Chris, Firstly I provided on what the LVD and the associated Guidance document says. So don't shoot the messenger.
Secondly, the fanciest electronic means of documentation available isn't worth a bean if it cannot be accessed in the EU. Perhaps you are thinking of a means whereby your technical documentation is available on-line, probably stored in multiple locations so that if one server goes down then one or more others can take over: in such cases it may be that you could always pull the technical file over, print it out in the EU, and the surveillance authorities would never know any difference. In such cases it would be pretty surprising if the said surveillance authority were to complain that the paperwork hadn't actually been sitting on some shelf in the EU gathering dust. Nevertheless, the LVD still says what the LVD says. Thirdly, a problem with technical files is having the required software to read it or turn it into paper. Of course, having the technical file available as a PDF helps, but there is still a requirement to have the technical file available "for a period ending at least 10 years after the last product has been manufactured." Some companies certainly do have the means to maintain and access electronic files for the requisite 10+ years (e.g. 20 years for a product with a 10 year production life): others, however, do not. Finally, please do not get confused between standardisation and regulations. CENELEC is a standards body (like ANSI) and they do not tell the law makers and enforcement bodies (read Capitol Hill, OSHA/FDA) what to do. Each Member State in the EU has its own way of enforcing the national legislation that approximates EU directives. However, there is a mechanism for sharing information between Member States and the Commission on products that have been taken off the market on safety grounds - and guess what, neither CENELEC, CEN or ETSI play any part in it. Regards, Richard Hughes -----Original Message----- From: Chris Maxwell [mailto:chris.maxw...@nettest.com] Sent: 11 December 2002 18:49 To: Gary McInturff; Nick Williams; Stephen Irving Cc: emc-p...@majordomo.ieee.org Subject: RE: Location of CE DoCs - electronic copies Gary, I'm with you on this one. I consider electronic availability to be equal to, if not superior to, having the documents on "European Soil". My feeling is that: as long as the documentation explains what the CE mark means; and points the user in the right direction for getting the files; then files can be emailed at a moment's notice; and the reader is guaranteed to get the latest revision as stored in our Document Control system. I don't think that you can make the equivalent statements about any method of keeping paper copies at any location. Of course, these are just my opinions and interpretations. I haven't had to tell them to a judge (does CENELEC have a judge?); but I believe that the reasoning is sound. Chris Maxwell | Design Engineer - Optical Division email chris.maxw...@nettest.com | dir +1 315 266 5128 | fax +1 315 797 8024 NetTest | 6 Rhoads Drive, Utica, NY 13502 | USA web www.nettest.com | tel +1 315 797 4449 | > -----Original Message----- > From: Gary McInturff [SMTP:gary.mcintu...@worldwidepackets.com] > Sent: Wednesday, December 11, 2002 10:38 AM > To: Nick Williams; Stephen Irving > Cc: emc-p...@majordomo.ieee.org > Subject: RE: Location of CE DoCs - electronic copies > > > Does electronic storage of the documents make any difference? The DoC, the test reports, BOM's, drawings and Design verification tests are all stored electronically and can be dumped from any printer in the world. Obviously, they would have electronic signatures. > Gary > > > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ 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: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
