Richard: Thanks for the info. I suspect you're right - we're seeing an
increased level of clarity on this point with more recent Directives.
You quote the R&TTE Directive below, and it is very clear that
publication in the OJ is required for presumption of conformity.
The 10 yr. old EMCD also seems fairly clear, providing a presumption of
conformity for equipment that meets "national standards transposing the
harmonized standards, the reference numbers of which have been published
in the Official Journal..."
The 26 yr. old LVD says the OJ is only used "for purposes of
information" and that "Standards shall be regarded as harmonized once
they are drawn up by common agreement between the bodies notified
by...and published under national procedures".
So in my mind, the problem now boils down to just the LVD, and the
question becomes:
Is publication in the OJ a mandatory pre-requisite of a standard
being considered Harmonized and therefore providing a presumption of
conformity with the LVD?
Hopefully the upcoming update to
http://www.newapproach.org/NewApproach/402.htm , will clarify the
situation, although I wonder if a web site can over-rule a Directive
(even in the guise of "clarification").
Regards,
Jim Eichner
Statpower Technologies Corporation
jeich...@statpower.com
http://www.statpower.com
Any opinions expressed are those of my invisible friend, who really
exists. Honest.
> -----Original Message-----
> From: WOODS, RICHARD [SMTP:wo...@sensormatic.com]
> Sent: Monday, March 22, 1999 5:33 AM
> To: 'emc-pstc'
> Subject: RE: Harmonized Standards
>
> I believe the conflict arises because the Commission has moved from
> the old
> approach to the new approach and they have also been revising their
> own
> point of view on standards. Here is the latest from the R&TTE
> Directive.
>
> Article 2(h): "'Harmonized standard' means a technical specification
> adopted
> by a recognized standards body under a mandate from the Commission in
> conformity with the procedures laid down in Directive 98/34/EC for the
> purpose of establishing a European requirement, compliance with which
> is not
> compulsory."
>
> Article 5.1: "Where apparatus meets the relevant harmonized standards
> or
> parts thereof whose reference numbers have been published in the
> Official
> Journal of the European Communities, Member States shall presume
> compliance
> with those of the essential requirements referred to in Article 3 as
> are
> covered by the said harmonized standards or parts thereof."
>
> ----------
> From: Jim Eichner [SMTP:jeich...@statpower.com]
> Sent: Friday, March 19, 1999 5:36 PM
> To: 'emc-pstc'
> Subject: RE: Harmonized Standards
>
> Greetings all:
>
> I eagerly visited this site, particularly the page dealing with
> Harmonized Standards at
> http://www.newapproach.org/NewApproach/402.htm
> but was a bit disappointed. The description is thorough and
> filled
> with
> new ways of using words that I used to think I knew the meaning
> of,
> but
> it doesn't answer the fundamental question that was the focus of
> the
> forum discussion a while back:
>
> Is publication in the OJ a mandatory pre-requisite of a standard
> being
> considered Harmonized (and therefore providing a presumption of
> conformity)?
>
> I will eagerly await the update a couple of weeks from now, and
> any
> new
> input on this question!
>
> Regards,
>
> Jim Eichner
> Statpower Technologies Corporation
> jeich...@statpower.com
> http://www.statpower.com
> Any opinions expressed are those of my invisible friend, who
> really
> exists. Honest.
>
>
>
> > -----Original Message-----
> > From: WOODS, RICHARD [SMTP:wo...@sensormatic.com]
> > Sent: Friday, March 19, 1999 6:27 AM
> > To: 'emc-pstc'
> > Subject: Harmonized Standards
> >
> > The Commissions official viewpoint on the rules for the use of
> > harmonized
> > standards can be found at www.newapproach.org
> > <http://www.newapproach.org> .
> > Click on "Concepts." According to the webmaster, "The concepts
> text
> > originates from the Commission, however I understand it is
> currently
> > under
> > revision and it is on the agenda for a meeting to be held next
> week. I
> > expect the final "official" text to be on the site in the
> following
> > week.
> >
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