Brian,

I agree with Richard. However, I would like to add one thing.
In ensuring continued compliance on your products, I would assume (only
because this is what I do) that you at least verified (on a similar in-house
sample of the product) that the upgrades did not detrimentily affect the
product's original compliance. This should be well documented and placed in
your product's compliance folder.

John A. Juhasz
Product Qualification &
Compliance Engr.

Fiber Options, Inc.
80 Orville Dr. Suite 102
Bohemia, NY 11716 USA

Tel: 516-567-8320 ext. 324
Fax: 516-567-8322 



-----Original Message-----
From: WOODS, RICHARD [mailto:wo...@sensormatic.com]
Sent: Monday, August 02, 1999 12:26 PM
To: emc-p...@ieee.org
Subject: RE: Upgrades



Brian, I have to assume that as the manufacturer, your company has taken on
the responsibility of ensuring compliance with the directives, applied the
CE mark and issued the Declaration. Now you want to sell an upgrade to the
equipment. Nothing has changed. You the manufacture are still responsible
for ensuring compliance of the upgraded equipment.  If the original
Declaration did not cover these options, then a new Declaration will be
required for the upgraded equipment.

Since the upgrades are expressly intended for use with your equipment and
not sold on the open market, I don't believe that they need to be CE marked.
        ----------
        From:  Brian Harlowe [SMTP:bharl...@vgscientific.com]
        Sent:  Monday, August 02, 1999 11:57 AM
        To:  emc-p...@ieee.org
        Subject:  Upgrades


        Please can you give me some opinions on the following.

        I have a customer who has one of our Scientific instruments that he 
        wishes to upgrade.

        If I supply him with CE marked everything to allow him to carry out 
        this up grade and I also provide him with a detailed manual on how
to 
        install and connect up these items to be emc compatible.

        Do my responsibilities end there and does the customer have to get 
        the instrument re tested and CE mark it?

        Regards

        Brian Harlowe
        * opinions expressed here are personal and in no way reflect the
position of VG Scientific

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