Hello Jim,
 
See below

--- On Tue, 10/27/09, Knighten, Jim L <jim.knigh...@teradata.com> wrote:



        From: Knighten, Jim L <jim.knigh...@teradata.com>
        Subject: certifying overall products vs. certifying individual 
constituant chassis
        To: emc-p...@ieee.org
        Cc: "Rowson, Stuart" <stuart.row...@teradata.com>
        Date: Tuesday, October 27, 2009, 2:19 PM
        
        

        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?

         

        Peter: Most manufacturers of rackable systems do tests and 
certification at the system 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.

         

        Peter: I also have come across some manufacturers that have not 
certified at the system level. Some of these manufacturers have been negligent 
about safety/emc regulations - others have done their due diligence and have 
additionally tested the racks at the system level (even though they have not 
submitted the rack system for certification by a third party). The latter may 
have tested system level tests for emc (quiet an experience as you mention 
below), but also have conducted internal safety tests such as Input Test (to 
ensure the overall system  ratings are not exceeded), monitored internal 
ambient temperature to ensure the internal chassis manufacturer's specified 
ambient levels are not exceeded, Leakage Current Test to ensure the cord 
connected earthed limit of 3.5 mA is not exceeded (exceptions if product is 
marked with a High Leakage Current Marking and provided with a specialized 
plug) and for rack systems that are not fixed to the floor, a Stability Test is 
conducted. 
        

        From the safety standpoint, in the US and other parts of the world,  a 
local inspector or certification body may not have problems with a rack system 
that has internal components that are Listed/Certified having their own power 
cords or interconnected by means of a PDU. As such some manufacturers opt for 
certification at the subassemly level. As the long as the subassemly is 
Listed/Certified, no further action is required. Such manufacturers are putting 
themselves at risk if they have not taken precautionary measues to ensure the 
system is compliant with all of the applicable safety requirements. Same goes 
with emc. 

         

         

         

        For EMI, I know the physics tto ebeaches 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.

         

        Peter: You are 100% correct and I know a few people in this forum whom 
I worked with in the past who can attest to this. 

         

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

         

        Peter: That is correct, but the manufacturer's specified maximimum 
ambient levels must be followed. In other words, if you purchase an ethernet 
switch which has been tested to a 25 deg C ambient (you can review the 
manufacturer's safety test reports), you cannot use it in your rack system 
which may be rated for a 50 deg C ambient. 

         

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

         

        Peter: This is an area where you need to spend time and define the 
countries where certification or a type approval is a must, the exceptions and 
what documentation (CB, NRTL Listing, FCC, EU EMC) will be required to meet the 
country's mandatory certification requirements for safety and/or emc. A system 
CB and/or emc report as applicable will go a long way in complying with the 
country's mandatory requirements.
        
        

        

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

         

        Peter: This could be a great solution for a country that has no 
specific regulations for safety and/or emc. For countries suc as the US where 
product liability laws are strict,  proof of compliance at the system level is 
the way to go

         

         

         

        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 
discussion list. To post a message to the list, send your e-mail to 
<emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at 
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