Ron,
I absolutely support your recommendation to include a safety test report in an
EMC Compliance Folder anyway.
That is my recommendation to anyone also.
Best regards,
Kevin Richardson
Stanimore Pty Limited
Compliance Advice & Solutions for Technology
(Legislation/Regulations/Standards/Australian Agent Services)
Ph: 02-4329-4070 (Int'l: +61-2-4329-4070)
Fax: 02-4328-5639 (Int'l: +61-2-4328-5639)
Mobile: 04-1224-1620 (Int'l: +61-4-1224-1620)
Email: kevin.richard...@stanimore.com or kevin.richard...@ieee.org
URL: www.stanimore.com
Confidentiality
This material (this email including all attachments) may contain confidential
and/or privileged information intended to be read or used by the addressees
only. If you are not one of the intended recipients, any copying, disclosure,
distribution, use of or reliance upon this material is prohibited. If you
receive this material in error, please immediately notify Stanimore Pty
Limited and delete/destroy all copies (electronic and hardcopy) of this email
and all attachments. While the sender tries to ensure the accuracy of the
information contained in this material, Stanimore take no responsibility for
any actions taken as a result of receiving this material or for any
consequence of its use.
-----Original Message-----
From: Pickard, Ron [mailto:ron.pick...@intermec.com]
Sent: Tuesday, 24 February 2009 9:38 AM
To: kevin.richard...@ieee.org
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Australia C-Tick and safety requirements
Hi Kevin,
Thank you for your detailed and informative reply.
Please note that I agree with you completely about the EMC Handbook.
Although
it gives some good guidance and useful information, it is still a handbook
after all. And, although C-tick compliance folders are not required to contain
a safety report, I believe it’s a good idea to include one anyway, but
that’s a preference and not a requirement.
Dan,
I hope you can now answer your friend’s questions.
Best regards,
Ron Pickard
ron.pick...@intermec.com <mailto:ron.pick...@intermec.com>
________________________________
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Kevin
Richardson
Sent: Monday, February 23, 2009 4:07 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Australia C-Tick and safety requirements
All,
A couple of clarifications may be helpful.
EMC Requirements
Australian EMC regulations do not include any 'product safety'
requirements.
As such, the Compliance Folder for EMC should include:
* a DoC declaring compliance with currently acceptable versions
of AS/NZS
CISPR 22 or CISPR 22 or EN 55022; and
* a test report from a reputable test lab confirming compliance
with the same
standard; and
* the usual product information required to uniquely identify the
device
This is all that is required in terms of EMC.
NOTE: Just a warning that EMC Handbook as mentioned by Ron should not
be
used as the definitive last word on compliance. While the EMC handbook si
helpful in describing the requirements in everyday language, it is not the
actual instrument of regulation and as such may not necessarily accurately
reflect the requirements at any given time and may well lag behind in
describing changes made to the regulations. To be absolutely sure you are
dealing with the current requirements you should always refer to the
regulatory instrument itself, i.e. the "Radiocommunications Labelling
(Electromagnetic Compatibility) Notice 2008" (commonly referred to as the EMC
Labelling Notice). This can be found at:
http://www.acma.gov.au/WEB/STANDARD/pc=PC_310703
<http://www.acma.gov.au/WEB/STANDARD/pc=PC_310703>
The actual regulatory instrument is kept at a different government
website
however, it is easier to start from the above link on the ACMA website.
Safety Requirements
In terms of electrical safety, if I understand correctly this "in-line
filter" device is a stand-alone device that includes a plug to plug into the
mains and also a connector for the PC mains plug to plug into and it
incorporates overvoltage and line filtering components.
If this is the case, then sounds like this device, most likely, would be
classified as a "Control or Conditioning Device" under Australian Electrical
Regulations and is therefore a 'Declared/Prescribed Article' and requires
formal approval by an Australian Electrical Authority.
Although some of this has been mentioned before, every device that
connects
to the mains supply in Australia is captured by the Electrical Regulations in
each Australian State or Territory, administered by that State's/Territory's
Electrical Authority. These electrical regulations divide products into two
categories as previously described by others. These being "Prescribed or
Declared Articles" and Non-prescribed or Non-declared Articles" (terminology
depends on the State or Territory). For Prescribed or Declared Articles
formal approval from the Regulatory Authority in one of the Australia
States/Territories is required. Approval from any State/Territory is accepted
in all other States/Territories. As previously stated by someone else, prior
to sale/supply, such devices must display the approval number issued by the
approving Regulatory Authority.
