Lab Equipment/WEEE RoHS

2003-06-11 Thread Joe P Martin

Greetings

I am trying to determine whether our laboratory equipment is required to
comply with the RoHS and WEEE Directives at this time.
We do have some instruments for use as IVD and realize that they do fall
under the scope of the WEEE Directive as Category 8 "Medical Devices:
Laboratory
Equipment for in-vitro diagnosis."  However, we are not sure about our
thermal cyclers, DNA sequencers, mass spectrometers, etc.

The scope currently includes Category 9 called "Monitoring and Control
Instruments" and gives examples including "Measuring, weighing, or
adjusting appliances for household or as laboratory equipment".   Our
instruments do not seem like any of the other examples for the same
category, yet they do measure things.  Our mass spectrometers can use
flight time of ions to help determine the mass and thus the original
constitution of the sample.

In addition, Member States may specify laboratory equipment within their
laws that support the WEEE Directive. As an example, the current Swedish
WEEE laws on producer responsibility clearly states that laboratory
equipment is included.

Your thoughts on this subject are appreciated.

Regards

Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com




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Safety standard

2003-06-11 Thread drcuthb...@micron.com

Question on which safety standard to use: The item is a piece of test
equipment that was designed in-house for use in-house. It will be shipped to
Europe. Is the correct safety standard EN 61010-1? Thanks.

   Dave Cuthbert
   Micron Technology



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RE: FDA registration of laser

2003-06-11 Thread Peter L. Tarver

Chris -

Your rationale for not resubmitting is valid *if* the GBICs
are Certified as Class I (I haven't seen one yet that
isn't).

Your rationale for resubmitting is missing some what ifs.
Specifically, if you remove (or cover with a label) any of
the required markings or use the device outside the
manufacturers' intended application (voltage, modulation
rates, etc.).  This is all in Laser Notice 42.

With regard to modulation rates, I reviewed one
manufacturer's certifications for one of their GBICs and
discovered that the IEC60825-1, Class 1 certification was
dependant upon not having the modulation disappear.  This
did not appear in the CDRH report, but seeing this led me to
believe the risks associated with its use without fault
testing of the modulation circuitry were greater than I was
willing to accept.  Certification reports for other GBICs
>from the same manufacturer did not include this caveat.

I don't know if all GBICs are subject to the same
consideration or if some fail-safes are built into them.  If
they are subject to the same consideration, it should be so
noted in their product literature and the certifications and
the manufacturers should be taken to task for putting a yoke
on end-users.



Regards,

Peter L. Tarver, PE
Product Safety Manager
Sanmina-SCI Homologation Services
San Jose, CA
peter.tar...@sanmina-sci.com


> From: Chris Maxwell
> Sent: Wednesday, June 11, 2003 11:04 AM
>
> our current thinking is that we don't need to
> re-submit the GBICs to the CDRH



> The only reason that I could see for
> re-submitting the GBICs would be if we tried to
> re-label them and sell them under a Nettest part
> number, which we don't.
>
> Does anybody see a hole in this reasoning?
>
> Thanks,
>
>  Chris Maxwell



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Re: FDA registration of laser

2003-06-11 Thread garymcintu...@aol.com
Nope,  you are absolutely correct on the GBIC's or the new smaller pluggable
LC connector optics. You are just a distributor of those under the laser
guidelines. Again, its a fully contained module that you make no changes to,
and they have no controls or failure modes that you could induce to change the
output of the laser.
   Gary



RE: LED Emissions

2003-06-11 Thread richwo...@tycoint.com

The answer to my questions can be found in Clause 5.2.2.4 of TR 60825-9. A
rectangular aperture is required for oblong sources and the method of
measurement is presented in that clause - it isn't easy. Sigh.

