PSNet
This ongoing discussion of self certification brings to the surface
several issues...
In applying the CE marking to equipment, the manufacturer must sign
the Manufacturer's Declaration of Conformity. In doing so, it must include
a list of the Directives and Standards that the manufacturer claims to
meet.
The manufacturer is allowed to do all the work to ascertain
compliance without the use of any outside help. In fact, that is commonly
encouraged by the EU.
In looking at the practicallity of this, hardly any small companies
have the resources of an in-house, full EMC lab to determine the
acceptability of their product to meet these requirements. So, this is
often hired out.
On the mechanical and electrical safety side, most engineering
departments feel that they can properly assess their equipement against the
requirements. This is usually the point of discussion of
self-certification.
Just one reminder, however, that the person who signs the MDoC for
the company bears personal criminal liability in EU law if they sign
falsely. So, the signer should ask carefully if the evaluators of the
equipment not only understood the technical requirements, but do they
understand the usual European interpretation of these requirements.
If there is any doubt in having this Euro understanding, the use of
a Notified Body on the first few projects will go a long way in assuring
that the Euro interpretation is understood and used in the product
evaluation.
So it costs a lot of money, you say... What's it worth to insure
that you don't get harassed about your meeting the requiements by some NCB
who is following up on a complaint... or worse, find yourself not being
able to defend compliance to the requirments because you didn't understand
the usual Euro interpretation of the requirements...
This little homily can, again, be classified as a word to the wise
or deficient... pick your poison...
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Peter E Perkins
Principal Product Safety Consultant
Tigard, ORe 97281-3427
+1/503/452-1201 phone/fax
p.perk...@ieee.org email
visit our website:
http://ourworld.compuserve.com/homepages/peperkins
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