Hi Scott,

I don't see the risk assessment replacing any requirement to supply a test
report.  My assertion is that any risk assessment we might undertake should
be at least as rigorous as the one that a member state's enforcement body
might do.

You can search for Decision 2010/15/EU here:
http://eur-lex.europa.eu/homepage.html?locale=en

Best regards,
David

*David K. Bell*
Senior Regulatory Compliance Engineer
Milestone AV Technologies

david.b...@milestone.com

+1.952.225.6782

On Fri, Apr 1, 2016 at 9:18 AM, Scott Xe <scott...@gmail.com> wrote:

> Dear David,
>
> Will the EU enforcement body use this format to inquire the LVD compliance
> to the suppliers in the future in replacement of getting the test report to
> the harmonised standard now?  Where to get a copy of the Decision
> 2010/15/EU?
>
> Regards,
>
> Scott
>
> On 1 Apr, 2016, at 5:09 am, David K Bell <davidkbell...@gmail.com> wrote:
>
> Scott,
>
> With regard to the risk assessment requirement in the Directives revised
> under the New Legislative Framework (NLF):
>
> This excerpt is from a discussion of the proposed EU Consumer Product
> Safety Regulation (CPSR):
>
> The European Commission will undertake a risk analysis of the product to
> determine whether the product is likely to pose a 'serious' risk. The
> default risk analysis methodology to be used is the already established EU
> Risk Assessment Methodology (Decision 2010/15/EU), by which products can be
> assessed and classified as posing a 'Low', 'Medium', 'High' or 'Serious'
> risk. If this risk assessment methodology is not appropriate for the
> particular product, the Commission must give a detailed description of the
> methodology used in its place.
>
>
> Appendix 5 of Decision 2010/15/EU on pages 33—64 covers Risk Assessment.
> This is the methodology that a EU enforcement body would use to determine
> if a product poses a serious risk and should therefore be withdrawn from
> the market and notified to other EU member states via the EU RAPEX rapid
> alert system.  Any risk analysis that we do to satisfy the requirements of
> the new LV  and EMC Directives should be no less rigorous.
>
> Best regards,
>
> *David K. Bell*
> Senior Regulatory Compliance Engineer
> Milestone AV Technologies
>
> david.b...@milestone.com
>
> +1.952.225.6782
>
>
> On Thu, Mar 31, 2016 at 11:35 AM, Scott Xe <scott...@gmail.com> wrote:
>
>> There are two major changes in new LVD.  One is the risk assessment that
>> is to be the obligation for the manufacturers.  The other one is that the
>> DoC is required to have object of declaration.
>>
>> The risk assessment is unclear how to do it and any reference to follow.
>> Currently there is few testing laboratories to provide such service to the
>> manufacturers.  Hope there is harmonised standard and/or guidance for
>> compliance in near future.
>>
>> Scott
>>
>>
>> On 31 Mar, 2016, at 1:50 am, Ronald Pickard <
>> ronald.pick...@compoundphotonics.com> wrote:
>>
>> Hi Charlie,
>> Thank you for your reply along with those linked references. Those ETSI
>> links provide projected target dates for approval and availability for the
>> new/revised standards being drafted for the RED, which are generally
>> targeted to be complete by the 13-Jun-2017 effectivity date for the RED.
>> Kudos to ETSI for that work.
>>
>> Best regards,
>>
>> *Ron Pickard*
>> Regulatory Compliance Engineer
>> *Compound Photonics*
>> D | +1 (602) 883-8039
>>
>> *From:* Charlie Blackham [mailto:char...@sulisconsultants.com
>> <char...@sulisconsultants.com>]
>> *Sent:* Tuesday, March 29, 2016 11:34 PM
>> *To:* Ronald Pickard <ronald.pick...@compoundphotonics.com>;
>> EMC-PSTC@LISTSERV.IEEE.ORG
>> *Subject:* RE: EU's new approach directive transitions
>>
>> Ron
>>
>> Few short answers:
>>
>> ·         No sign of that happening at all and I cannot see it happening