>  -Original Message-
> From: WOODS, RICHARD  
> Sent: Wednesday, June 11, 2003 9:50 AM
> To:   'emc-pstc'
> Subject:  LED Emissions
> 
> I am attempting to measure, in accordance with IEC 60825-1+A1 +A2, the
> size of the apparent source of a LED plastic fiber optic driver when the
> fiber is removed. The driver assembly consists of a visible red LED, clear
> magnifying lens and a barrel into which the 2.2 mm dia plastic fiber cable
> is inserted up to the lens surface. When I focus a relay lens near the tip
> of the barrel, I can find a minimal size image that consists of a bright
> center with concentric rings (reflections along the length of the barrel).
> The image diameter is about 2.3 mm. When I focus further inside the
> assembly, I can find a smaller virtual image of the magnified LED surface
> - about 1 mm diameter. Which of these two images is considered to be the
> apparent source?
> 
> If the image near the tip of the barrel is the apparent source, it is a
> near circular image and I can use a circular aperture to determine the
> apparent size. If the apparent source is the one inside the barrel, the
> image is square (the LED die), and the standard appears to say that I must
> use a rectangular aperture. Is this correct or may I use a circular
> aperture? If so, the standard does not provide the procedure to determine
> the apparent size using a rectangular aperture. Any hints?
> 
> Richard Woods
> Sensormatic Electronics
> Tyco International
> 


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RE: FCC and Hi Temp operation

2003-06-11 Thread Kurt Fischer
My recommendation is to look at the radio performance issues as well as the
regulatory. It is possible that you have no FCC compliance issues but the
radio does not perform! The FCC could not care less if your radio works or not.
 
Kurt
 
Kurt Fischer 


HYPER Corporation 
1279 Quarry Lane, Suite B 
Pleasanton, CA 94566-8499 
+1.925.462.9105 ext. 205 (Voice) 
+1.925.577.5517 (PCS) 
+1.925.280.7751 (Fax) 
mailto:kurt.fisc...@hyperinterop.com 
www.hyperinterop.com 

 





From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Wednesday, June 11, 2003 9:58 AM
To: chuck.bu...@cubic.com; emc-p...@majordomo.ieee.org
Subject: RE: FCC and Hi Temp operation


My recommendation is for the supplier to provide you with a device that they
certify to operate within the scope of their FCC Grant at your specified temp
range. In other words, place the ownership of the problem back on the
supplier. Let them determine if they need to resumit data to the FCC for the
higher temp operation.
 
Richard Woods 
Sensormatic Electronics 
Tyco International 


From: Burns, Chuck [mailto:chuck.bu...@cubic.com]
Sent: Wednesday, June 11, 2003 11:25 AM
To: emc-p...@majordomo.ieee.org
Subject: FCC and Hi Temp operation



Hello, everyone. 

We are integrating a purchased 802.11b device into our product, but face
ambient temperature requirements up to 80 degrees C. This brings up two
problems:

1. Will it work at that temperature? One vendor advertises 55 degrees max,
another 70 but with an offer to "screen" products at 80.

2. What are the FCC requirements? The FCC Rules for the 2.45 GHz band, 15.249,
specify a frequency tolerance of 0.001% over the -20 to +50 degree range, but
do not specifically address higher temperatures. Do we simply fall back onto
the more general provisions of 15.215, keeping the 20dB bandwidth signal
within the designated band, with a recommendation to keep it within the
central 80% of the permitted range? Since we are not manufacturing the
transmitter, which already carries FCC certification, who is responsible to
the FCC for ensuring compliance at our extreme temperature?

Regards, 

Chuck Burns 
Manager of Compliance 
Cubic Transportation Systems, Inc. 
5650 Kearny Mesa Road 
San Diego, CA 92111 
Tel.: (858) 627-4562 
Fax: (858) 292-9987 
chuck.bu...@cubic.com 





RE: FDA registration of laser

2003-06-11 Thread Chris Maxwell

I want to leech off of this question; I hope that I don't get it off track.

We currently produce a module that use GBICs.  For the unfamiliar, a GBIC is
an optical transceiver for gigabit ethernet.  Our quality personnel handle
CDRH submissions; and our current thinking is that we don't need to re-submit
the GBICs to the CDRH for the following reasons:

1.  We don't make them.
2.  They are self contained.
3.  They are already CE marked and submitted to the CDRH by their own
manufacturer.
4.  The original manufacturer is clearly labeled on the units.
5.  They are universal and installed by the customer.   Our product could use
any appropriate GBIC.  We offer a couple of brands to our customers.  
However, to me it still wouldn't make sense for us to re-submit these brands
to the CDRH. Our customers could install any brand of GBIC.  


