Re: ETSI standards vs NEBS

2000-10-08 Thread Victor L. Boersma
Just a minute here.  NEBs are requirements for Network Equipment
formulated by what was the Bell Operating Companies' research
arm Bellcore.  (They have now been cast adrift as Telecordia).

The Operating Companies have done a good job of making sure
that the requirements for their equipment were not regulated
and are in effect part of the commercial negotiations that take place
between the buyer and the seller.  If you're a big enough seller, you
can negotiate on these requirements.

Ciao,


Vic Boersma


RE: Using RTTE directive before April 2000?

1999-12-10 Thread Victor L. Boersma
Message text written by "Roger Magnuson"
> As you know, the current Directive took much too long
to implement in certain countries (no names...) and I guess this is the
reason for this unusal
approach.<

Roger,


the approach is not unusual under the terms of the Treaty of Maastricht
which no longer requires that the member states must transpose the
Directive before it is implemented.  That was one of the victories of that
Treaty (some will not see it that way).

The only thing unusual is that the R&TTE Directive is implemented, 
"POST MAASTRICHT", all the other ones so far were PRE MAASTRICHT.
This will be the norm in the future, in particular for the new EMC
Directive.


Ciao,


Vic


RE: internet information (worldwide electricity supplies)

1999-11-20 Thread Victor L. Boersma
I haven't checked the WEBsite (I avoid visiting WEBsites unless there is a
terrible need to know) so I don't know what exactly is there.  However,
quite
often, the useful information to have is what the permissable variations in
the Electrical supply are in various parts of the world.  At one time I had
such
a list for North America and it helped considerably in product design.  My
understanding is that with the privatization of the North Amercan
electricity
generation and distribution, the private sector operators are now
establishing
norms for how much deviation they will allow in the "DESIGN"
characterisitics
of a power generating and/or distribution entity, before they will let such
a 
[provider connect to their network.  (Supply contracts tend to have
terrible
penalty clauses for the power going down or off).

These norms overall, are not in the public domain because the operators of
all manner of networks have come to the realization that too much standard,

makes their facilities more vulnerable to cyber attacks.


Ciao,


Vic Boersma


RE: FCC Part 68 Testing in the UK

1999-11-20 Thread Victor L. Boersma
And than to think that all those people operating random number generators
are not even mentioned.


Ciao,


Vic


Part 68 Training

1999-11-11 Thread Victor L. Boersma
>>We have a new engineer learning Part 68/IC CS-03 that we would like to 
enroll in a seminar or training course.  Is anyone aware of any seminars or

training courses for Part 68/IC CS-03.

Best Regards,

Jody Leber

jle...@ustech-lab.com
http://www.ustech-lab.com

U. S. Technologies
3505 Francis Circle
Alpharetta, GA 30004

770.740.0717
Fax:  770.740.1508<<

Jody,

Every two years or so, TIA puts on a seminar where people are led through 
Part 68 and CS-03.  Last one was in February 1998 so perhaps it is that
time 
again.  Their price is right.

If not, I am prepared to put one on at a small price. 

Ciao,


Vic Boersma


Re: Production Line Test for -48 Vdc Equipment

1999-07-06 Thread Victor L. Boersma
I'd better start reading my UL1950/CSA950 again than.  They are supposed to
be identical documents
and CSA does not have to satisfy OSHA, hence, it must be in the
"deviations" for UL ???

Thanks and regards,


Vic


PS  Is it only me, or is everybody getting these messges two or three times
???   V




Re: Production Line Test for -48 Vdc Equipment

1999-07-06 Thread Victor L. Boersma
I'd better start reading my UL1950/CSA950 again than.  They are supposed to
be identical documents
and CSA does not have to satisfy OSHA, hence, it must be in the
"deviations" for UL ???

Thanks and regards,


Vic


PS  Is it only me, or is everybody getting these messges two or three times
???   V


RE: Billing tones...?

1999-06-30 Thread Victor L. Boersma
Message text written by INTERNET:t...@world.std.com
> A computer security device such as a logic circuit that could be
connected to the machine (i.e. via a printer port) which, when
interrogated, returns a unique logic code. <

Live and learn.  We're all grateful for this bit of new information.
My suspicious mind was trying to work back from the root of the
word and left in strange places.


Ciao,


Vic


RE: Korean approvals

1999-06-17 Thread Victor L. Boersma
Mirko,


this is all getting very muddy now that there is an APEC MRA on Telecom
requirements 
and an APEC MRA on Product Safety in the offing.  Combine that with Korea
in the throes
of changing over to a program that is more like the FCC program (before the
FCC launches 
a Notice of Inquiry on whether to do away with Part 68) and you can
conclude that things
are in a state of flux.


Ciao,


Vic 

Re: Network Equipment and UL 1459/1950

1999-03-29 Thread Victor L. Boersma
Message text written by INTERNET:t...@world.std.com
>I have to agree that there shouldn't be another US (UL) standard for
network
equipment when the equipment can be incorporated into UL1950. UL1950 can be
revised
to clarify the network equipment requirements, perhaps as a "deviation" or
an
"appendix" (annex), or just rewording the existing sections to make it
easier to
follow.<

The reason why we went the UL1950 route was to be able to join the IECEE
Schemes, where
it is a prerequisite that the nation use the governing IEC Publication with
a minimum of deviations.

We had a bit if a difficult time with the IEC and are supposed to show how
we are "DECREASING" the number of deviations, not increasing them.  We had
a difficult time to convince the data processing industry to embrace
customer premises equipment.  We never could get an international agreement
to incorporate Central Office equipment.

I may be mistaken, but I do not believe that we will get support from the
main stakeholders in UL1950,
to increase the number of deviations to accomodate Central Office
equipment.  Therefore, incorporating such requirements in a UL1459/CSA 225
product makes most sense.

Even if we could get  support in North America to propose modifications to
IEC 60950 to accomodate CO equipment, we are talking about a process that
will take years.  I am afraid I start sounding like all
the other would-be historians  in making these comments and my white hair
and arthritic knees don't help the image.  Nevertheless, a bit of history
helps in understanding some of these things.


Regards,


Vic Boersma 

Re: Network Equipment and UL 1459/1950

1999-03-25 Thread Victor L. Boersma
Message text written by INTERNET:t...@world.std.com
>In my view, these exemptions are specifically targeted at equipment such
as
PBXs and network equipment that are typically installed by service
personnel
and include hardwired grounding.<

When Telecom equipment (of the non-network equipment variety) was included
under IEC 950
it was a hard sell to the Data Processing equipment manufacturers, who did
not want to see their
Data Processing equipment standard polluted by telecom considerations.  In
addition, the
telecom reps where not really PBX experts of any sort (with one exception).
 Therefore, in trying
to interpret IEC  60950, one cannot assume that PBX and network equipment
was targetted. 
There was a basic assumption that if the Mainframe computer and router
equipment manufacturers
could do it, than the telecom equipment manufacturers ought to be able to
do it, over time.

On another note, a lot of these type of requirements come from so-called,
horizontal standards developed by other experts who have no knowledge of
either Information or Communications technology practices.  If you want to
change these "horizontal" standards, you have to join that crowd for years
till they have confidence in you, and than you might be able to change some
of those things.  
By and large, one cannot get money for that sort of a campaign in the ICT
industry.  Therefore, you
have to live with it.  When we started the campaign for IEC950, CO voltages
and currents were considered dangerous and one would have had to run
telecom installations in conduit.  We've come
a long way.