Using the NSW State Electrical Regulations as an example, this device is
captured under category 8 of the 'Declared Article's category listing, see
extract below:
8. CONTROL OR CONDITIONING DEVICE - an electrical device which -
(a) is a household type;
(b) is for controlling or conditioning the electrical input to
electrical
apparatus;
(c) is self contained; and
(d) connects to supply by means of a flexible cord and plug, appliance
inlet
or pins for
engagement with a socket-outlet.
Class specification:
AS/NZS 3100 and AS/NZS 3197:2005 with amendment 1.
The applicable standard would be AS/NZS 3197 as identified above. The
mains
plug and mains cordage (if it had cordage rather than the device incorporating
mains plug pin connectors) are also in their own right, Declared/Prescribed
Articles and must be approved and display the approval number.
Requirements for Non-Declared/Non-Prescribed Articles
For Non-prescribed or Non-declared Articles, while there is no
requirement
for formal approval etc the device is still captured by the Electrical
Regulations and must comply with the requirements for Non-prescribed or
Non-declared Articles, i.e. AS/NZS 3820. Those requirements are as described
by Peter in an earlier email, i.e.:
Non-prescribed electrical equipment
A person who sells non-prescribed electrical equipment must comply with
section 120 of the Regulation. Generally speaking all non-prescribed
electrical equipment must comply with the safety criteria of AS/NZS3820
(Essential safety requirements for low voltage electrical equipment). This
would include, but not be limited to:
* a test report showing compliance to the relevant Australian
product
standard;
* if no relevant Australian product standard exists, a test
report
showing compliance to another relevant standard such as AS/NZS3350.1,
AS/NZS60335.1 or AS/NZS 3100;
* a certificate of approval issued as per relevant Australian/NZ
legislation;
* another method consistent with clause 5 of AS/NZS 3820
Usually, the easiest way means of complying is by way of the 1st option
of
using a test report showing compliance with with the relevant Australian
product standard.
Consumer Protection Laws
Consumer protection laws by way of the Australian Trade Practices Act
also
require the device be "safe" and "fir for purpose". "Safe" is defined as
complying with the relevant Australian product safety standard or generic
safety standard where no product standard exists so by default, in complying
with the Electrical Regulations of the various Australian States/Territories
you comply with the consumer protection laws. While the consumer
protection laws concern all aspects of safety, not just electrical safety, by
complying with the Australian product safety standard you would be considered
to have taken all reasonable precautions.
Safety of a Telecommunications Device
The Australian telecommunications regulations have specific safety
requirements and require the product Compliance Folder includes, apart from
other things, a test report to AS/NZS 60950.1 from an RTA (Recognised Testing
Authority). A listing of RTA test labs is maintained by NATA (National
Association of Testing Authorities). A CB test lab is not necessarily an RTA
so a CB test report may not be acceptable.
The issue mentioned by Ron about ACMA auditors not accepting a test
report to
IEC 60950.1 + Australian National deviations etc should not occur where:
* the IEC 60950.1 report also clearly states compliance with
Australian
National deviation according to AS/NZS 60950.1:2003 (the report should clearly
spell out the Australian standard, including the version); and
* the test report is from an RTA listed test lab; and
* is an "endorsed" test report (i.e. clearly states the test
report is
produced under the test labs accreditation to test to that standard and
identify the accrediting organisation etc)
Hope this helps along with the input from others.
Best regards,
Kevin Richardson
Stanimore Pty Limited
Compliance Advice & Solutions for Technology
(Legislation/Regulations/Standards/Australian Agent Services)
Ph: 02-4329-4070 (Int'l: +61-2-4329-4070)
Fax: 02-4328-5639 (Int'l: +61-2-4328-5639)
Mobile: 04-1224-1620 (Int'l: +61-4-1224-1620)
Email: kevin.richard...@stanimore.com or
kevin.richard...@ieee.org
URL: www.stanimore.com
Confidentiality
This material (this email including all attachments) may contain
confidential
and/or privileged information intended to be read or used by the addressees
only. If you are not one of the intended recipients, any copying, disclosure,
distribution, use of or reliance upon this material is prohibited. If you
receive this material in error, please immediately notify Stanimore Pty
Limited and delete/destroy all copies (electronic and hardcopy) of this email
and all attachments. While the sender tries to ensure the accuracy of the
information contained in this material, Stanimore take no responsibility for
any actions taken as a result of receiving this material or for any
consequence of its use.