The only reason that I could see for re-submitting the GBICs would be if we
tried to re-label them and sell them under a Nettest part number, which we
don't.

Does anybody see a hole in this reasoning?

Thanks,

 Chris Maxwell | Design Engineer - Optical Division
email chris.maxw...@nettest.com | dir +1 315 266 5128 | fax +1 315 797 8024

NetTest | 6 Rhoads Drive, Utica, NY 13502 | USA
web www.nettest.com | tel +1 315 797 4449 | 


>  



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RE: FCC and Hi Temp operation

2003-06-11 Thread Barbara Judge
Hi Chuck,
 
The device in question would fall under 15.247, which has no extreme
temperature requirement in the U.S.  If the WLAN device was tested for use in
the EU the European Norm (EN 300 328) does involve extreme temperature testing
of -20 to +55 C, unless it is for indoor use or controlled environment only,
in which case they would still have to test from 0 to + 35 C.  If it is a plug
in device for use in a host system, the standard only requires that the WLAN
device meet the temperature extremes declared for the host system.  I hope
that you find this info helpful.
 
Best Regards,
Barbara


From: Burns, Chuck [mailto:chuck.bu...@cubic.com]
Sent: Wednesday, June 11, 2003 8:25 AM
To: emc-p...@majordomo.ieee.org
Subject: FCC and Hi Temp operation



Hello, everyone. 

We are integrating a purchased 802.11b device into our product, but face
ambient temperature requirements up to 80 degrees C. This brings up two
problems:

1. Will it work at that temperature? One vendor advertises 55 degrees max,
another 70 but with an offer to "screen" products at 80.

2. What are the FCC requirements? The FCC Rules for the 2.45 GHz band, 15.249,
specify a frequency tolerance of 0.001% over the -20 to +50 degree range, but
do not specifically address higher temperatures. Do we simply fall back onto
the more general provisions of 15.215, keeping the 20dB bandwidth signal
within the designated band, with a recommendation to keep it within the
central 80% of the permitted range? Since we are not manufacturing the
transmitter, which already carries FCC certification, who is responsible to
the FCC for ensuring compliance at our extreme temperature?

Regards, 

Chuck Burns 
Manager of Compliance 
Cubic Transportation Systems, Inc. 
5650 Kearny Mesa Road 
San Diego, CA 92111 
Tel.: (858) 627-4562 
Fax: (858) 292-9987 
chuck.bu...@cubic.com 





RE: Interconnecting Cables

2003-06-11 Thread Sylvia Toma


Hello Richard,

You mentioned that the cable contains hazardous voltage.  In order to
determine what type of interconnecting cable is suitable to use, you need to
find out whether or not the cable in question is supplied by a limited power
source (LPS) or NEC Class 2.

For non-LPS applications, if the cable is less than 3.05 m in length, a
suitably rated "jacketed appliance wiring material (AWM) is required.  Also,
power supply cords described in EN/UL 60950:2000 Annex NAE (3.2.4) and Table
NAE.4 can be used.  You mentioned Style 2464.  Style 2464 is a jacketed AWM,
rated 300 V 80 C.  As long as the length of the cable is maximum 3.05 m and
marked VW-1 or FT-1 (flammability rating), it should be suitable.

For non-LPS applications, if the cable exceeds 3.05 m in length, then a Listed
cable designated in the NEC (e.g. Type DP) is needed.

For LPS applications, the only requirement is that the cable should be AWM,
maximum 3.05 m in length and marked VW-1 or FT-1.  There are no requirements
in terms of Style, temperature and voltage ratings.

Hope this helps.

Rgds,
Sylvia



From: richwo...@tycoint.com [mailto:richwo...@tycoint.com]
Sent: Wednesday, June 11, 2003 5:59 AM
To: emc-p...@majordomo.ieee.org
Subject: FW: Interconnecting Cables



I didn't receive any comments at all, so I am trying again. Any comments
would be welcomed.