Ciao,


Vic


FCC Deregulation of Equipment Certification

1998-12-28 Thread Victor L. Boersma
Message text written by INTERNET:t...@world.std.com


>On December 17 FCC took another big step towards getting itself out of the
telecommunications equipment approval business, in order to allocate
resources to enforcement of its regulations.  Docket 98-68 covers both
wired and wireless telecom equipment de-regulation issues, an Adobe Acrobat
file version of the docket is at

http://www.fcc.gov/Bureaus/Engineering_Technology/Orders/1998/fcc98338.pdf

Text and Wordperfect versions also available on FCC's home page in the
Headlines section.


Tom, thank you very much for sharing this with us.  You are correct from
the perspective
of what this means to Industry and Certification houses.  However, you have
not grasped
the essence of the decision.  The FCC REMAINS the Approval Authority.  The
TCBs only
certify that the equipment meets the requirements.  So, the FCC is getting
out of some
of parts of the approval business, but not all parts.  Given that in the
past one civil servant
reviewed the applications for registration no matter who submitted them,
and had a sixth
sense for what was fishy, anything that requires more people and accredited
laboratories 
and certification organizations WILL HAVE TO COST MORE and will probably
not be as
responsive, efficient and cost-effective.  COMPARE THIS WITH THE MARK OF A
NRTL,
THE NRTL NEVER EVER SAY THEY APPROVE THE EQUIPMENT, THEY SAY THAT THE
EQUIPMENT MEETS THE REQUIREMENTS OF SOME PARTICULAR STANDARD(S).
THYE "LIST" THE EQUIPMENT ON A LIST OF EQUIPMENT THAT HAS PASSED THE TESTS.
IF YOU READ THE FINE PRINT YOU FIND OUT THAT THE AUTHORITY HAVING
JURISDICTION
IS THE ONLY ONE WHO CAN APPROVE, AND DOES SO ON THE STRENGTH OF THE
MARK OF A NRTL.  PART 68 EQUIPMENT NEVER WAS APPROVED.  IT WAS REGISTERED. 

This action amends parts 0,2,15,25, and 68 of the rules to give
manufacturers the option of obtaining equipment CERTIFICATION from private
entities for equipment requiring approval from the FCC.
Telecommunication Certification Bodies, or TCBs, will be established "to
function much like the Commission by certifying a product based on the test
results of one representative sample."
THE COMMISSION DID NOT DO MUCH CERTIFYING IN THE PAST.   THEY REGISTERED.

TCBs must "have the technical expertise and capability to test the
equipment it will certify", although a TCB can accept manufacturer's data
or data from subcontractors - the TCB will be responsible for subcontractor
results.

The Docket also adopts rule changes to implement Mutual Recognition
Agreements (MRAs) for product approvals with the European Community (EC),
THE CHANGE IN THE RULES WAS INSTIGATED BY THE MRAs.  IT IS NOT
PROBABLE THAT THE RULES WOULD HAVE BEEN CHANGED AS THEY 
ARE, IF IT WEREN'T FOR THE MRAs. 
the Asia Pacific Economic Cooperative (APEC), and others.  TCBs will be
private entities in the US, designated entities in other countries.

WHETHER THE ENTITY IS PRIVATE OR PUBLIC HAS NOTHING TO DO WITH DESIGNATION.
THE US DESIGNATES QUALIFIED LABORATORIES TO THE EUROPEAN COMMUNITY.  THE
EUROPEAN COMMUNITY DESIGNATES QUALIFED LABORATORIES TO THE US.
THE US DESIGNATING AUTHORITY MUST ASSURE ITSELF THAT THE LABORATORIES THEY
DESIGNATE ARE CAPABLE OF DOING THE JOB.  BECAUSE THEY CANNOT TREAT FOREIGN
BODIES DIFFERENT THAN NATIONAL BODIES, THEY HAD TO INSTITUTE THIS
ACCREDITATION BUSINESS, OR MAKE IT A FREE-FOR-ALL.  THEY CHOSE THE
ACCREDITATION CHURCH, WHICH WILL DRIVE THE PRICE OF TELECOM PRODUCTS IN
NORTH AMERICA UP FOR THE CONSUMERS.  (I AM NOT ARGUING THAT THEY SHOULD
HAVE GONE THE FREE-FOR-ALL ROUTE.  I AM MERELY STATING THAT WE WENT FROM A
SIMPLE AND INEXPENSIVE APPROVALS ROUTE TO A MORE COMPLEX AND COSTLY ROUTE,
IN THE HOPE AND EXPECTATION THAT WE WILL GAIN FROM THE INCREASE IN
BUSINESS.) 

TCBs will be accredited to ISO/IEC Guide 65 and ISO/IEC Guide 25.  NIST
will be
responsible for accrediting TCBs, FCC will DESIGNATE QUALIFIYING TCBs TO
THE EUROPEAN UNION.  SUCH DESIGNATIONS WILL BE ANNOUNCED via
Public Notice.  (NOTE: THE EU HAS THE RIGHT TO QUESTION US DESIGNATIONS,
THE US HAS THE RIGHT TO QUESTION EU DESIGNATIONS.  BEING DESIGNATED DOES
NOT "NECCESSARILY" MEAN YOU'RE IN.  I HAVEN'T CAREFULLY READ THE FCC
DOCUMENT, SO I AM NOT SURE THAT THE FCC NEEDS TO DESIGNATE LABS FROM THE
US, FOR THE US.  I WOULD EXPECT THAT THE FCC WILL PROVIDE A PUBLIC NOTICE
ON WHAT FOREIGN DESIGNATIONS IT DID ACCEPT).

Once TCBs have been established, FCC will no longer process or issue
certifications for pc's and pc peripherals (new para 15.101)

There has been no limit put on the number of TCBs that will be accepted.

TCBs will be able to perform all the equipment CERTIFICATION functions
currently performed by FCC, with the following caveats and exceptions:

- TCBs are not to impose their own requirements and conform test and
certification procedures with FCC rules and requirements

- TCBs will not be permitted to waive rules.  Waivers and new or novel rule
applications or interpretations will be done by FCC

- Grantees 

Blowing steam

1997-05-16 Thread Victor L. Boersma
Anybody willing to help Peter 


-- Forwarded Message --

From:   "AIKAT Peter -EAS", INTERNET:peter.b.ai...@extott14.x400.gc.ca
TO: Vic Boersma, 102126,156
DATE:   15/05/97 20:08

RE: Blowing steam

Excerpt from Pressure Vessels chat group:

=
 With wet (50 psig, 99% quality) steam flowing at about 100 feet per 
 second in a pipeline, what micron size droplet distribution might be 
 expected? This information is needed to specify mist eliminator 
 performance, and we do not want to specify more equipment than is 
 necessary. Information on droplet size distributions in a blowdown 
 flash tank would also be of interest.
=


Re: TREG or EMC-PSTC

1997-04-11 Thread Victor L. Boersma
Tom,


for me, you are asking the wrong questions, but than that is for me.

I am interested only in "general" regulatory and compliance issues, which is a
field
of its own in our global community.  I don't have time to read all the good
stuff from
the techies on how they diddle modems to pass the UK requirements.

I'm not saying that is not good and worthwhile stuff, but if you're trying to
track the 
global regulations for Information and Communications Technology equipment, than
these details become chaff in the wind.  You don't have time for it.

I found that the EMC-PS forum had too much technical detail and not enough
information
to make it worth my while.  I'm getting to a point where I start questioning the
value of
the TREG, if the trend for going down technical ratholes continues.

Once again, I'm not saying that the technical stuff is not valuable, to the
contrary, in the
days that I had to get approvals for stuff, that would have been an invaluable
source.

It is just that the, what I call "electro-political" part of this business has
grown to a size
that does notpermit sidetracking on finer technical points any longer.

