Hi John, Richard and group, I agree with your opinions for most of it but want to add this to it:
The application of the GPSD is meant exactly the way we handle the generic EMC standards: as a backup to products not covered by any other more dedicated (ce) directive. Of course for a directive to be more specific, it needs a scope, having loop holes and omissions. This does not mean that your life as a manufacturer has become much more difficult, now selecting a directive for products with "multifunction" properties may seem to lead to contradictories. The EC target meant by using ce marking and the GPSD (which is not ce-mark related - I believe) is to create a situation in which safe products are created. Any safety problem with any product will ultimately be judged by the question: "did the manufacturer show due diligence in creating a safe product", and not by "did he select the right directive" . Directives and standards and essential requirements are a way to handle this for mature manufacturers. As manufs are familiar with their product best of all, they can (need to) be trusted to categorize their product best. Due diligence is part of this idea. The EC system is not meant to create some framework where every product is covered by exactly the right directive and standard, and where a smart manufacturer can escape testing by using aloop hole in a directive or standards scope. A manufacturer is not lead by hand, but need to motivate his choices, and need to make a choice. In any of the cases below, your reasoning should be: Is my product safe for all these environments, and yes if this means that it should be covered by multiple directives at the same time, then it should be like that. But then, select one , the one that fits best to the original description of the product or covers the most relevant risks and create your files accordingly, Fill up the safety loop holes leftover voluntarily. As far as Richard's remarks concern: Professional products need to be safe too, if no other directive fits the product, how to show due diligence ? Regards, Gert Gremmen, (Ing) ce-test, qualified testing =============================================== Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ =============================================== >>-----Original Message----- >>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf >>Of John Allen >>Sent: Tuesday, March 28, 2000 4:54 PM >>To: emc-p...@majordomo.ieee.org >>Subject: RE: General Product Safety Directive >> >> >> >>Hi folks >> >>Very interesting and I am glad that Richard has spotted this as I >>was under >>the same impression (as, I think, were/are many other people). >> >>However, I personally doubt it makes much difference to the TECHNICAL >>safety requirements that should be applied to any specific product. These >>mainly come from standards which are often sector independent. >> >>Also, it should be noted that the discussion paper also says (in the >>middle) that when "professional" products migrate to the consumer market >>then the GPSD DOES now apply - so it might be difficult to >>identify exactly >>when that occurs. >> >>Personal computers are probably both a good and a bad example: >> >>a) A 230V desktop unit is definitely subject to the LVD and not the GPSD. >> >>b) A notebook PC with an external AC/DC PSU is not subject to the >>LVD, and >>thus the GPSD probably applies (but see c) below!) - EXCEPT if it >>is a very >>high-spec high-end unit for "professional use" when the GPSD would not >>appear to apply but it is then covered (according to the discussion >>document) by work-place legislation. >> >>c) A telecomms connectable notebook unit is subject to the R&TTE >>Directive, >>not the LVD and that makes no supply-voltage rating distinction, nor any >>distinction between consumer and non-consumer products - (and the >>high-end >>unit will almost certainly have telecomms connectability!). >> >>d) High-spec units of this type often "slide down the market" to become >>consumer products so the GPSD now applies to even the high-spec unit! >> >>e) In all cases EN60950 is the applicable safety standard - so there's no >>difference to the technical requirements! >> >>f) Finally, I have seen many definitions of "consumer" that are not >>explicit enough to exclude personnel in their working environment. >> >>However, I can certainly see that where the product has no "consumer" >>applications then the GPSD will not apply - but, again, will the actual >>effects on the way we (as equipment suppliers) actually design, >>manufacture >>and supply products be much different? I rather doubt it. >> >>I think the major effects of the GPSD are related to the needs to inform >>various government bodies if you have been a bad boy - or you know of >>someone who has - and the on-going implications thereof. >> >>What do others make of this? >> >>John Allen >>Racal Defence Electronics Ltd >>UK >> >>---------- >>From: wo...@sensormatic.com[SMTP:wo...@sensormatic.com] >>Sent: 28 March 2000 13:40 >>To: emc-p...@majordomo.ieee.org >>Subject: General Product Safety Directive >> >> >>You may find this link concerning the potential revision of the GPSD to be >>of interest: >>http://europa.eu.int/comm/dg24/policy/developments/prod_safe/ps04_en.html >><http://europa.eu.int/comm/dg24/policy/developments/prod_safe/ps04 _en.html> . I learn something every day. I always thought the GPSD applied to all products unless another safety directive existed, such as the LVD. Wrong! The GPSD only applies to consumer products. Professional products are not covered. That is made clear in the linked document. I wonder what else I have misunderstood all these years. Richard Woods ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
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