>  -Original Message-
> From: WOODS, RICHARD  
> Sent: Tuesday, June 03, 2003 10:58 AM
> To:   'emc-pstc'
> Subject:  Interconnecting Cables
> 
> I need to determine the robustness requirements for the outer insulation
> of an interconnecting cable for ITE when the cable contains hazardous
> voltages and when the cable will be in the same physical environment as
> the power cord. Clause 1.5.5 of EN 60950:2000 says that the cable must
> comply with the relevant requirements of the standard, but those
> requirements are not further specified in the standard.  One might infer
> that the insulation must be no lighter than the requirements for power
> cords specified in Clause 3.2.5, but that is not clear. In particular, I
> need to determine if properly voltage rated computer interconnect cables
> (e.g., UL style 2464) are sufficiently robust to comply with the standard.
> Any suggestions on acceptable cable types/styles would be appreciated.
> 
> Richard Woods
> Sensormatic Electronics
> Tyco International
> 


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Re: FDA registration of laser

2003-06-11 Thread garymcintu...@aol.com
   I think I agree with the laser 42 reference, but I would be a little
careful. The notice applies to units that are not only complete in their
construction and as such their output cannot be affected by the circuits into
which they are being installed. E. g. If the drive voltage increases to the
module, the module must have mechanisms to prevent an increase in output
power. 
   A good example are the optical transceivers used in the Ethernet and
Sonnet world. They are small complete transceivers that may be ordered and
installed into equipment after manufacture simply by plugging them into and
existing receptacle. Many of these units have class II lasers, but they have
been evaluated to insure that a fault in the end use equipment can't cause the
modules to produce greater than class I laser outputs, even in double fault
conditions.
   I don't know if the same is true for the laser modules used to
construct CD's and DVD etc. If it is then notice 42 is indeed appropriate.
   Gary





RE: FCC and Hi Temp operation

2003-06-11 Thread richwo...@tycoint.com
My recommendation is for the supplier to provide you with a device that they
certify to operate within the scope of their FCC Grant at your specified temp
range. In other words, place the ownership of the problem back on the
supplier. Let them determine if they need to resumit data to the FCC for the
higher temp operation.
 
Richard Woods 
Sensormatic Electronics 
Tyco International 


From: Burns, Chuck [mailto:chuck.bu...@cubic.com]
Sent: Wednesday, June 11, 2003 11:25 AM
To: emc-p...@majordomo.ieee.org
Subject: FCC and Hi Temp operation



Hello, everyone. 

We are integrating a purchased 802.11b device into our product, but face
ambient temperature requirements up to 80 degrees C. This brings up two
problems:

1. Will it work at that temperature? One vendor advertises 55 degrees max,
another 70 but with an offer to "screen" products at 80.

2. What are the FCC requirements? The FCC Rules for the 2.45 GHz band, 15.249,
specify a frequency tolerance of 0.001% over the -20 to +50 degree range, but
do not specifically address higher temperatures. Do we simply fall back onto
the more general provisions of 15.215, keeping the 20dB bandwidth signal
within the designated band, with a recommendation to keep it within the
central 80% of the permitted range? Since we are not manufacturing the
transmitter, which already carries FCC certification, who is responsible to
the FCC for ensuring compliance at our extreme temperature?

Regards, 

Chuck Burns 
Manager of Compliance 
Cubic Transportation Systems, Inc. 
5650 Kearny Mesa Road 
San Diego, CA 92111 
Tel.: (858) 627-4562 
Fax: (858) 292-9987 
chuck.bu...@cubic.com 





Re: FCC and Hi Temp operation

2003-06-11 Thread garymcintu...@aol.com
   The first thing to do is to check the component temperature ratings to
see if you will even meet the parts manufacturers operating limits. Many
commercial components are rated at 70C, meaning that the parts vendors only
guarantee the operation up to that point, after that you are on you own. They
will likely have some level of safety margin, but I wouldn't be betting my
equipment and company reputation on what the vendor's sales guys told you. If
the equipment hasn't been designed for that kind of ambient it may well pass
the relatively short duration screening test but you will see a sharp
reduction in the life of the product. The major stress on integrated circuits,
etc., is temperature. As the ambient and component temperatures increase the
failure rate increases exponentially and conversely life, and reliability
decrease exponentially. Screening the parts by the vendor will only tell you
that these particular units made it for an extremely short time (compared to
expected product life). How they play with the rest of the system and there
associated variables is nothing but a crap shoot, and its going to be a new
risk for every lot the vendor produces.
   The last time I checked the FCC mainly identified the test ambient as
between 50F and 100F (but I'm fuzzy on the upper limit), and that the
equipment be in a well warmed condition. That implies that the testing done
under a normal test site condition would be acceptable. However, I have had a
couple of instances when increased temperatures changed, and indeed failed,
some equipment. The components and impedances change somewhat, but the problem
I encountered was more mechanical in nature. There were some spring tension
components that were used for grounding of flex PCB's etc, that expanded under
the higher temperatures and they lost there ground contact. I would at least
confirm the emissions compliance at the higher temperatures.
   Gary McInturff



