All - I have received a number of responses, for which I am grateful.
As a matter of course, we must all try to act as lawyers in pursuit of compliance. To that end, I reviewed the documents I had in hand [which included the CSA transition document (which I treat as a third hand interpretation), the LVD, the list of harmonized standards from the OJ, the Guide to the Implementation of Directives Based on New Approach and Global Approach, EN60950:1992 through A4 and a copy of the Forward to EN60950:2000], prior to posting my query. None of these provided me with a feeling of certain knowledge. As points of comparison, I offer the following citations. >From Guide to the Implementation of Directives Based on New Approach and Global Approach (the so-called "Blue Guide"): 4.5. Revision of harmonised standards Following its internal regulations, the relevant European standard organisation lays down the date of publication at national level of the revised harmonised standard, and the date of withdrawal of the old standard. The transitional period is normally the time period between these two dates. During this transitional period both harmonised standards give presumption of conformity, provided that the conditions for this are met. After this transitional period, only the revised harmonised standard gives a presumption of conformity. The Commission may consider that, for safety or other reasons, the old version of the harmonised standard must cease giving a presumption of conformity before its date of withdrawal, set by European standards organisation in question. In such cases, the Commission fixes an earlier date after which the standard will no longer give a presumption of conformity, and publishes this information in the Official Journal. If circumstances allow, the Commission consults the Member States prior to taking a decision to reduce the period during which the standard gives a presumption of conformity. The reference of the revised harmonised standard, the reference of the old harmonised standard, and the date where the presumption of conformity of the old standard finishes are published together in the Official Journal. >From EN60950:1992, Forward to A4: For products which have complied with EN 60950:1992 and its amendments A1:1993, A2:1993, A3:1995 before 1998-08-01, as shown by the manufacturer or by a certification body, this previous standard may continue to apply for production until 2003-08-01. You will note that there is a distinct difference in language between the two documents. EN60950:1992 is quite clear, while the Blue Guide is not quite satisfying. Other points of comparison lie in the last dates of manufacture in the various forwards EN60950:1992 and the right-most column from the OJ's list of harmonized standards titled "Date of cessation of presumption of conformity of the superseded standard." These dates agree completely, though I still wished to eliminate all doubt, because of the differences in language. The language of the list of harmonized standards and the Blue Guide don't explicitly mention manufacturing and could be interpreted as the last date a product certification could be obtained using a standard, which is consistent with the text of the forwards to EN60950:1992. With the absence of similar verbiage in the forward to EN60950:2000 and knowing that the last dates of manufacture in EN60950:1992 occurred some time after the DOW for each amendment, I am left desirous of certainty. With the advent of an additional interpretation (I say interpretation, because I've seen nothing explicit, official and in writing to support this) that the DOW is the last date a product may be offered for sale, irrespective of dates of manufacturing, what used to apply for last dates of manufacture, and that product might be in a distribution path well prior to the DOW, but not yet sold. Not to disparage the value of previous postings or to doubt the veracity of posters on the subject, but we all must take posts to the list server with a grain of cynicism, lest we find ourselves paddleless up a reeking creek, heading for the rapids. The old saw about "assume" plays a key role. I now wish to change my query, to alleviate the irritation some may have felt at this being "asked again": is there an official document available that provides unambiguous clarity defining "date of cessation of presumption of conformity of the superseded standard," in the context of manufacturing? My searches on Europa, UK DTI and the internet in general have not to date yielded useful results. Regards, Peter L. Tarver, PE Product Safety Manager Sanmina-SCI Homologation Services San Jose, CA peter.tar...@sanmina-sci.com ------------------------------------------- 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"