Hence your questionaire poses a problem for me.  I am interested in the general
aspects
of all the fields you mention, BUT NOT FROM A TECHNICAL PERSPECTIVE.

Thanks anyway for giving us an opportunity to express our thoughts on this.


Vic  Boersma

"WE NEVER ADMITTED BEING IGNORANT IN THE FIELDS WE WORKED"

For a copy of our rates please hang on to your seat.   


Re: Proposed changes to UL 1950 3rd Edition

1997-03-04 Thread Victor L. Boersma
As a founding member of the bi-national committee, I have objected to ANY and
ALL deviations from IEC-950 in the BiNet.  Obviously, not very succesfully.  I
believe that  
if I still were a member of that illustrious group, I would object to there
being a national committee in any country that thinks up deviations to IEC 950.

The job of national committees ought to be the preparation of inputs into TC74,
and inside,
the removal of existing deviations in the national code (and fix the CEC and
NAC, while at it).

The notion that a good citizen in Preoria Ill needs to go to Geneva to change
the national
requirements, does not sit very well with many.  However, that is the only way
we're going
to bring sanity to this global market place.

There will be a good deal of pain in that procedure, but the only pragmatic way
to deal with
the problem is to go through the pain.  In the mean time, if you have a customer
who only
buys equipment with gold-plated bases, you will do the plating, if he has the
money.

Happy not to contribute to any controversy.


Vic


Re: Re[2]: Proposed changes to UL 1950 3rd Edition

1997-03-02 Thread Victor L. Boersma
My comments are the rock in the big pond.  YES.

However, just back from INTER COMM 97.  

Anybody who thinks that in three years from now, when PCS is taking hold, when
CATV companies offer dial tone and telcos are offering TV, we will be operating
the old T1 pipe infrastructure, is ready for a rude awakening.

We are in for a VERY competitive ICT (Information and Communications
Technologies)
business period, that will involve a restructuring of our infrastructures.  You
won't even be
able to sell the equipment as second hand equipment to developing countries.
They'll be
leapfrogging those technologies.

IEC-950 and its derivatives (EN 60 950, UL 1950, CSA 950) will probably have to
change as
well.  They were never intended for the technologies we are inventing as we go.

Aren't I lucky that I am part of an interesting world in my dotage.

Ciao,


Vic


Buy stock in equipment and software providers.  Sell stock in competing service
providers
you don't believe will make it.  VB


Re: Proposed changes to UL 1950 3rd Edition

1997-03-01 Thread Victor L. Boersma
Poor idea.  We no longer design ICT equipment for anyone geographic location on
the 
globe.  The equipment has to be "GLOBALLY" IEC-950 compliant.   Most of the
equipment you mention does not have a product life that exceeds three years.  By
that time, newer technology equipment takes over.  Hence, there should not be
any problem having compliant equipment
available and in place by the time UL1950/CSA950 kick in and you should be able
to peddle
such equipment world-wide.

Ciao,


Vic  Boersma


Re: LVD and 48VDC equipment

1997-02-12 Thread Victor L. Boersma
Grant,

Does it matter ?
You do not have to follow ANY standard to do your Declaration of Conformity.
You may
just claim that you meet the essential requirements of any applicable
Directive(s) and go
to town, smearing CE-marking all over the place.

It would seem prudent that before you start the marking exercizes, you do some
checking 
on what your gadget does or does not support, and stick this valuable
information in a product file, WHICH you tender for inspection, if you get
challenged on your declarations.

The question now is, when you do the "some checking" what do you check to ???

Regardless of whether I think it applies, given the penalties for getting caught
short, I would make sure I comply with EN 60950, or have damn good reasons for
not doing that.
I prefer the provisions of the LVD to the provisions of the Liability Directive.


Sjuut,


Vic  Boersma


Re: IEC-950 4th Amendment

1996-10-21 Thread Victor L. Boersma
Just received notice that Amendment 4 to IEC Publication 950 was published in
August 1996.

It was prepared by IEC TC 74 which prepares requirements for the safety and
energy efficiency of information technology equipment, including electrical
business and telecommunications equipment.   Price is 219.00 Swiss francs.

For more info contact Mr. Nelson at:

Tel:  +41 22 919 0228
Fax: +41 22 919 0300

Internet:d...@iec.ch



Ciao,



Vic  Boersma


Re: ONE Safety Standard

1996-09-30 Thread Victor L. Boersma
While the rollers on washing machines (how old are you Manny ?) and Printing
presses may
be the same, they are worked somewhat different by different types of people (or
were anyway) under different types of circumstances.  Therefore, a one size fits
all approach,
might result in disasters.

However, I don't believe that with the exponential explosion of different
technologies, we can
continue to produce "specific" requirements as new inventions come along, in a
timely manner.  The standards will be outdated before they can be written.
Either the standards become irrelevant because they are not adhered to, or they
will inhibit innnovation.

The EU approach, to produce directives that provide the "essential" requirements
and assume
compliance with those essential requirements where conformity to harmonised
standards is claimed, to me appears imminently sensible.  It provides the best
of all worlds, a method to
determine safety where there is no standard (yet) and a method to do so
efficiently, where
there is a harmonized standard.  It might even help convince committee members
that have
a penchant for going down ratholes, trying to reach agreement on harmonised
documents. 


Ciao,



Vic  Boersma


Re: Certification of Product Safety Personnel

1996-08-27 Thread Victor L. Boersma
When I left the Netherlands many years ago, they certified 
EVERYBODY.  Our milkman had to go to school for 4 years, so he
could answer questions about the milkfat content of anyone of 
his products.  (He also was expert on how to care for the big 
working dog, that helped him pull the milk cart). 

Did that get us better milk ???

Did that get us the milk faster ???

Did that get us cheaper milk 

You'all know the answer to those questions.


The problem with "GOOD" compliance engineers is even more vexing.

If your organization never have any compliance problems and never 
hears from the son/daughter of a gun, you've got yourself a VERY 
good one.  That may not show as such in his/her personnel files.  
Create a compliance crisis twice a year to which you have the 
solution, and you'll be a hero.

The answer to good management does not lie in training and education,
although that will help.  The answer lies in good managers, and they
are born, not made.  Same goes for CEOs and members of the Board.

Don't try and pass on the reponsibility for picking the right person
for the job, to some auditing agency.  The good manager will pick
the right personnel.  The poor manager will rely on all sorts of
aids to compensate for his/her incompetence and wind up with the
duds.

Now as we get to "good consultants" some feel there is a 
contradiction in terms here, but once again, they, like suckers,
are born, not made.


Ciao,



Vic  Boersma


Re: NAFTA and HS

1996-08-23 Thread Victor L. Boersma
Under separate cover a report from the last TSSC meeting (TSSC= the
Telecommunications Standards Subcommittee).  The report refers to
the CCT, which is the Consultative Committee Telecommunications.

The CCT is a trinational private sector organization, trying to
implement the provision of chapter 13 of the NAFTA.

If there is a NAFTA certificate, it has nothing to do with equipment
approval.  I have no idea  what an HS is.  All this in spite of
having been involved with the CCT from before the time the US signed
off on the NAFTA.

Current chair of the CCT is Chuck Berestecky of Lucent Technologies.


Regards,



Vic  Boersma


Re: CE Approval

1996-08-07 Thread Victor L. Boersma
There is no such a thing as CE Approval.  There is a thing called CE Marking.

CE Marking signifies that the party that affixes the mark, claims that the
product was put
through the applicable conformity assessment processes and meets the essential
requirements of the applicable "New Approach" Directives.

