>(who supposedly has been shipping CE marked product to EU on their own for >years "with no issues")
Absence of proof of non-compliance is not proof of compliance (or "so what" in short hand :) ) Whilst you're chasing the safety - compare built state subjected to EMC with current build state. Regards Charlie -----Original Message----- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: 14 March 2014 14:54 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Critical Components definitions All makes perfect sense. In the case of a project I have now which is not typical our outsource manufacturer has already gone through the process of obtaining passing EMC and safety reports from their independent agency in the US (who I won't name here but is not an OSHA approved NRTL, they only do CE compliance). Interestingly enough their safety report refers to the critical components list in an annex but they did not initially provide it to me (other annexes were missing as well). Ultimately my company is responsible for the product and the TF so I've been going back and forth with our outsourcer (who supposedly has been shipping CE marked product to EU on their own for years "with no issues") explaining what a critical components list is. Now if none of that makes any sense, I.e. a safety report from a certification agency which includes an empty annex where a critical component list is supposed to be that did not exist at the time the report was written, well it doesn't make sense to me e! ither. -Dave -----Original Message----- From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Friday, March 14, 2014 9:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Critical Components definitions I have always viewed the Safety Critical Components List (SCCL) as kind of like a Cheat Sheet or Road Map to a safety inspection. As probably most Safety Inspectors, I wouldn't even think about starting a safety evaluation without the SCCL up front. Otherwise, you would be crawling around inside someone's product and probably having to dismantle every part trying to see the manufacturer's name, part number, ratings and hopefully some agency approval marks. Then doing an endless Internet search for the missing information and probably not finding it. I view this as a waist of my time. Internally, on our own products, we include as much information on our SCCLs as we can. We even list components that may technically not be a Safety Critical Components by application, but may make a safety inspections go smoother by including it. For instance, we list every PC board just in case the inspector asks us to show proof of its flammability rating or wants to see the artwork. We include the Rating Label and all warning labels on the SCCL. We even include the part numbers for Schematics that would be helpful to have during an inspection. Over time we have learned what information is helpful to have during an inspection and we try to include that information within the SCCL. Our SCCLs of course includes the manufacturer's name, part number, ratings, and approvals. If a part has special protection requirement we include that. We also include a Web Link to the manufacturer's data sheet if available. If a part does not have agency approvals but is verified as part of our type testing, that is noted on the SCCL. This information is all stored within our components database system and tied to the BOMs of each model of products produced. Our SCCLs becomes part of our internal safety test reports (modeled after the CB test reports). This information is given to Inspectors who will often include our SCCLs within their Field Evaluation reports. Hope this information is helpful. The Other Brian -----Original Message----- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Friday, March 14, 2014 8:16 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Critical Components definitions Actually I wasn't just referring to their selection of components (in itself an issue, they pretty much included the entire BOM) but the information in the list. They haven't provided any of the NRTL mark info, critical tech specs, or applicable standards the parts are certified to after repeated requests. I finally got them to provide the manufacturer names and part numbers. -Dave -----Original Message----- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Friday, March 14, 2014 3:22 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Critical Components definitions In message <d9c1067d2cb544069485d5c3cdbf4...@bn1pr08mb059.namprd08.prod.outlook.com<mailto:d9c1067d2cb544069485d5c3cdbf4...@bn1pr08mb059.namprd08.prod.outlook.com>> , dated Fri, 14 Mar 2014, "Nyffenegger, Dave" <dave.nyffeneg...@bhemail.com<mailto:dave.nyffeneg...@bhemail.com>> writes: >they don't seem to understand what a critical components list is. I've >given them examples and not gotten very far so I was looking for >something more official like from the standards. Standards writers cannot tell what parts a designer might use and how they might be used. A component could be critical in one circuit but not in another. Bearing in mind what a 'critical component' is (one whose failure, in any way, would compromise safety), one normally examines the schematic and, for each part, considers 'What if...?'. This enquiry must include whether further failures might occur as a consequence of one part failing. Of course, some components are always critical, some, but not all, of those in mains supply circuits. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> Nondum ex silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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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: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