-----Original Message-----
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of
Pickard, Ron
Sent: Saturday, 21 February 2009 4:34 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Australia C-Tick and safety requirements
Dan, Jim et al,
I believe the Australian document that you were requesting is
the ACMA’s
EMC Handbook, which can be accessed at:
http://www.acma.gov.au/webwr/aca_home
publications/reports/industry/manuals/emcbook.pdf
<http://www.acma.gov.au/webwr/aca_home/
ublications/reports/industry/manuals/emcbook.pdf>
The ACMA does not impose safety requirements for C-tick (ACMA)
or RCM
(Regulatory Compliance Mark, owned by AU & NZ regulators) markings, but I
believe the “state authorities” that Peter refers to do and are the
provincial electrical authorities (refer to Appendix D) which must ensure that
equipment attaching to the electrical power grid is safe and in almost all
cases pertains to power supplies and power cords. Please note that in some
cases, registration will be needed. Also, Appendix E may also apply to your
product.
So, it is a good idea to also include an acceptable
Australian/New Zealand
safety report and the electrical authority’s acceptance, where applicable,
into the product’s DofC and the compliance folder.
In regard to your last question, although a CB
certificate/report with AU/NZ
deviations does indeed cover your product for safety in Australia & New
Zealand, the ACMA has been a bit persnickety during compliance folder audits
about it preferring actual AS/NZS 60950-1 reports generated from NATA
accredited labs. If anyone can point to an actual ACMA requirement on this
point, we all would be grateful.
I hope this answered your questions and as always, I stand to
be corrected
where needed. Comments?
I look forward to your reply.
Best regards,
Ron Pickard
ron.pick...@intermec.com <mailto:ron.pick...@intermec.com>
________________________________
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of
Jim Robson
Sent: Friday, February 20, 2009 10:47 AM
To: pmerguerian2...@yahoo.com; EMC-PSTC@LISTSERV.IEEE.ORG; Dan
Roman
Subject: RE: Australia C-Tick and safety requirements
Peter,
I have been researching this issue also. Can you tell me what
Australian
document says that C-tick marked ITE (non-Telco) equipment must comply (and/or
be tested to) with AS/NZS 60950?
The Telecommunications Labelling (Customer Equipment and
Customer Cabling)
Notice 2001 definitely calls out AS/NZS 60950 for Telco equipment.
The Radiocommunications Labeling (EMC) Notice 2008 which covers
ITE does not
call out AS/NZS 60950.
You also wrote "does not require a safety approval from a state
authority".
Do mean AS/NZS 60950 testing must be done at an approved lab and then cite
AS/NZS 60950 on the Declaration of Conformity?
Regards,
Jim Robson
________________________________
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of
peter
merguerian
Sent: Friday, February 20, 2009 7:43 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG; Dan Roman
Subject: Re: Australia C-Tick and safety requirements
For safety, this is not a perscribed equipment and therefore does not require
a safety approval from a state authority
However, the product must still comply with the Australia safety requirements
in AS/NZS 60950.1. This standard is harmonized with IEC60950-1 so if you
comply with the standard and its' Austrlia devioations, you're good to go.
Peter Merguerian
--- On Fri, 2/20/09, Dan Roman <dan.ro...@dialogic.com> wrote:
From: Dan Roman <dan.ro...@dialogic.com>
Subject: Australia C-Tick and safety requirements
To: "EMC-PSTC@LISTSERV.IEEE.ORG" <EMC-PSTC@LISTSERV.IEEE.ORG>
Date: Friday, February 20, 2009, 7:23 AM
Hello all,
I’m passing along two questions for a friend that I cannot answer
because
they are outside of my product area of expertise. The product in question is
a passive line filter for use with a PC. It contains overvoltage and line
filtering components (some coils, caps, and MOVs).
1. Does the C-Tick mark for non-telecom equipment require both EMC
and
safety declarations? I know that for the telecom equipment my company
produces, the ACA requires telecom, safety, and EMC (A-tick and C-tick) but I
don’t know if the safety portion is a telecom specific requirement or not.
If the answer is the C-Tick is for EMC only, are there other requirements for
safety or other marks that would apply to this product in Australia? I am
sure there must be.
2. Does a passive device like this fall under EMC requirements?
CISPR
22/EN55022 don’t specify a lower frequency limit exempting products, so this
passive line filter connected to a 50 Hz supply would appear to need testing.
Everything I deal with has clocks in excess of 1 GHz these days so this
question never came up where I work!
It is always interesting getting questions outside of your normal day
to day
experience.
--
Dan Roman, N.C.E.
Product Regulatory Engineer
Dialogic Research Inc.
1515 State Rt. 10
Parsippany, NJ 07054-4538
*mailto:dan.ro...@dialogic.com <mailto:dan.ro...@intel.com>
*Voice: +1 973-967-6485 Fax: +1 973-967-6262
Intranet: http://compliance.eicon.com/
<http://compliance.py.intel.com/>
Internet: http://www.dialogic.com
<http://www.intel.com/design/network/products/telecom/index.htm>
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