If the product meets the requirements of an applicable harmonized standard for
that product,
compliance with the essential requirements is assumed.

That does not answer the questions that were behind the question,

Do I need to apply the CE Marking ?

I believe the answer is yes.

Having VDE and TuV certification for these fuses, can I assume that I meet the
essential requirements ?

The answer probably is yes.   However, my knowledge of the applicable Directives
for
fuses and their standards, harmonized or non-harmonized is limited.  


Regards,


Vic  Boersma 


Re: TCADD

1996-07-26 Thread Victor L. Boersma
You need to do some mouth rinsing.

At one time it was the CE Mark.  However, fundamentalists in the
EU Parliament objected to that terminology because it was
reminiscent of the "mark of the beast".  Hence, it was changed
to "CE-marking".  

CE-Stamp, my Lord 


Vic  Boersma



To join this club, you have to send a message to the EMC-PSTC
address shown above, believe it is  and
say "subscribe".  You than will receive all sorts of information
that you can sort.





Re: What is EN-41003?

1996-07-26 Thread Victor L. Boersma
Don't think so Roger.

IEC 950 = EN 60 950, was meant for Information Technology Equipment, including 
Electrical Business Equipment.

EN 41 003 has a checkered history, but was mainly intended to provide additional
requirements for any type of equipment that connects to a Telecom network.  That
could be
Informatlon technology equipment or a coffeepot that is started via a telephone
line.

Indeed, EN 41 003 is pretty much Clause 6 of IEC 950, so far.

The scientists have now put much of the content of Clause 6 of IEC 950,
throughout the
body of that Publication, so that it is no longer immediately obvious that
something is or
is not Telecom related by virtue of it being in Clause 6.

UL 1459 is definitely NOT included in UL-1950.  UL-1459 was the first UL try to
create
a Telecom equipment standard, based on UL-114.  This was going on at about the
same time that CSA was involved in a similar endeavour, first C22.2 No. 0.7 and
later
C22.2 No. 225.

There was a bit of an effort to keep UL-1459 and CSA 225 more or less
compatible, till
it struck the membership as ludricous to keep this construct, while the rest of
the world was
moving to IEC-950 for these converging technologies.

Hence, the BiNat Task Force created the BiNat or Binational standard, issued by
both
UL and CSA as UL-1950 and CSA C22.2 No. 950, identical.  The price is comparable
and you'll have to decide on what logo has more appeal when you go out to buy a
copy.

The BiNat is also BiCult in that it not only covers two nations, the US and
Canada, it also
covers two cultures, Information Technology and Telecommunications Technology.
The document is based on IEC-950 with a number of deviations imposed by the
National
Electrical Codes of the USA and Canada and the much reviled "overvoltage"
requirements
which try to account for the fact that in much of North America, electricity and
telephone
service is brought to the residence via "pole lines", where the telephone cable
runs on the
same Poles as the Electrical wiring, giving rise to a certain amount of
induction as well as
the possibility of high power getting on to the telephone cable in cases where
the electrical wire breaks and falls onto the telephone cable.

Regards,


Vic



PS  Ringing voltage is not 48 Volts



Re: TTE Directive as it applies to VSATs

1996-07-17 Thread Victor L. Boersma
You should have come to the seminar we gave last week in Toronto and San Jose as
it was stimulated by the proposed new CTE (Connected Telecommunications
Equipment)
Directive.  The proposal is still being worked and if there is a draft text, it
is not out yet.

However, one of the facets of the new proposal is to do away with all "a-priori"
testing and
rely on "a-posteriori" surveillance, for all telecom terminal equipment.  It is
going to be a couple
of years before you see it.  By that time, if you get a-posteriori" surveilled,
you'd better
have your act together because any equipment that fails to meet the essential
requirements
of the new Directive (NOT ETSI Standards) will be found "defective" and subject
to the full
force of the Product Liability Directive with fines up to 70 M ecus.

Ciao,


Vic


RE: Mexican Product Safety (NOM)

1996-07-16 Thread Victor L. Boersma
For Information Technology Equipment and Telecommunications 
Equipment, the responsible standards organization in Mexico is 
NYCE (Normalizacion y Certificacion Electronica).

The VP in charge of Certification is Victor-Hugo Perez-Salinas,
the operating manager is Julio Nunez.  Victor-Hugo is ex-Motorola,
Julio is ex Alcatel.  Both speak fluent English.  They can be reached
at:

011-525-687-3932, 687-3852, 536-3378, 543-3639, 536-3408 or
fax at 543-4070.

The Mexican high-tech industry would like to switch to IEC-950 and
Mexican representatives now participate in the work of IEC TC74.
However, under Mexican law, if they switch to IEC-950, that is the
only standard they can use.  That would play havoc with Mexican 
pencil sharpener manufacturers, etc., etc.  Hence they are looking
for a way to accomodate that concern.

In addition, Mexico, and many other 3rd world countries, do not 
have an infrastructure that allows them to have many laboratories 
that are equipped to measure to high-tech standards.  They can not
promolgate standards that no Mexican laboratory can test to.  Hence,
they will have to earn the money to pay for that expertise, in their 
country, by any and all means.  It is unacceptable that stuff would
be tested by foreign laboratories to Mexican requirements, because
Mexico can't do it.

I estimate that they will need about $ 300 M in regulatory revenue
on high tech equipment, to do that.  We are going to pay that money,
one way or the other.   (SWAG=Scientific Wild Arsed Guess).

Ciao,


Vic 


Re: Why 42.4Vac/60Vdc - or 250V

1996-07-15 Thread Victor L. Boersma
This whole debate points to a lack in the standards development
world that I have lamented for many years (and done something
about whenever I could).

THERE IS NO RATIONALE STATEMENT WITH THE REQUIREMENTS 

Time and again, one butts up against a wall, when one wants to change
something, that goes somewhat like, Well those folks must have known
what they were doing, and I don't want to change it unless I know
why it was so in the first place.

Those folks probably did have a rationale, but not necessarily a
good one, and not necessarily one that is still valid today.  Unless
the standard tells me what the rationale was, what it was that they
were trying to protect against, I must assume, as a catalyst for 
change, that it is probably invalid today.  Hence,

EVERY REQUIREMENT IN A STANDARD OR TECHNICAL REGULATION, MUST HAVE
A RATIONALE STATEMENT, OR THE REQUIREMENT SHALL BE DEEMED OUTDATED.

Ciao,


Vic


CLC/BTWG 74-3(SG)40

1996-07-15 Thread Victor L. Boersma
At the EU seminar we were provided with copies of a new CENELEC
document "Information on the Links Between Products, Directives
and Standards in the Electrotechnical Field."

The document comes in 3 parts
Part 1, in golden rod, Directive - Product - Standard
Part 2, in green,  Standard - Product - Directive
Part 3, in yellow, Product - Standard - Directive

It is almost .5 inch of paper, printed on both sides, so don't ask
me to copy it for you.  Try and get a copy from Mrs. A. Colman
at the Central Secretariat of CENELEC, Rue de Stassart 35, B-1050, 
Brussels in Belgium.

Document Number  CLC/BTWG 74-3(SG)40


Regards,


Vic


Re: Documentation Legal rqmts

1996-07-15 Thread Victor L. Boersma
EU authorities prefer if the file is held by a European entity, but
donot insist on that.  However, there appears to be an unwritten law
that expects you to be able to produce the darn thing with 24 hour
notice.  There is genberal unhappiness with the fact that some 
manufacturers don't seem to be able to do that, for silly reasons
such as bankruptcy and such.  Hence the proposed new CTE wants all
files held by a competent body, which is not allowed to look at the 
darn thing, just hold it.  Even the most liberal of the competent
bodies object to becoming a filing cabinet, so we'll see what happens.


