[PSES] inane EDN article

2013-04-26 Thread Brian Oconnell
There are too many 'What The Heck Were You Thinking' moments for such a
short article. Classic example of how NOT to test, then submit a relatively
hi-power piece of equipment to an NRTL/CSS.

http://www.edn.com/electronics-blogs/tales-from-the-cube/4412240/The-product
-that-made-me-downright-certifiable






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Re: [PSES] factories for marked cable

2013-04-26 Thread John Woodgate
In message <7878A08362FE46DCBD64C291ACE4BA2F@LENVOR61iJOHN>, dated Fri, 
26 Apr 2013, John Cotman  writes:



Something seems to have got lost along the way here:

The original question was not "who can grant the  mark?", but 
(paraphrased) "must the cable factory be in the EU?"


The answer to the factory question is "No", as millions of consumer 
products made outside the EU with  marked cable shows.  (and yes 
there is falsely marked cable too)


The original question was 'A cable supplier has mentioned that cables 
cannot bear the  marking if they are not manufactured within an EU 
country.  This seems to be buried in HAR agreement documents that are 
out of my reach.  Can anyone confirm this? '


Note 'Cannot bear the  marking'. I don't think anything much has 
been lost.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
They took me to a specialist burns unit - and made me learn 'To a haggis'.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] factories for marked cable

2013-04-26 Thread John Cotman
Something seems to have got lost along the way here:

The original question was not "who can grant the  mark?", but
(paraphrased) "must the cable factory be in the EU?"

The answer to the factory question is "No", as millions of consumer products
made outside the EU with  marked cable shows.  (and yes there is
falsely marked cable too)

John C.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 26 April 2013 09:06
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES]  factories for marked cable

In message 
<3f0347ac6ed9504191f91f07629fbb0c0155b...@thhsle14mbx2.hslive.net>, 
dated Fri, 26 Apr 2013, Charlie Blackham  
writes:

>
>Looking at the LVD guidance, (and of course it's "guidance" not "law") 
>http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , 
>page 28
>
> 
>
>Products  Scope of LVD     Examples of products    Comments
>
>Cables   Yes [picture of 
>cable] Marked with HAR to increase tractability

'tractability' - the quality of being easily managed

I suspect weasel wording here. The Commission has no business apparently 
elevating a private marking scheme to a requirement under a Directive. 
So using a confusing word may be a way to 'fog' the issue. Some people 
will assume it's a typo for 'traceability'.

Participation in the HAR scheme is *effectively* restricted to 
certification bodies (it's not a manufacturers' organization) in Europe 
because ENs and HDs must be in force in the country - from the HAR site:

QUOTE

Within the country of the applicant, the European ENs and HDs must have 
formally entered into force; any conflicting national standards must 
have been withdrawn. Assessment of capability and qualification of the 
candidate by a HAR assessment team, according to harmonised 
requirements; positive results to be formally endorsed by the HAR Group.

ENDQUOTE

This restriction must, in fact, bear some responsibility for the 
widespread presence of dangerous fake 'HAR' marked cables. I have a 
sample alleged to have 0.75 mm^2 conductors, which are barely 0.3 mm^2 
in fact, fitted with a fake British 13 A plug marked '10 A' but without 
a fuse.

The point is that if you use a test house and the cable isn't HAR 
marked, the test house may well want to test the cable to whichever of 
HD 21, HD 22, EN 50525, EN 50143, EN 50214, EN 60702 or EN 61138 
applies, and that is extremely costly.
-- 
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
They took me to a specialist burns unit - and made me learn 'To a haggis'.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] factories for marked cable

2013-04-26 Thread John Woodgate
In message 
<3f0347ac6ed9504191f91f07629fbb0c0155b...@thhsle14mbx2.hslive.net>, 
dated Fri, 26 Apr 2013, Charlie Blackham  
writes:




Looking at the LVD guidance, (and of course it's "guidance" not "law") 
http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , 
page 28


 

Products  Scope of LVD     Examples of products    Comments

Cables   Yes [picture of 
cable] Marked with HAR to increase tractability


'tractability' - the quality of being easily managed

I suspect weasel wording here. The Commission has no business apparently 
elevating a private marking scheme to a requirement under a Directive. 
So using a confusing word may be a way to 'fog' the issue. Some people 
will assume it's a typo for 'traceability'.


Participation in the HAR scheme is *effectively* restricted to 
certification bodies (it's not a manufacturers' organization) in Europe 
because ENs and HDs must be in force in the country - from the HAR site:


QUOTE

Within the country of the applicant, the European ENs and HDs must have 
formally entered into force; any conflicting national standards must 
have been withdrawn. Assessment of capability and qualification of the 
candidate by a HAR assessment team, according to harmonised 
requirements; positive results to be formally endorsed by the HAR Group.


ENDQUOTE

This restriction must, in fact, bear some responsibility for the 
widespread presence of dangerous fake 'HAR' marked cables. I have a 
sample alleged to have 0.75 mm^2 conductors, which are barely 0.3 mm^2 
in fact, fitted with a fake British 13 A plug marked '10 A' but without 
a fuse.


The point is that if you use a test house and the cable isn't HAR 
marked, the test house may well want to test the cable to whichever of 
HD 21, HD 22, EN 50525, EN 50143, EN 50214, EN 60702 or EN 61138 
applies, and that is extremely costly.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
They took me to a specialist burns unit - and made me learn 'To a haggis'.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] factories for marked cable

2013-04-26 Thread Charlie Blackham
Looking at the LVD guidance, (and of course it's "guidance" not "law") 
http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , page 28



Products  Scope of LVD Examples of productsComments

Cables   Yes [picture of cable] 
Marked with HAR to increase tractability



Regards

Charlie





-Original Message-
From: Cortland Richmond [mailto:k...@earthlink.net]
Sent: 26 April 2013 06:36
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES]  factories for marked cable



It looks very much as if this is a NGO, an association of firms who have 
trademarked a useful indicator of compliance, but one that is in no way 
required for entry to the EU marketplace



If it were to become a required mark, however, that could compare to the 
situation of some decades ago, when localities and States in the US sometimes 
required a "UL" (tm) mark on electrical equipment, thus restricting testing to 
that one firm's labs. This was eventually ruled an unlawful barrier to 
competition, and we now use the term Nationally Recognized Test Laboratory 
(NRTL) to describe all the recognized labs whose marks are acceptable.



I suspect a similar logic might then apply, were a non-EU cable manufacturer to 
find his product denied entry for lack of the "HAR" mark.



Could be wrong: I am not a lawyer.



Cortland Richmond





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