Jim et al,
 
I have been following this with a certain fascination.
 
Willful ignorance -- choosing to ignore a fact one knew or should have known
-- is far from being a defense when questioned on compliance matters.  Would
the choice not to test for combined leakage current in a medical device render
the a marketer immune who know each part contributed to a level over that
permitted?  IMO the same logic applies to emissions.  
 
IMO, even if one is not legally required to test, -- as in the sale of
components direct -- one might well find himself in violation of implied
warranty of serviceability should a customer find himself forbidden because of
emissions to use what we sold him. 
 
WE know - or should know -- when we have something borderline or worse.
 
 
Cortland Richmond
KA5S
 

        ----- Original Message ----- 
        From: Knighten, Jim L <mailto:jim.knigh...@teradata.com>  
        To: emc-p...@ieee.org 
        Cc: Rowson, Stuart <mailto:stuart.row...@teradata.com> 
        Sent: 10/27/2009 5:20:14 PM 
        Subject: certifying overall products vs. certifying individual 
constituant
chassis

        I am wondering what the industry experience is regarding basing EMC or 
Safety
product certification on individual chassis (or subsystems/components) that
may comprise the product, vs. certification at the product level?

        

        In particular, I have some products that are 40U racks containing 
multiple
chassis, each of which is compliant and has its own certification.  Currently,
product certification is done at the entire product level (i.e., rack) and
there is a product regulatory label on the overall product.  I know that some
companies (names withheld) that appear to be certifying only at the chassis
level, rather at the ensemble product level.

        For EMI, I know the physics teaches us that CE + CE does NOT equal CE 
(i.e.
one compliant chassis combined with another compliant chassis does not assure
a compliant combination of the two chassis).  I have war stories to
corroborate this.

        For Safety, there are some tests (heating test is an example) that can 
be are
run at the product level.

        Country approval documentation requirements vary by country, but usually
there is requirement for a DoC, CB report, etc.

        

        I get increasing pressure internally (economically driven) to declare 
product
certification done if all the constituent chassis are compliant and certified.

        What is the experience you guys have?

        Thanks in advance,

        Jim

        __________________________

        James L. Knighten, Ph.D.

        EMC Engineer

        Teradata Corporation

        17095 Via Del Campo

        San Diego, CA 92127

        858-485-2537 – phone

        858-485-3788 – fax (unattended)

        


        

        

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This message is from the IEEE Product Safety Engineering Society emc-pstc
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