Regards,


Vic


Re: re:Mexican Product Safety (NOM)

1996-07-15 Thread Victor L. Boersma
Ed,


I believe that is about as clear as you can get for the moment.

People should realize that all this work with the EU, APEC, NAFTA
etcetera makes sense only if you forget about electrical safety, 
or EMC or Conformity Assessment, but start regarding it in the light
of how many trade dollars in Pharmaceuticals  will we gain, if we
give a bit of electrical safety that isn't needed.

This is a serious game, that has very little to do with the 
technologies that surround it.  It will effect the way you do business
more and more.  Witness the FCC decision to introduce laboratory
accreditation and an "FCC mark" to give the DoC something to trade on.


Regards,


Vic



NB:  Ed, I haven't seen your CCT report yet ??   VB


Above and Below

1996-07-10 Thread Victor L. Boersma
Interesting question came up at the EU seminar yesterday in Toronto,
where nobody really was able to give a definitive answer.

Questions comes in an EU related version and in a general version.

What are the regulatory requirements for a device that has a 
"rated voltage" below the limits of the LVD, but has inside
voltages that are:
(a) within the scope of the LVD
(b) higher than the scope of the LVD

What are the requirements for a device that has a "rated voltage"
below the limits of IEC-950, bust has inside voltages that are:
(a) within the scope of IEC-950
(b) higher than the scope of IEC-950

We all knew the common-sense answer, but common sense is nothing
than the sum total of what you've learned before age 18 (I believe).

Off for San Jose now.  Tata


Vic Boersma  


Re: emc immunity

1996-06-29 Thread Victor L. Boersma
All I can say is HEAR ! HEAR !

(and that in spite of my carefully cultivated gut-feel)

Vic  Boersma


Re: Australian Requirements

1996-06-23 Thread Victor L. Boersma
I believe there is a confusion factor creeping into this debate.

Neither AUSTEL, OFTEL in the UK, the FCC in the US or Industry Canada
have any business accepting IECEE CB certificates.  IECEE CB 
certificates pertain only to Electrical Safety.  The agreement to 
accept such certificates is between participating "PRIVATE SECTOR"
organizations.

BSI, VDE, UL, ETL, CSA and such organizations are members of the
scheme and are expected to accept certificates from other members, 
and allow the manufacturer to affix the mark of the national 
organization in the receiving country.  For example, upon receipt
of a certificate from UL, that the equipment has passed all
applicable requirements with respect to Electrical Safety in Germany,
VDE will allow an American manufacturer to affix the VDE mark to
such equipment (provided the proper follow-up procedures are in place
etc., etc.)

The appropriate German Telecom authorities have nothing to do with
how the American manufacturer obtained the right to affix the VDE
mark, they only note that the equipment does carry that mark with
the permission of VDE.

In many countries, telecom equipment will not be approved to the
telecom requirements, UNLESS, it has first been approved w.r.t.
electrical safety and EMC.  The IECEE CB scheme, so far, can only
be used for the electrical safety part.

Regards,


Vic


Re: Australian Requirements

1996-06-13 Thread Victor L. Boersma
The IECEE CB scheme is very much alive and well and more countries
are joining every year.  The scheme recently has been expanded to
include not only a CB scheme, but as well, an EX and a FC scheme.

Not all that familiar with the EX scheme as that is intended for 
equipment used in explosive atmospheres (which I try to avoid), but
the IECEE FCS (Full Certification Scheme) will start up very soon.

To the best of my knowledge, the "biggies" such as UL and CSA have
all qualified for that scheme.  There is a meeting this week in
Geneva of the IECEE management committee where some new accomodations
are being debated.  If you want to know the latest and the best,
sign up for one of the Seminars (Toronto or San Jose)  in the first
week of July, where Joe Gryn will have session on that very topic.


Regards,


Vic  Boersma  


Re: EMC severity levels: an update

1996-06-05 Thread Victor L. Boersma
Large Corporations indeed do have their "in-house" standards, so do any number
of
small corporations.

Those standards are the result of years of study on failed products, an
investment that often
is far from trivial.

Those standards are what gives those corporations their competitive edge in the
market place
and makes some brands a "household name", because of their reliability.
Obviously, those
corporations know that the standards aren't enough AND, what is enough.

Any employee of any corporation that has made that investment and tells this
forum how to
compete with his organization, should not expect a raise.


Regards,


Vic



Re: New Canadian Marking Requirement?

1996-06-03 Thread Victor L. Boersma
Ken's description is accurate.  Industry Canada previously accepted FCC
registration as
proof of compliance with canadian requirements and than discovered that a
violation of
the FCC requirments did not form a basis for enforcing canadian rules.  Hence
the need 
to have this statement about compliance with Canadian rules.

Unfortunately, the industry missed this event and were all of a sudden faced
with this change.  ITAC (the Information Technology Association of Canada)
arranged for a meeting with Garth and his boss and they agreed on not enforcing
the rule for some period, so we could ease in.

There you have it.  We are still trying the powers that be to agree on a common
mark between
the NAFTA countries and worldwide that says "CISPR22" and that is a DOC to the
effect that
you meet those requirements.

Regards,


Vic   



Re: Pack of CE Marks?

1996-05-31 Thread Victor L. Boersma
I don't know from what perspective you are asking the question, BUT, in the
final analysis,
the only things that count (assuming that the product is covered under one or
more of the
"New Approach Directives" is:

Was the product subjected to the Conformity Assessment procedures prescribed in
the
applicable Directives

AND

Does the product meet the "essential requirements" of the applicable Directives


Unless you can answer  YES  to both questions, you are in violation of the law.


Regards,


Vic  Boersma  



Re: Ethernet Compliance

1996-05-29 Thread Victor L. Boersma
You're asking an unaswerable question, in my opinion.

(1) Many buildings are prewired and can't handle any more wire, you've got to
make do with
what is there, or make rewiring part of the contract.  You're not likely going
to be the lowest bidder on the job, if you do.

(2) If the people who do the wiring know what they are doing, you can have very
good results
using either coax or CAT 5.  If the people doing the wiring don't know what they
are doing,
they are likely going to make a mess out of either.  Believe me, I have seen
people making
a horrible mess out of either.

(3) You have not mentionned running fiber 

(4) You have not mentionned doing a wireless distribution 

I suggest you take a building distribution specialist group on to discuss this
further.  I have
included a number of my friends of that persuasion in the distribution.


Regards,


Vic  Boersma



Re: FWD>RE>FW- Electrical Safet

1996-05-24 Thread Victor L. Boersma
Lordy - Lordy

(Since when does the opinion of compliance engineers carry any weight with the
Authorities Having Jurisdiction (AHJ) ?) 

OSHA regulates federally controlled enterprises.  Electrical equipment needs to
be listed/certified by a Nationally Recognized Test Laboratory.  The NRTL DOES
NOT APPROVE the equipment, it merely attests to the fact that the equipment has
been tested to certain requirements and if the equipment passes those tests,
allows its logo to be affixed to the equipment.  The actual approval of the
equipment is done by OSHA.  OSHA does not really
inspect and approve the equipment, its inspectors look to see whether the
equipment carries
the marking of a NRTL and presume compliance of such equipment.

Other AHJs such as municipalities, counties, states etc. operate under their own
rules.  Some
recognize the NEC, some recognize only part of the NEC and certification/listing
organizations must seek recognition of their marking individually in each
jurisdiction.  Believe me, that is not a trivial undertaking.  However, there is
nothing that says that you have to be a NRTL to be recognized by an AHJ.
Ofcourse it does not hinder, if you are.

