Dumb Question
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
Re: NPF Returns
In message "Steve Chin" writes: > I have a dumb question. How do the EU directives apply to a unit that was > put into service prior to Jan. 1, 1996 (without a CE mark on it), which > has been returned to its US manufacturer for serveice, and is being > returned to its owner with No Problem Found (no repair work was performed > on the unit, only an examination for functionality). Does a unit found to > be NPF need to have a CE mark applied to it before it can be sent back to > its owner? Definitely not. In fact no CE mark is required even if it is repaired as long as it is only returned to the original specification. Essentially, it is second-hand equipment originally "placed on the market" before 1.1.1996 and therefore still exempt. It is only if the unit was modified or upgraded that it would be treated as newly "placed on the market" and would therefore require CE marking. The UK official interpretation of this point is Q11 in Section 11 of the FAQ "Sources of EMC and Safety Compliance Information" which is now regularly posted to the sci.engr.electrical.compliance newsgroup (last posted 20 April) and which will be archived at http://world.std.com/~techbook/compliance_faq.html Regards, Bill Lyons. = Claude Lyons Limited Brook Road Waltham Cross Herts EN8 7LR England Leaders in Voltage and Power Control - Precise Electrical Instrumentation Telephone: +44 1992 76 Fax: +44 1992 769849 Telex: 22724 CL LTD G email: b...@lyons.demon.co.uk or w.ly...@ieee.org =