FCC and Hi Temp operation

2003-06-11 Thread Burns, Chuck
Hello, everyone. 

We are integrating a purchased 802.11b device into our product, but face
ambient temperature requirements up to 80 degrees C. This brings up two
problems:

1. Will it work at that temperature? One vendor advertises 55 degrees max,
another 70 but with an offer to "screen" products at 80.

2. What are the FCC requirements? The FCC Rules for the 2.45 GHz band, 15.249,
specify a frequency tolerance of 0.001% over the -20 to +50 degree range, but
do not specifically address higher temperatures. Do we simply fall back onto
the more general provisions of 15.215, keeping the 20dB bandwidth signal
within the designated band, with a recommendation to keep it within the
central 80% of the permitted range? Since we are not manufacturing the
transmitter, which already carries FCC certification, who is responsible to
the FCC for ensuring compliance at our extreme temperature?

Regards, 

Chuck Burns 
Manager of Compliance 
Cubic Transportation Systems, Inc. 
5650 Kearny Mesa Road 
San Diego, CA 92111 
Tel.: (858) 627-4562 
Fax: (858) 292-9987 
chuck.bu...@cubic.com 





Re: Site Atten. and Field Uniformity

2003-06-11 Thread lfresea...@aol.com
Hi Bob,

this is something that my lab does. We use network analyzers for NSA, and
Field uniformity from 26 MHz to 4 GHz if you need that.

While we are not A2LA accredited yet, we hope to be soon.

Sincerely,

Derek N. Walton
Owner L F Research EMC Design and Test Facility
Poplar Grove,
Illinois,  USA
www.lfresearch.com




Re: FDA registration of laser

2003-06-11 Thread David Heald

Kim,
  You DO need to register.  Testing may not be required, but is
strongly encouraged regardless (technically you can refer to the laser
component manufacturer's results).

Note: This is assuming that you aren't just putting an off the shelf
enclosed CD/DVD ROM drive in a system, which shouldn't require any
testing or submission.  

Best Regards,
Dave Heald


>>> Kim Boll Jensen  06/11/03 04:54AM >>>
Hi all good people

Just a simple question.

When using a CD or DVD driver in a product (PC or audio product) and
the
driver is FDA registered, do I need to register the final product at
FDA
too. I can't find a paragraph in 21 CFR which tells me when not to
register.

(The drives are Class I but includes a higher laser internally as fare
as I know)


Best regards,


Kim Boll Jensen
Bolls Raadgivning
Denmark



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LED Emissions

2003-06-11 Thread richwo...@tycoint.com

I am attempting to measure, in accordance with IEC 60825-1+A1 +A2, the size
of the apparent source of a LED plastic fiber optic driver when the fiber is
removed. The driver assembly consists of a visible red LED, clear magnifying
lens and a barrel into which the 2.2 mm dia plastic fiber cable is inserted
up to the lens surface. When I focus a relay lens near the tip of the
barrel, I can find a minimal size image that consists of a bright center
with concentric rings (reflections along the length of the barrel). The
image diameter is about 2.3 mm. When I focus further inside the assembly, I
can find a smaller virtual image of the magnified LED surface - about 1 mm
diameter. Which of these two images is considered to be the apparent source?

If the image near the tip of the barrel is the apparent source, it is a near
circular image and I can use a circular aperture to determine the apparent
size. If the apparent source is the one inside the barrel, the image is
square (the LED die), and the standard appears to say that I must use a
rectangular aperture. Is this correct or may I use a circular aperture? If
so, the standard does not provide the procedure to determine the apparent
size using a rectangular aperture. Any hints?

