here is my intuitive response.
I think that in all three cases the existing equipment does not have to be brought into compliance, but that the add on equipment does. My reasoning is that since the existing equipment did in fact comply with the regulations which were in force at the time of installation, that equipment is compliant equipment to today's rules (even though it would not comply with the emission limits of the standard). Add on equipment must also comply with today's rules, meaning that the add on must be shown to comply with the limits of the standard. How to demonstrate compliance with a performance standard will require some ingenuity, since the add on becomes part of the existing equipment, but probably not impossible. I think that the rules allow for the use of simulation boxes located some distance away from the EUT (so that the simulation device does not contribute to the test results), so that it might be possible to demonstrate that the add on stuff complies by itself. How to make the add on stuff pass is the challenge, but that might be an easier answer than making the complete box pass. For instance, if the add on stuff is enclosed in its own emissions resistance enclosure (does not have to be metal, could be conductive cardboard like that Schlagel stuff that can be formed), it might work. Or maybe the answer is to design the add on to be externally mounted. It will be interesting to hear how others solve this problem, in any event, good luck. Gabriel Roy Hughes Network Systems The above opinions, as alway Mr. Phelps, are my own and will self destruct in 15 seconds. ----------------------------------------------- snip ----------------------------------------- Here's a real and present puzzler for us. We are a maker of large industrial equipment. We have a number of existing units in the field in Europe. They were shipped before January 1996, and do not conform to the EMC requirements. Customers now wish to order various options and upgrades to the units. We are trying to determine in which cases we can simply ship and install the option/upgrade and remain in legal compliance, and in which cases we must also remove and replace the electronic controls and bring the ENTIRE machine into compliance with the EMC directive. Here are some sample cases: 1) ADD AN OPTION WHICH ALLOWS MACHINE TO PERFORM FUNCTION IT COULDN'T PREVIOUSLY DO. The option requires that additional control circuitry be added to the electronics control cabinet. 2) ADD AN OPTION THAT DUPLICATES AN EXISTING FUNCTION; e.g. allowing the machine to process 4 raw materials rather than 3, or deliver to 4 outlets rather than 3. The option requires adding a few electrical devices to the machine, but wires into existing control circuits. 3) ADD AN ADJACENT MACHINE THAT WORKS IN TANDEM WITH THIS MACHINE AND COMMUNICATES WITH IT; e.g. a robotic feeder to eliminate manual loading of the machine. The new, adjacent machine fully complies with all CE directives. QUESTION: For each case above, do we have to bring the entire old machine into compliance with the EMC directive when we add the option? Why? I think the answers, repectively, are Yes, No and No, but I cant tell you why, and therefore am uncomfortable with the possible legal liability of being wrong. Any help, opinions, reasoning from you folks would be greatly appreciated! Mike Sherman FSI International m_sher...@delphi.com (612) 361-8140 phone (612) 448-2825 fax
