I have not done systems that are as physically big or as yours, but this
is how we have danced at the 'component vs systems' party. If you have
data that indicates each combination of boxen has unique performance, then
you must certify at system, so you ignore the following.

1. Provide, to marketing, a summary of regulatory requirements for
system-level vs box-level. 
2. Request sales dept to perform marketing study to determine if the
end-user will bear the cost/effort of system-level certification.
Emphasize the resultant box-level conditions of acceptability and user
document requirements. And perhaps the sales dweebs may actually want to
provide some boxen as individual products.
3. Present regulatory requirements + marketing study to engineering and
sales managers.
4. Live with their decision. 

Finally, if this is for aviation, military, or police/fire - this approach
is not good. The tests must be done at the system level or they have no
meaning.

FWIW, I sitting in front of a halt chamber REPEATING about 35 hours of
tests because sales said "enough - we have tests and reports for all
components" too soon...

Brian 


From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Knighten,
Jim L
Sent: Tuesday, October 27, 2009 1:19 PM
To: emc-p...@ieee.org
Cc: Rowson, Stuart
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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