Richard Woods
Sensormatic Electronics
Tyco International



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FW: Interconnecting Cables

2003-06-11 Thread richwo...@tycoint.com

I didn't receive any comments at all, so I am trying again. Any comments
would be welcomed.

>  -Original Message-
> From: WOODS, RICHARD  
> Sent: Tuesday, June 03, 2003 10:58 AM
> To:   'emc-pstc'
> Subject:  Interconnecting Cables
> 
> I need to determine the robustness requirements for the outer insulation
> of an interconnecting cable for ITE when the cable contains hazardous
> voltages and when the cable will be in the same physical environment as
> the power cord. Clause 1.5.5 of EN 60950:2000 says that the cable must
> comply with the relevant requirements of the standard, but those
> requirements are not further specified in the standard.  One might infer
> that the insulation must be no lighter than the requirements for power
> cords specified in Clause 3.2.5, but that is not clear. In particular, I
> need to determine if properly voltage rated computer interconnect cables
> (e.g., UL style 2464) are sufficiently robust to comply with the standard.
> Any suggestions on acceptable cable types/styles would be appreciated.
> 
> Richard Woods
> Sensormatic Electronics
> Tyco International
> 


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RE: FDA registration of laser

2003-06-11 Thread Peter L. Tarver

Kim -

If the drive is already certified as a Class 1 laser product
and you do not modify it or remove any of the required
markings, you don't need to do anything, irrespective of the
internal laser source's laser class.Refer to Laser
Notice 42 at

http://www.fda.gov/cdrh/radhlth/pdf/laser-notice-42.pdf

For general information on reporting requirements, refer to

http://www.fda.gov/cdrh/radhlth/summary.html

and scroll down to or search on Summary of Reporting
Requirements

or refer to

http://www.fda.gov/cdrh/radhlth/eprc_reports_and_records.htm
l

for more details.


Regards,

Peter L. Tarver, PE
Product Safety Manager
Sanmina-SCI Homologation Services
San Jose, CA
peter.tar...@sanmina-sci.com

> -Original Message-
> From: Kim Boll Jensen
> Sent: Wednesday, June 11, 2003 1:55 AM
>
> Hi all good people
>
> Just a simple question.
>
> When using a CD or DVD driver in a product (PC or
> audio product) and the
> driver is FDA registered, do I need to register
> the final product at FDA
> too. I can't find a paragraph in 21 CFR which
> tells me when not to
> register.
>
> (The drives are Class I but includes a higher
> laser internally as fare
> as I know)
>
>
> Best regards,
>
>
> Kim Boll Jensen
> Bolls Raadgivning
> Denmark
>



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Home appliances and EN61000-3-2 (harmonics of input current)

2003-06-11 Thread gunter_j_ma...@embraco.com.br

Dear colleagues

Please, correct me if I am wrong ...
After January, 2004, the current amendment A14 to EN61000-3-2 will be
imcorporated to the Standard.
So, who were  Class A will continue to be Class A.

Is there any activitie that foresses a new classification of products ?
Nowadays, our product is part of home appliances (white goods - more than
75W) that need to comply with Class A.
But as happened to TVs and PCs, I think these white goods will be Class D
in the future.

Thank you !

Günter J. Maass
EECON






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RE: FDA registration of laser

2003-06-11 Thread FastWave

No registration is required if:
1) You put a Class I laser product into your product (in its entirety) and
your product is Class I.
2) You include the documentation that came with the laser product with your
product.
3) You leave all the labeling on the laser product as you received.

There is an official "variance" published by the CDRH that outlines this - I
will find dig this up and forward to.

Regards,

Bill Bisenius
ED&D, Inc.
bi...@productsafet.com
www.productsafeT.com

 -Original Message-
From:   Kim Boll Jensen [mailto:k...@bolls.dk] 
Sent:   Wednesday, June 11, 2003 4:55 AM
To: EMC-PSTC
Subject:FDA registration of laser

 << File: Kort for Kim Boll Jensen >> Hi all good people

Just a simple question.

When using a CD or DVD driver in a product (PC or audio product) and the
driver is FDA registered, do I need to register the final product at FDA
too. I can't find a paragraph in 21 CFR which tells me when not to
register.