To recapitulate, the NEC in the USA and the CEC in Canada, are voluntary
standards,
 invoked and made mandatory by local authorities, as they see fit.  (Many AHJs
have not
updated their statutes and under law, are bound by older vintages of the NEC or
CEC).

Certification and Listing organizations DO NOT APPROVE equipment.  That is the
prerogative of the Authorities Having Jurisdiction.  Normally, if the local
inspector notes
the marking of a recognized Listing or Certification organization on a product,
he/she stops
the investigation right there and assumes that the product meets the applicable
requirements
and therefore approves the installation.  (Installation may mean, plugging the
thing into a
socket).

Most every appliance I know off. goes on the fritz some day and gets repaired.
Unless the
repair is done by an authorized agent of the manufacturer, your warranty, your
listing, and the mfrs.responsibility go out of the window as soon as the
equipment is opened up.  Many, many
appliances get repaired by unauthorized technicians and are technically no
longer the piece 
of equipment that was tested and certified as being compliant.  I would not be
surprised if a study were to show that at least 30% of the electrical appliances
on this continent are technically out of compliance with their listing
requirements.  We've learned to live with that
and to my knowledge, this has not led to the streets of this great nation being
littered with
electrocuted corpses. Hence, nobody took action.

The gentleman from Goodwill has more of a liability problem that a technical
problem.

Regards,


Vic  Boersma



Re: European Power cords

1996-05-23 Thread Victor L. Boersma
In response to Nick Rouse's comments:

I stand to be corrected.  Indeed, Member States may thwart the intent of the
Directives
by doing weird and wonderful things when they transpose/approximate.  At times
their
reasons me not be the purest, but in the UK case, it is clear to the rest of the
world that
a good plug has a fuse. 

I believe that every principality has something or other that says that you
should use plugs in that country that fit the sockets they are likely going to
be plugged in to.  The issue in that case is that an ill-fiting plug may cause
heating, fire and other unpleasant things.

The question now is, if you supply the customer with a box that has a cord and
plug that may
not fit the local sockets PLUS a cord and plug that WILL fit the local sockets,
will that cause
enough confusion to lead to unpleasant events.

Remember, you meet the letter of the local law that says that you shall provide
the proper
plug.  The issue is whether the improper plug, also included in the package,
will be
considered likely to cause problems.  My take is that this may well vary from
country to
country.  The worst case is if the plug "almost" fits and people who can not
read the instructions are going to try.

Given the complexities of all the possible combinations, I change my tune and
now believe that
probably you should not be allowed to give the customer a choice of cords in the
box, because
it may well be a violation of the LVD essential requirements.

Regards,


Vic  Boersma


Vic  



Conformity Assessment of Integrated products

1996-05-21 Thread Victor L. Boersma
There has been a spate of comments on this channel lately about the problems
encountered
when a product is an integration of several other products.

Doug Probstfeld of INTEL in Hillsboro, OR, has produced a white paper on the
topic and makes some recommendations on how to deal with it.

Not everybody may agree with Doug's approach, but I think it is a good start.

(I don't like the use of the word "modules" in Doug's paper, as it confuses the
EU
Conformity Assessment modules, with components used in an integrated product,
in the reader's minds.)

In the paper he goes into each of the problem areas in great detail and attaches
a copy of
the Notice of Proposed Rulemaking by the FCC to deal with the EMC aspects in the
USA,
under Part 15 of the FCC Rules and Regs.

The FCC also has put in place a mechanism to deal with the telecom aspects of
integrated
packages, under Part 68 of the FCC Rules and Regs.  Greg Slingerland of MITEL
was
instrumental in getting that one off the ground.

UL has a special Task Force looking at the Electrical Safety aspects of the
"plug and play"
scenario.  (Believe that INTEL and MITEL are on that Task Force).

The telecom industry has always lived with this problem, as it  always was
composed of bits and pieces from different manufacturers, assembled in the
field.  There never was a
complete PBX in one place, to be certified.  We're now doing that with computer
systems with servers from one manufacturer and controllers from another
manufacturer to printers and terminals of yet other manufacturers, on a large
scale.

On the small scale, we're buying keyboards, mouses, monitors, motherboards,
printers,
power supplies and all manner of cards to go into the tower of our choice, to
make our
PC system.  When we upgrade to a faster modem, a larger monitor screen a more
powerful this and a faster that, we don't bring this thing back to the
manufacturer.
The smart ones will take it to a reputable integrator, the poor ones will take
screwdriver
in hand and do it themselves.

That is the reality we live in.  We should try and avoid different solutions to
this challenge
and opportunity, in every principality on mother Earth, and work on some global
solutions.


Regards,



Vic




Doug Probsfeld and Greg Slingerland can be reached at the eMail addresses above.



European Power Cords

1996-05-21 Thread Victor L. Boersma
Mark Montrose wrote:

"RE:European Power Cords


This question relates to the use and application of power cords 
provided into the EU when shipped from the USA.

A company builds one version of a highly configurable product.  The 
user chooses any combination of optional pwbs (over 20 different 
options) plugged anywhere into a large backplane along with a choice
of several different power supply assemblies (universal auto-voltage
detect, redundant, non-redundant, etc.).  The product is handled by 
European distributors who order a large number of units for their 
warehouses for reshipment to any country within Europe, including 
non-European countries.  The manufacturer, located in the USA, has 
no idea what country the unit will be sold to or how it is finally 
configured since this is up to the European distributor to configure
and sell the unit.

I don't think the authorities having jurisdiction give a damn about
all this.  WHO makes the Declaration of Conformity and WHO holds the
technical file, the manufacturer or the distributor ???

The USA manufacturer provides a North American power cord set as a 
default item to all shipping assemblies, since most units sold are 
to North America.  The company, at no charge, will provide to the 
distributor a power cord appropriate to the end country's application
This power cord is purchased from a European power cord manufacturer,
located in the UK, and dropped shipped to the distributor, also 
located in the UK  (one of several European distributors throughout 
the continent).

Once again, all this is irrelevant, WHO is the responsible party ?
Do you farm that responsibility out to your distributors, or are
you responsible 

The following issues have now been raised by a sales manager in the 
UK which we are unable to answer.

1.   Is it legal to ship North American, 120VAC power cords into the
 UK, knowing that these cords will be thrown away upon receipt? 
 Please provide the statutory Instrument in UK law that says 
 120 VAC rated cords are illegal for importation, even if they 
 will never be used.

Wrong question.  You can ship whatever you want into the UK.  The 
issue is whether you can put it on the market in the UK, or anywhere IThe only 
questions that you need to answer are in
else.  Putting on the market is making it available to a third party,
for the purpose of distribution and/or use.  By the way, storage is 
not considered placing on the market.  Selling to distributors is.
  
It is a bit US ethnocentric to expect UK law or EU law to say 
something about US, 120VAC, 60 Hz powercords.  In any event, the 
issue here is not UK Statutes, but EU Directives, which are legally
binding laws of the European Union that become mandatory by their 
transposition into national laws of the Members States.  The UK has 
transposed the Low Voltage Directive but that is not relevant either,
because you are distributing all over the map out of the UK.

Boxes that go to Upper Slobovia, do not have to meet EU and EEA
requirements.  They probably will have to meet Upper Slobovian 
requirements, once they get there.

2.   Please provide the UK statutory Instrument (and any other 
 European Country National Law)  that mandates products received
 from North America must contain a power cord appropriate to 
 their national electric requirements, plug specific.

