My understanding is the manufacturer must consider all reasonable uses and misuses of the product and then take the appropriate actions to ensure the safe use of the product. Warnings may form part of that action and may include a list of intended uses and warnings against other uses. However, warnings cannot replace sound engineering practice. I can sell a CCTV camera intended for QA surveillance on a factory floor and use the standard immunity levels; but if I also sell the camera in the local DIY store, then I am obviously foreseeing other uses and warnings not to use the camera in the home would be useless. Reason has to prevail.
Richard Woods Sensormatic Electronics Tyco International -----Original Message----- From: Enci [mailto:e...@cinepower.com] Sent: Thursday, January 03, 2002 11:20 AM To: emc-p...@majordomo.ieee.org Subject: RE: EMC-related safety issues I understand in this particular case the RF camera may have been marketed for baby surveillance. The majority of camera systems, wired and wireless, that I have seen are not marketed in this manner. Most are advertised as security/surveillance cameras. Are you implying that all manufacturers of these camera systems must consider the possible use of the products for the protection of persons? What if the manufacturer clearly states in the user instructions that the product is not suitable for the protection of persons? I have always understood that a manufacturer can meet obligations by addressing intended use only. For example if I was to manufacture a kettle, I would state for boiling water only in the relevant documentation. Some of the recent messages in this thread would seem to imply that I would have to consider the possible use of the kettle being used to boil something other than water, gasoline for example. Am I then liable from the damages resulting from the possible ignition of the volatile fumes from some undefined energy source, i.e. lack of emc immunity? Enci At 08:26 03/01/02 -0500, Richard Woods wrote: > Ken, let me address the specific case you mentioned - the RF camera >used for baby surveillance. In that particular application, surveillance >for the protection of persons, more severe immunity requirements apply. >Those requirements are either specified in EN 50130-4 or the particular >ETSI product EMC standard. A manucturer should understand that the product >may be used for protection of persons and apply the appropriate immunity >requirements. Failure to do so, could create a liability issue. Richard Woods >Sensormatic Electronics >Tyco International -----Original Message----- >From: Ken Javor [mailto:ken.ja...@emccompliance.com] >Sent: Wednesday, January 02, 2002 2:22 PM >To: cherryclo...@aol.com; emc-p...@majordomo.ieee.org >Subject: Re: EMC-related safety issues > > To say that Industry standards don't go far enough, that it is >the responsibility of the Producer to be able to determine all possible >environments and failure modes that might ever occur is placing an >impossible burden and any rationale entity, upon reading this document >will immediately cease production of anything that could conceivably >ever malfunction in anyway whatsoever. > > But this safety guide says yes, and places the manufacturer at risk. > >---------- >From: cherryclo...@aol.com >To: emc-p...@majordomo.ieee.org >Subject: Re: EMC-related safety issues >Date: Wed, Jan 2, 2002, 9:49 AM > > > >>Once again, John, you seem to be trying to give a negative >>impression about the IEE's guide on EMC and Functional Safety (which >>you now admit you haven't read) instead of simply saying what it is >>that you think is wrong with it. >> >>Of course I am passionate about the IEE guide - my colleagues and I >>spent a long time working on it! >> >>When I discovered you were criticising it to the emc-pstc of course >>I had to respond - but I was not (and am not) trying to defend the >>guide, merely trying to find out just exactly what it is that you (and >>your silent 'equally senior experts') don't like about it so I can >>get it improved. >> >>I am sorry if my wordy emails give the wrong impression - the simple >>fact is that I always write too much (as any editor who has had an >>article from me will confirm!). >> >>Once again I ask you - and everyone else in the entire EMC or Safety >>community world-wide - to read the IEE's guide and let me have >>constructive comments about how to improve it. >> >>You can easily download it for free from >>www.iee.org.uk/Policy/Areas/Electro (- you only need to download the >>'core' document for this exercise and can leave the nine 'industry >>annexes' for later criticism). >> >>I'll make it easy for anyone to comment even if they haven't read >>the Core of the IEE's guide.... >>...the guide is based on the following engineering approach, >>explicitly stated at the start of its Section 4 and duplicated below. >> >>***** >>To control EMC correctly for functional safety reasons, hazard and >>risk assessments must take EM environment, emissions, and immunity >>into account. The following should be addressed: >> >>1) The EM disturbances, however infrequent, to which the apparatus >>might be exposed >> >>2) The foreseeable effects of such disturbances on the apparatus >> >>3) How EM disturbances emitted by the apparatus might affect other >>apparatus (existing or planned)? >> >>4) The foreseeable safety implications of the above mentioned >>disturbances (what is the severity of the hazard, the scale of the >>risk, and the appropriate safety integrity level?) >> >>5) The level of confidence required to verify that the above have >>been fully considered and all necessary actions taken to achieve the >>desired level of safety >>***** >>Please - anybody and everybody out there - tell me if there is >>anything wrong with this engineering approach to EMC-related >>functional safety. Involve experts you know who are not subscribers >>to emc-pstc too. Please be as detailed as you can be. >> >>If I receive no constructive comments about the above 5-point >>approach by the end of January I will assume that the IEE's guide is >>on the right tracks and will not need major revisions. You can send any >> comments to me via emc-pstc or directly to >>keith.armstr...@cherryclough.com or cherryclo...@aol.com. >> >>Interestingly, my reading of IEC/TS 61000-1-2 leads me to believe >>that it follows the same general approach as the IEE's guide. >> >>Regards, Keith Armstrong >> >>In a message dated 31/12/01 21:58:43 GMT Standard Time, >>j...@jmwa.demon.co.uk writes: >> >> >>>Subj:Re: EMC-related safety issues >>>Date:31/12/01 21:58:43 GMT Standard Time >>> j...@jmwa.demon.co.uk (John Woodgate) >>> owner-emc-p...@majordomo.ieee.org >>>Reply-to: j...@jmwa.demon.co.uk<mailto:j...@jmwa.demon.co.uk> (John >>>Woodgate) >>> emc-p...@majordomo.ieee.org >>> >>>I read in !emc-pstc that cherryclo...@aol.com<17c.18c06c2.296 >>>20...@aol.com>) about 'EMC-related safety issues', on Mon, 31 >>>Dec 2001: >>> >>>> Quite a number of EMC and Safety experts took part in >>>creating the IEE's >>>> Guide on EMC and Functional Safety, including a lawyer who >>>specialises in >>>> high-tech issues. You will find their names listed at the >>>end of the 'core' >>>> of the guide (downloadable from >>>www.iee.org.uk/Policy/Areas/Electro). Many >>>> of these experts also involved their colleagues and others >>>so we got a very >>>> wide spread of opinion. >>> >>>My comments referred to the IEC work, specifically verbal >>>reports from >>>people involved. You will have noticed that the work culminated >>>in a TS, >>>not a standard as originally envisaged. That in itself may be an >>> >>>indication of certain difficulties in its passage through IEC. >>> >>>I think that a passionate defence of the IEE document (which I >>>have not >>>studied, so will not comment on) *may* also be an indication >>>that there >>>is more emotion surrounding this subject than is desirable. >>>-- >>>Regards, John Woodgate, OOO - Own Opinions Only. >>>http://www.jmwa.demon.co.uk >>>After swimming across the Hellespont, I felt like a Hero. >>> >>> > > > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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