<200102261711.jaa27...@epgc196.sdd.hp.com>, Rich Nute <ri...@sdd.hp.com> wrote: > > > > >With thanks to Ed Jones... > >On Thusday, February 22, The Wall Street Journal Europe >published an interesting opinion on the harmonic current >emissions standard. > >The opinion is by Rob Hunter, a lawyer and Chairman of >the Centre for the New Europe, a Brussels-based think >tank.
I think I may know a bit about the harmonics emission standard, since I helped to write the latest big amendment, after ten years of agitating for the need for amendment, and I am helping to write the next complete revision. This amendment was developed *internationally*, with a US expert from the computer and measuring instrument manufacturing sector leading the work. For purely procedural reasons, it has been published in CENELEC before being published by the IEC. For the avoidance of doubt, I am sponsored for this work by a trade association of manufacturers of professional audio and lighting equipment. > >Mr. Hunter is quite critical of the EU "New Approach" >process. He says: > > "In this procedure, the EU sets vague safety and > technical rules for everything from toys to super- > computers -- for example, toys shall be 'safe.' The > EU then delegates to private standardization bodies CEN and CENELEC are NOT 'private bodies'. ETSI is a private body. CEN and CENELEC adopt ISO and IEC International Standards unless special circumstances in Europe prevent that. If that is so, regional amendments, applying in all participating countries, are introduced. > the drafting of detailed requirements explaining > what the delphic rules mean." They NEED to be 'vague' (I prefer 'generic') so that the detailed technical requirements can be developed by people who understand the technical issues without unreasonable legal constraints. > > "The supposed advantage of this New Approach is > twofold. For industry, it gets to write the detailed > rules applying to it. For the Commission, the New > Approach frees it from a burdenom task; it also > allows the Commission to claim that it has nothing to > do with writing the standards, and hence cannot be > held responsible." That is false. DGIII of the Commission decides which standards it will accept as providing prima facie evidence of conformity with Directives. It does NOT accept all the standards it's offered. The Commission DEMANDS responsibility for determining which standards are 'notified' in the OJEC as acceptable. > > "All this sounds quite above-board. It isn't." > > "For one thing, the standards are not merelay a means > of proving compliance with the underlying legislation. > They actually determine the meaning of the law itself." That is essentially true. The alternative is to include all the technical requirements in the Directives themselves. That was tried and proved impracticable. Any improvement or revision of the technical requirements, to relax unnecessary restraints or to allow for new technology, requires the LAW to be changed in 18 countries, which takes YEARS. > >Mr. Hunter discusses "...the way these standard-setting >bodies can be gamed by industry insiders for advantage." This has happened, but it has been ALLOWED to happen through apathy by industry sectors that SHOULD have participated in the standards-making process. It can't happen if committees are properly representative. > >Mr. Hunter goes on to show how the New Approach process >allows the Commission to sidestep "...WTO laws prohibiting >'mandatory' product measures that create 'unnecessary >obstacles' to international trade." They may be 'unnecessary' in his opinion: the reality may be different. I don't think he is technically qualified to determine necessity. > >Mr. Hunter's opinion goes on to show that the only ones >who benefit from the harmonic current emission standard >are the European electricity distributors. They "avoid >investments in bolstering their networks against the >theoretical harmonics risk" at the cost of manufacturers >and consumers. > The risk is certainly NOT just theoretical. The failure mechanisms due to harmonic currents are very well-understood, and are quite easy to understand in most cases. Analysis of the economic issues, **internationally**, with full participation by American interests, indicates that the lowest-cost solution to the problems created by harmonic currents almost certainly comprises equipment-level mitigation (as required by the EMC Directive), site-level mitigation (as indicated in IEEE 519) and system-level mitigation (as practised by the supply industry for around 50 years). After several years of unproductive and very costly contention, the international work on this subject is now becoming consensual. It is very undesirable for old contentions to be dragged up by people who are apparently authoritative but are woefully ill-informed. We now KNOW why the major problem with harmonic currents in the Americas is 'hot neutrals', whereas in Europe there are several other problems as well. -- Regards, John Woodgate, OOO - Own Opinions Only. Phone +44 (0)1268 747839 Fax +44 (0)1268 777124. http://www.jmwa.demon.co.uk Foxhunters suffer from tallyhosis. PLEASE do not mail copies of newsgroup posts to me. ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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