Good point - didn't know that (:-)), but it's another example of where the EU approach is more pragmatic.
-----Original Message----- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 21 February 2015 22:01 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Is NRTL listing mandatory for consumer-grade telephone terminal equipment? In message <!&!AAAAAAAAAAAYAAAAAAAAAEGjmYsMtGZAuvo7rFLQ++figAAAEAAAADf9dud5KeJHuCKyK rUnaccBAAAAAA==@blueyonder.co.uk>, dated Sat, 21 Feb 2015, John Allen <john_e_al...@blueyonder.co.uk> writes: >OTOH, the EU approach is more encompassing because the prime >requirement is to comply with the essential protection requirements of >the relevant Directive(s). As such you do NOT need to comply with all >the detailed requirements of a standard, but if you claim compliance >with a Harmonized Standard but you don’t comply with some of its >specific requirements then you DO have to identify where you have >deviated and how you still hold that you comply with the essential >requirements of the Directive in question. There is an important principle here, and it almost certainly applies to PV products, which use relatively new technology that is still being improved. No-one will try to write a standard for a product that does not yet exist, so standards development must always lag innovation. If it lags as little as possible, it can hamper product improvement, because it's written around a 'Mark 1' version of the new technology. If it lags a lot, badly-designed products can appear on the market, and the lagging standard's provisions may be influenced by them - governments and manufacturers will not generally allow standards to drive existing products from the market. The EU system attempts to resolve this dilemma - swift standardisation is encouraged. Product improvement is permitted, but controlled by the requirement to state and justify a deviation from the applicable standard. A historical example. LED lamps were illegal on British bicycles for some years after they became practicable, because the (very elderly) regulations specified 'incandescent lamps', with the intention of disallowing acetylene ('carbide') lamps. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- 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: 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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- 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: 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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