The UK statute is not relevant.  EU Directives are.  The EU Member
States must allow free movement of goods that meet the essential
requirements of all relevant Directives.  Since the plugs are 
different in every EU Member State, making having a specific plug 
an essential requirement would immediately stop all trade in 
electrical equipment.

3.   In examining the LVD and EN 60950, no mention is made regarding
 the legal requirement to ship a particular power cord into 
 Europe.  The LVD para 3.2.4 mandates electrical requirements 
 and type of cordage required.

The LVD does not have a para 3.2.4, IEC-950 derivatives do, but will
not specify the plug.  Reason is that IEC-950 is not a catalogue of
possible plugs but a safety standard.  In addition, good business
acumen dictates providing the equipment with a usable plug in the
country where you sell (and instructions in a language the local
populace can understand). 

4.   If the USA manufacturer cannot stock variations of European 
 power cords, then how does your company handle this issue of 
 multiple power cordsets for use worldwide.

Any USA manufacturer who wants to, can stock any number of European
power cords he wants to.  However, he may find it to his advantage
to let that be handled by his distributors.  That has nothing to do
with technical requirements, it has something to do with the
economics of any given operation.

5.   Are their any other statutory Instruments or requirements 
 related to power cord usage within the EU not addressed above."

YES, ANNEX I of the LVD, in particular the

Re: Low Voltage Directive

1996-05-21 Thread Victor L. Boersma
Council Directive 72/23/EEC applies to any equipment designed for use with a
voltage rating
of between 50 and 1000 VAC (or between 75 and 1500 VDC).   Rated voltage is
defined in
IEC-950 as the primary power voltage, as declared by the manufacturer. So what
did you
put on the box as the "rated voltage" 

W.r.t. the WAN radio module.  Be careful now because the CE marking means you
comply
with ALL applicable Directives.  To the best of my knowledge that means that you
need to
be in compliance with the essential requirements of the LVD, the EMCD and the
TTED as
well as having subjected the equipment to the Conformity Assessment procedures
prescribed
in those three.  The TTED conformity assessment procedures prescribe 3rd party
testing
and the marking will require not only the CE mark with the number of the
Notified Body, but
probably also the crossed hockey sticks to indicate that the product is intended
and
suitable to be connected to the public telecommunications network.

If you are the integrator of the equipments, you are responsible for assuring
that the
combination is still safe, probably not a major problem, and that the EMC
Directive
requirements are still met.  That may be a bit more of a problem as mucking
around with
the equipment usually does not lead to improved EMC performance.

Awell zunne, da's 't leven


Vic  Boersma



Re: Excluded Installation Revisited

1996-05-20 Thread Victor L. Boersma
Alan,


 We know what is "excluded" from needing a CE mark:

(1) Products for which there are no legal requirements as to their technical
characteristics
(2) Products for which there only exist national requirements as to their
technical
 characteristics
(3) Products for which the requirements as to their technical characteristics
are laid down
 in EC directives "OUTSIDE" the "new approach"

Many of the authorities having jurisdiction now feel that we should consider as
apparatus
only "components of a complex nature" and that simple modular components such as
for instance, diodes or integrated circuits, need not comply with the essential
requirement, need not be subjected to any conformity assessment practices and
need no marking.

That, would not exclude your CBT system.

The questions I would ask myself are:

Are there legal EU requirements as to the technical characteristics of a CBT
system ?

If so, are they inside or outside directives under the "new approach" ?

I suspect that the answer to the first question is NO, thus exempting your CBT
system.
Please note that this would NOT exempt the components of you CBT system from
having to carry the CE marking.

Having said that, I am convinced that each part of a system can be as safe as
all get-up,
but if assembled by somebody not steeped in the arts, may result in a dangerous
package.
This particularly holds for "distributed systems" such as PBXs, LANs, etc. 

Regards,


Vic   



Re: IEC 529

1996-05-20 Thread Victor L. Boersma
Sandy Florence asked whether anybody knew anything about IEC-529 and "do
you have to comply with it"

You'll have to be a bit less cryptic with that question.

IEC-529, is the brainchild of TC70 on Degrees of Protection provided by
enclosures
(IP Code) and is a basic Safey Publication.

TC70 prepares international standards, including appropriate test methods, where
those
have not been provided in other IEC Publications, for degrees of protection
provided by 
enclosures against ingress of solid foreign objects and water and against access
to dangerous parts.  That includes standardization of access probes for use in
IEC Publications.  In as much
as the standards you use, invoke IEC Probes, or call for IPs, yes I believe that
you will have
to comply.  

According to my information, neither the USA or Canada participates in the work
of TC70,
but I would be very surprised if my old friend Walter Skuggevik of UL did not
track what happens there, just to keep the fickle finger of UL alive and well.
In addition, Al Brazauski,
now back with UL, headed a taskforce in IEC TC74 that was looking at enclosures.


Regards,


Vic



Re: CE Mark

1996-05-20 Thread Victor L. Boersma
 Ron Fotino said: 

 "I don't know about the "legal" position.  However, it seems to 
 me if you are buying the PC for personal use, there is no risk 
 of losing your PC."

 Fully agree.  If the manufacturer recalls the product, there
 is no obligation on the part of the buyer to respond to such a
 recall.  I would be very surprised if the "recall" by a small
 jobber in London, would result in a return of more that 5% of
 the products he assembled.

 (I would be very surprised if a small jobber in London would
 not just disappear and open up under a new name in another 
 section of the city before being put into a position where
 he/she would have to do a recall).   
 
 "If you are buying alot of them for corporate use or resale, 
 might I suggest you "leverage" the manufacturer to do the 
 proper testing and make the declaration.  You could test them 
 yourself.  This is a problem though because the manufacturer 
 could make changes without letting you know."

 If the assembler is working on a scale where he/she fills
 corporate orders or delivers for resale, we are no longer
 talking about a real "SMALL" operation in the first place.

 In addition, most corporations that buy PCs in bulk do have
 policies in place (for self protection purposes) that would
 not allow them to buy stuff that is not properly certified 
 and marked.

 Ergo, while this is sound advise, I doubt that in real life
 this advise is needed.  It is part of the normal business
 environment.
 
 "It is very realistic to believe that a small PC "manufacturer"
 would go into liquidation before facing prosecution."
 
 I must repeat that in a world where the PC is subject to so
 many innovations, at so rapid a pace, that much of the 
 assembling, upgrading and integrating will be done by "other
 than" the original equipment manufacturers, the notion of
 testing/certifying products as a whole is becoming 
 increasingly anachronistic.

 I suspect that trying to test/certify/license the assemblers
 will prove equally anachronic.  There are just too many hungry 
 people out there that need to make a living.

 Collectively, we will have to put on our thinking caps and try
 and find "do-able" solutions.

 Regards,


 Vic  Boersma





Re: CE Mark

1996-05-19 Thread Victor L. Boersma
This is a common concern that stems from the fact that people no
longer buy "A COMPUTER", but buy a system that needs upgrading at
frequent intervals.  CTI (Computer-Telephone-Integration) is only
one aspect of this trend.  In the USA, the FCC has a program that 
allows for "Component Registration", UL has just launched a new 
advisory group to make recommendations to that effect and CSA in
Canada can already do it.

All this will help, but the back-alley operator is not going to
worry too much about marking and we probably will see that we will 
have to design the parts so that anybody can put them together, no
matter how you misconnect them.

The legal position of the purchaser is different in every jurisdiction.

In some places it is unlawful to "make" things without a mark, in
others it is unlawful to sell things without a mark, yet in other
places there is nothing unlawful about either, but it is unlawful
to connect unmarked equipment into a wall socket.

