In message <7861714BC9794A2C8FE39FAD9F42BC3C@MmPc21>, dated Thu, 13 Nov 
2008, Piotr Galka <piotr.ga...@micromade.pl> writes:


>I have in mind the open (without case) boards question just from the 
>beginning of my interest in EMC (2 years before we joined EU in 2004) 
>because since 1992 we have in our offer the microcontroller education 
>system with some open boards connected when needed. After reading old 
>Directive and its guide and later the new Directive and its guide I am 
>still not sure if after 2004 we sell it legally or not and designing 
>new (this time analogue) education system I'd like to be sure.

I have given your case some more thought and consulted one or two 
colleagues, because it discloses an omission in the official 
documentation, insofar as the special case of educational products is 
not addressed.

Please understand that this is just my personal opinion and in no way 
could I guarantee that it will work.

We have to go back, first, to a basic EMC principle, which is that a 
source of disturbance, however strong, is of no consequence if there is 
no potential victim equipment within the distance at which the 
disturbance phenomenon has declined to a negligible level.

A second point is that in an environment under a single ownership, the 
responsibility of mitigating any interference between equipment in that 
environment rests with the owner. This must be so, because the EMC 
standards assume certain distances between source and victim, whereas an 
owner may place them very close together. So you don't have to worry 
about a TV in a room next to the electronics lab - the TV may have to be 
moved.

The Directive requires you to produce an EMC assessment. The following 
information, with the reasoning behind it, should be included in the 
assessment.

As regards the first point and the emissions from your equipment, you 
should specify a minimum separation of, maybe, 10 m between the 
equipment and sensitive equipment such as TVs not owned by the users of 
your equipment.

For ESD, you should specify that ESD precautions MUST be taken, because 
the equipment is INHERENTLY sensitive to ESD and cannot be rendered 
immune while serving its intended purpose.

Then you use the procedure given in Annex III of the 2004/108/EC 
Directive to get a formal acceptance of your solution by a Notified 
Body. You can then, under Article 7, apply the CE mark.

-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Either we are causing global warming, in which case we may be able to stop it,
or natural variation is causing it, and we probably can't stop it. You choose!
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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