Thanks Nick,
I knew that what was happening with the CB wasn't right, but I was afraid to
challenge them since they would presumably know more than me, and therefore
in some way may have been able to justify what they were (are) doing.

As for the EN60439 issue, I have found that certain labs will not make
engineering judgements, depending on which body has accredited them.  They
will only report on facts derived from testing.  Even when the engineers say
"off the record it will be OK", they still won't put it in a report and say
"It is our considered opinion that this or that change is unlikely to effect
the compliance of this or that product".  I do find the whole thing so very
frustrating, made even more so because, to me EN60439 is an awkward standard
to follow.  Perhaps it is just me.

Thanks again,

David Sproul.

-----Original Message-----
From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: 27 June 2002 21:47
To: David Sproul
Cc: EMC-PSTC
Subject: Re: Multiple Product Variants under EN60439.


David,

Replies in the text of your questions...


At 17:25 +0100 26/6/02, David Sproul wrote:
>Dear Group,
>As you will all know, under the EMC Directive a range of product
>variants can be covered by a Technical Construction File.
>
>A company who manufactures control panels for large industrial plant
>has to re-submit every control panel it makes the a Competent Body
>because it was impossible for them to build a super panel with every
>conceivable component included.
>
>I have 3 questions:
>1/  Is there any other way they can have their range cover by a TCF
>without having to re-submit to the Competent Body?

Firstly, I suggest they find a new CB - it sounds like the one they
have got is more interested in making money at their expense than in
solving a problem for their clients. Secondly, it's highly likely
they don't need to be using a TCF anyway.

>2/  Under the LVD, do these panels have to be type tested to EN60439
>by a Certified Body?

No. And 60439 may not be the right standard anyway.

>3/ Is there anyway they can have their panel range reviewed to
>EN60439 and be sure that their Safety Technical File will cover
>future variants, without having to return to the Certified Body for
>each new Panel.
>

Yes. They need to be trained to know how to do it for themselves.

>The industry they work in is very competitive, so they cannot raise
>their prices too much.  Therefore each visit to the Competent Body
>and the Certified Body is eating into their meagre profits.
>

Most of their competitors don't bother with independent verification
for either safety or EMC.

>Are there any significantly knowledgeable people who could bring
>this company some good news?
>

It's what we do for a living. To say more would be an abuse of the
EMC-PSTC forum.

>Best regards,
>David Sproul,
>Alexander Lynn Approvals Management,
>Tel/fax +44 (0) 1383 852222
>Mobile +44 (0) 7950 744466
>
>

Regards

Nick.

----

Conformance Ltd - Product safety, approvals and CE-marking consultants
Tel. + 44 1298 873800, Fax. +44 1298 873801
Registered in England, Company No. 3478646


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