Hello All,

Well judging by the responses I worded my question poorly. I was trying to
avoid specifics because I felt the general case would be more of interest to
the group at large. So let me restate the problem. 


Generically

1. There is a EMC family product specification for a product published in
the OJ as a method of  showing compliance to the EMC directive.

2. There is a CENELEC document which is published as a EN which is not part
of any new approach directive. It contains (among a lot of other things) EMC
testing clauses.

3. CENELEC regulations require national standard organisations to implement
European standards

4.The EMC directive requires member countries to adopt standards published
in the OJ for that directive

5.Both CENELEC and the EMC directive require conflicting standards to be
withdrawn.

6.The EMC product family standard and the CENELEC standard have EMC tests
and test methods which are at odds with each other. They therefor are
conflicting standards.


In my case specifically,

1.The products are fire systems or components of fire systems

2. The EMC family product spec is EN50130-4

3. The CENELEC document is EN54 (In several parts) which is a performance
standard for Fire detection systems

So my question would be

 Is there an established procedure for making requests that these groups
harmonise and follow their own regulations? Does one complain to CENELEC,
the European Commission or both or someone else entirely?

Jon Curtis mentioned in his reply that he thought  "attempting to change the
way CENELEC does business is futile". but I think that still I must try for
several reasons. 
1. This double testing costs large companies like ourselves tens of
thousands of dollars in added testing cost per year for no particular good
reason.
2. When it gets down to it, CENELEC actually is responsible for the EMC
document EN 50130-4 as well as the fire standard EN54. If we accept that
groups within the same standards organisation can't harmonise where does
that leave us on global standardisation.


BTW For those who think I'm advocating less stringent tests or missing
certain tests that is not my intent. EN50130-4 call out a much more
comprehensive test suite than EN54 and it uses test methods that are newer
than EN54.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel   +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020 








-----Original Message-----
From: Grant, Tania (Tania) [mailto:tgr...@lucent.com]
Sent: Tuesday, November 09, 1999 9:42 PM
To: EMC-PSTC (E-mail); 'Kevin Harris'
Subject: RE: European Standards in conflict with the EMC directive



Kevin,

I cannot believe that we are all cowards here.   However, it may be that we
are unfamiliar with your subject matter.   I, for one, have never heard of
the EMC standard EN50130-4, don't know if it falls under the new approach
EMC Directive or not, and don't know what other EN standards it may be in
conflict with.   In other words, I cannot shed light on your subject.   I
would not be surprised if many have the same problem.   It might help if you
get a bit more specific here, such as, what are the conflicting EN
standards, and what are the specific conflicting clauses.  

Tania Grant,   tgr...@lucent.com <tgr...@lucent.com>  
Lucent Technologies, Communications Applications Group


----------
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Tuesday, November 09, 1999 3:01 PM
To:  EMC-PSTC (E-mail)
Subject:  RE: European Standards in conflict with the EMC directive


Hello Again Group,

Well the group's total silence on this point is indeed interesting. Does
nobody know how to proceed or is everyone just keeping their corporate heads
down :))))
Please reply offline if you feel uneasy answering this question in a public
forum.


Regards

Kevin Harris



-----Original Message-----
From: Kevin Harris [mailto:harr...@dscltd.com]
Sent: Monday, November 08, 1999 10:38 AM
To: EMC-PSTC (E-mail)
Subject: European Standards in conflict with the EMC directive



Greetings,

Is there an established procedure for demanding the withdrawal of EMC
clauses within standards who's primary purpose is industry regulation, not
EMC. In my company's industry there is an established product family
standard for EMC (EN50130-4) but the good people at CENELEC seem to be
ignoring the EMC directive, and have published within the last year or two,
EN standards which include EMC testing clauses, with methods that are at
odds with the EMC document EN50130-4 published in the OJ. Especially
troubling to me is the fact that all of the test organisations that test for
the industry regulation specification do not accept either third party or
self declarations that the product is EMC compliant. I do not wish to test
the same product more than once for a single market. What path do you
recommend I follow to demand the repeal of these clauses.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel   +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020 


-

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