I believe that what we see is a defacto drive for change in
regulatory practices.  There is no way that you can recall the
products put out by the back-alley operators  (by the way, some
are VERY GOOD and VERY KNOWLEDGEABLE) and prosecution will probably
only drive them a bit deeper underground.

Current regulatory practices won't touch these people, so new and
innovative means will have to be developed to control the situation.


Regards,



Vic


Re: Approvals

1996-05-02 Thread Victor L. Boersma
I hate to disagree with my customers BUT:

In Canada and the USA, the CSA certification and UL listing do NOT
constitute "APPROVAL".

The Authorities Having Jurisdiction (AHJs), for our purposes the
electrical inspection authorities in the States or Provinces do
the approving.

They normally do that by observing whether or not the equipment carries
the mark of an accredited certification or listing agency.  If they
see that mark, they approve and stop their investigation there.
(THEY DON'T HAVE TO !)

If they don't see that mark, they may choose to investigate the
product themselves, or, they may instruct the manufacturer to go
and get it tested in a place of their liking.  They will than 
approve or disapprove on the basis of that investigation.

The certification organizations are NOT in the business of 
"approving" equipment, they are in the business of certifying that 
the equipment meets specific requirements.

An electrical inspector is responsible for determining whether an
installation should be approved.  I believe you could sue the pants
of him if he did NOT approve, because the equipment does not carry
his preferred mark.  However, if the equipment does NOT carry that 
mark, he is not going to approve before he has received assurances
in one way or another that the equipment meets the applicable
requirements.  He usually is ill-equipped to do that verification
himself.


Regards,


Vic 


Re: Who can apply the CE Mark?

1996-04-30 Thread Victor L. Boersma
I attended a conference in Amsterdam on March 18th (had to dump my
poor wife in a motel on Cocoa Beach for the week-end to do it) where
Mr. Joergen Richter of DG XIII introduced a draft for the new
Connected Telecommunications Directive (CTE).  The gist of the
story is that the Commission is having a change of heart on how to
best regulate.  The point was made repeatedly that under the current
system they can't track the original parties that made the 
declaration.  They want to go even so far that they want the
notified bodies to hold the files WITHOUT LOOKING AT THE FILES and
require that the EC mark comes with the number of the notified body
that holds the files, even for a Module A conformity assessment.
(Needless to say, the Notified Bodies were less than enthralled with
that notion).  The fun is only beginning.

Regards,


Vic


Re: Dates on MDoC

1996-04-29 Thread Victor L. Boersma
Hi Jon,


Perhaps this is a very good time to remind all and sundry that
most of the Directives have been modified at one time or another
by other Directives.  To the best of my knowledge, one is expected 
to cut out relevant parts of new Directives and glue them into
the old Directives.  I know of one commercial service that does
this for you, on a subscription basis, for selective Directives.

Do not think that because you have the Directive in your hot little 
hand, you have the latest version of the Directive.


Regards,


Vic


Dumb Question

1996-04-27 Thread Victor L. Boersma
In the grey past, we obtained certification/listing from our 
friendly certification houses.  If we thought that something 
was wrong with the application of an old standard to a new product,
we would have a heart-to-heart talk with our certification 
organization.  If we had a good, solid and valid argument, chances 
were that our certification organization would agree and certify us
to the spirit of the standard.  In addition, it was likely that our
certification organization would propose changes to the standard, to
rectify the anomaly.

In the brave new world of "Declaration of Conformity", the only
time you have to explain yourself is, when you get caught.

The question will be whether the regulatory police will consist of
intelligent people who think like you, or will they be dummies who
think unlike you ?

If they think unlike you, your organization may be in for 
extraordinarily expensive times, where the fact that they don't
have you on the payroll any longer, will not offset the costs.

Question:

How are we going to best protect our owners and ourselves in this new
environment  


Ciao,


Vic  Boersma 


CE Marking

1996-01-14 Thread Victor L. Boersma
I have recently been handed a wonderful little book issued by das Zentral
Verband Elektrotechnik- und Elektronikindustrie e.V. (the German Electrical and
Electronic
Manufacturers' Association) on CE Marking.  Since this is an 8.5 x 11 inch copy
of a European A4 format document, all information w.r.t. where to where to get
copies and 
date of publication have been stripped off. The guide considers five of the most
important 
New Approach Directives: Low voltage (LVD), Electromagnetic Comaptibility (EMC),
Telecom Terminal Equipment (TTE), Machinery (MS) and Construction.  Many of the
most frequently
asked questions in this forum are answered.

It gives the Fundamentals of EC Marking; talks about the EC Directives that
require it; 
the Attestation content of the EC Marking; which products are subject to the
marking;
when the marking becomes obligatory; what the mark means; whether you can put on

other marks as well (it even tells you that there is a disagreement between
German 
and EU officials on this issue); etc., etc.  It also provides you with copiesof
forms
N, N-c, N-QU, BM, BM-QP and ZS, the attestation of conformity in accord with the

different modules.  It is a 50-page booklet and I don't know whether it is
copyrighted. 
Therefore, I have more than one reason for not wanting to spend my meagre
resources
on the distribution of this jewel.  However, if anybody knows how to get this
booklet and 
could inform this forum, I think we should make it prerequisite reading before
joining 
this forum.


Regards,



Vic



Re: Product Liability Directive

1996-01-10 Thread Victor L. Boersma
RON,

There are three Directives you may want to look at:

85/374/EEC  The Product Liability Directive
92/59 /EEC  The Product Safety Directive
91/C 12/11  The proposed Services Liability Directive

regards,


Vic   
-- Forwarded Message --

From:   Bjorn Hansen, INTERNET:b.n.han...@bnr.co.uk
TO: Ron Pickard, INTERNET:r...@ncgwpc.syntellect.com
EMC-PSTC, INTERNET:emc-p...@ieee.org
TREG, INTERNET:t...@sdd.hp.com
DATE:   10/01/96 13:23

RE: Re: Product Liability Directive

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From: b.n.han...@bnr.co.uk (Bjorn Hansen)
Subject: Re: Product Liability Directive
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Ron,

This is the one you are looking for:

Directive: 85/374/EEC,  25-Jul-85   "Approximation of the laws, regulations
and administrative provisions of the Member States concerning liability for
defective products"

Regards, Bjorn Hansen



At 09:38 10/01/96 PST, Ron Pickard wrote:
>
>Hello to all,
>
>I have read many articles that relate to the EU's Product Liability 
>Directive, but there has been no mention to its document number (e.g., 
>73/23/EEC = LVD). I have also asked a few people for this, without success.
>
>I would like to purchase this document, but I cannot at this time because of 
>the above dilemma. To this end, would any of you who know this information 
>be able to provide me with it? Any help would be greatly appreciated.
>
>Thanks in advance for your help.
>
>Regards,
>Ron Pickard
>r...@syntellect.com
>
>
Bjorn Hansen  BNR Europe Ltd, Harlow, Essex
b.n.han...@bnr.co.uk, ESN 742-3265, +44.1279.403265, Fax: +44 1279 451866




Re: World wide source for EMC amd Safety regulations and updates.

1996-01-03 Thread Victor L. Boersma
There are a number of private enterprisers that will provide you with copies 
of various directives on CD ROM or Floppies and provide updates every
three months on a subscription basis.  I know of at least one but there are
probably more  (Cost about $350 per year).  If you need to me, drop me
a line.  

Your favorite certification agency should have updated information on
applicable standards, as that situation changes so that you can get IECEE 
Scheme Certifcates to back up your declarations.  If you don't have a favorite
protection house, drop me a line.


Regards,


Vic