Hi Kevin, I am inclined to side with the regulatory authority. If you have a device that has an R&TTE component in it, than that directive applies. Since the R&TTE Directive requires compliance to the EMC and LV directives in order to declare conformity to it, it is not necessary to declare to them individually. If the R&TTE Directive did not require conformity to either the EMC or LV directives, then those would have to be applied and declared to separately.
Kind Regards, Sam Wismer Engineering Manager ACS, Inc. Phone: (770) 831-8048 Fax: (770) 831-8598 Web: www.acstestlab.com -----Original Message----- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of Kevin Harris Sent: Wednesday, March 06, 2002 12:28 PM To: EMC-PSTC (E-mail) Subject: R&TTE DoC Philosophy Question Hello, I just had an interesting conversation with the head of a approvals authority for a country in Europe for our type of products. The discussion centred around DoCs for the R&TTE directive. His claim was since I had a product that has a R&TTE element to it then I just make a declaration to the R&TTE directive and not to the EMC directive. To support his claim he refers to Article 3.1(b) of the R&TTE directive which states "1.The following essential requirements are applicable to all apparatus" and part (b) "the protection requirements with respect to electromagnetic compatibility contained in Directive 89/336/EEC. His interpretation is, then, that any standard published in the OJ for the EMC standard is (by this clause) also valid for the R&TTE directive and one should make their declaration accordingly. My interpretation of this statement is slightly different. I believe that I cannot make an R&TTE directive DoC using EMC published standards. I felt that the intention of this clause meant that just because you are declaring to the R&TTE directive you are in no way relieved of the obligations of the EMC directive. Accordingly we produce a EMC declaration and a R&TTE declaration. The EMC declaration uses standards published in the EMC OJ to show compliance and the R&TTE directive DoC is to the standards published in the OJ for that directive. In the end I suppose this is all semantics as you end up doing the same test suite regardless but........ What are the feeling of this group. Do you agree with either position? Do you have another interpretation? Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: harr...@dscltd.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...@mediaone.net 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" ------------------------------------------- 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...@mediaone.net 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"
