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