>> ·         No, existing Directives are repealed by the new Directives on
>> the dates indicated,  but you may wish to look at Recommended format for
>> DoC that can reference existing and new Directives,
>> http://ec.europa.eu/DocsRoom/documents/14886/attachments/1/translations/en/renditions/native
>> (referenced from
>> http://ec.europa.eu/growth/sectors/electrical-engineering/emc-directive/index_en.htm
>>  )
>> ·         ETSI are working hard on updating over 150 standards, some
>> more information available:
>> o   https://docbox.etsi.org/Workshop/2015/201511_RED-WORKSHOP/ for
>> presentations from November workshop
>> o   Work program on radio standards:
>> http://webapp.etsi.org/ena/cvp.asp?search=RADIO and a number of RED
>> standards have a been published or are available as final draft
>> o   Work program on EMC standards:
>> http://webapp.etsi.org/ena/cvp.asp?Search=emc&Status=&Directive=&submit1=Get+Work+Items
>> ·         Lists of HS for current standards can be used for new
>> Directives until new lists are published as per relevant article in the
>> directive such as article 27 of the 2014/35/EU LVD.
>> ·         So far I’m aware of:
>> o   LVD guidance on transition to new LVD,
>> http://ec.europa.eu/DocsRoom/documents/13141/attachments/1/translations/en/renditions/native
>>  available at
>> http://ec.europa.eu/growth/sectors/electrical-engineering/lvd-directive/index_en.htm
>> o   RED guidance is being worked on, but RED is not mandatory until 2017
>> so there is more time for this.
>> http://ec.europa.eu/DocsRoom/documents/11983/attachments/1/translations/en/renditions/pdf
>>  provides guidance on transitions for equipment moving into and out of
>> R&TTE/RED.
>> ·         No one is expecting anything.
>>
>> Regards
>> Charlie
>>
>> *Charlie Blackham*
>> *Sulis Consultants Ltd*
>> *Tel: +44 (0)7946 624317 <%2B44%20%280%297946%20624317>*
>> *LinkedIn: **uk.linkedin.com/in/charlieblackham/*
>> <http://uk.linkedin.com/in/charlieblackham/>
>> *Web: www.sulisconsultants.com <http://www.sulisconsultants.com/>*
>> Registered in England and Wales, number 05466247
>>
>>
>>
>> *From:* Ronald Pickard [mailto:ronald.pick...@compoundphotonics.com
>> <ronald.pick...@compoundphotonics.com>]
>> *Sent:* 29 March 2016 23:46
>> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
>> *Subject:* [PSES] EU's new approach directive transitions
>>
>> Hi to all, and especially to those that are knowledgeable of the EU’s
>> processes on this subject,
>>
>> I know that this subject has been discussed before without resolution,
>> but the time is nearing the end of the transition periods of the EU’s new
>> EMC, LV and RE directives and I (I’m guessing I’m not alone) was wondering
>> if anyone knows what the EU intends to do when these directives reach
>> beyond their respective transition periods with no listed harmonized
>> standards?
>>
>> - Will the directives’ transition dates be extended?
>> - Will a presumption of conformity continue to exist to the repealed
>> directives after the transition period?
>> - What is ETSI’s timeline to revise its harmonized standards to reflect
>> these new directives?
>> - Will harmonized standards under the current respective directives
>> continue to be utilized under the new directives (probable)?
>> - Is there any EU guidance that addresses the above questions? If so,
>> please provide a link(s).
>> - Will the EU pull a rabbit out of its hat at the last moment?
>>
>> Can anyone shed any light on this?
>>
>> I look forward to your reply.
>>
>> Best regards,
>>
>> *Ron Pickard*
>> Regulatory Compliance Engineer
>> *Compound Photonics*
>> D | +1 (602) 883-8039
>>
>> -
>> ----------------------------------------------------------------
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>
>
>

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