(The drives are Class I but includes a higher laser internally as fare
as I know)


Best regards,


Kim Boll Jensen
Bolls Raadgivning
Denmark


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Re: FDA registration of laser

2003-06-11 Thread T.Sato

On Wed, 11 Jun 2003 10:54:36 +0200,
  Kim Boll Jensen  wrote:

> When using a CD or DVD driver in a product (PC or audio product) and the
> driver is FDA registered, do I need to register the final product at FDA
> too. I can't find a paragraph in 21 CFR which tells me when not to
> register.

I would suggest to refer to the Laser Notice No.42 issued from CDRH, at:

  http://www.fda.gov/cdrh/radhlth/pdf/laser-notice-42.pdf

Which is titled "Clarification of compliance requirements for certain
manufacturers who incorporate certified Class I laser products into
their products", and describes possible reduction of the requirements
under certain conditions.

Regards,
Tom


Tomonori Sato  
URL: http://member.nifty.ne.jp/tsato/


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Site Atten. and Field Uniformity

2003-06-11 Thread rehel...@mmm.com

I am looking for a company in the US that will perform site attenuation and
field uniformity for us.
We normally generate our own data but this year we are looking for an
independent verification.

Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel:  651- 778-6336
Fax:  651-778-6252
===



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RE: New Approach Directives and DOA and DOW

2003-06-11 Thread Nick Williams

I'm not going to disagree with Neil's approach (indeed I endorse it), 
but I would observe that the Construction Products Directive (CPD) is 
different to the other New Approach Directives in this (and many 
other!) respects, in that CE marking is not possible for products 
within the scope of the Directive until a Harmonised standard has 
been published. It is not possible to CE mark against the Essential 
Requirements of the CPD since these apply to the buildings into which 
the product is integrated, not the product itself.

The European Commission has decided, for all CPD harmonised 
standards, that there will be a period of 9 months from the Date of 
Availability of the standard, before CE marking can commence. This is 
in order to allow governments, trading standards, notified bodies, 
test labs and manufacturers etc,, to prepare for the big event. Thus 
even if the Harmonised Standard is available and you can test to it 
now, you are not permitted to apply the CE marking until after the 
date published by the Commission in the Official Journal.

The CPD is a mess, and certainly has done nothing to promote a free 
market in construction products for more than ten years now. The 
Commission has allowed the whole of this market sector to be hijacked 
by people whose primary business interest is in conformity assessment 
and as a result manufacturers of CPs will gain nothing like the 
market freedom offered by (i.a.) the LVD or Machinery Directives.

Nick.




At 10:13 +0100 11/6/03, Barker, Neil wrote:
>I would agree with you. Providing that the CPD has been enacted in the law
>of the Member State in which you wish to market your product, and that
>appropriate routes to compliance are available, then it should be your
>decision to take that route to market in preference to the former national
>system. You could take issue with the responsible government agency
>concerning the actions of their Notified Body, but remembering that you are
>at liberty to use any NB in the EU, I would simply go elsewhere. You don't
>have to use a NB in the destination country.
>
>Best regards,
>
>Neil R. Barker
>Compliance Engineering Manager
>e2v technologies ltd
>Waterhouse Lane
>Chelmsford
>Essex
>CM1 2QU
>U.K.
>
>Tel: +44 (01245) 453616
>Fax: +44 (01245) 453410
>E-mail: neil.bar...@e2vtechnologies.com
>
>
>>  -Original Message-
>>  From: Kevin Harris [mailto:kevinharr...@dsc.com]
>>  Sent: 10 June 2003 16:00
>>  To: EMC-PSTC (E-mail)
>>  Subject: New Approach Directives and DOA and DOW
>>
>>
>>
>>  Hello Group,
>>
>>  I've just been told a story by a notified body under the Construction
>>  Products Directive in Europe that as far as they were
>>  concerned, despite the
>>  fact that a standard was published in the OJ and it's DOA has
>>  already passed
>>  that they were under no obligation to accept that standard or
>>  indeed follow
>>  the CPD at all until the DOW (removing their national
>>  standard) had passed.
>>  In this case, the notified body under the CPD is the same agency that
>>  currently is their "notified body" under their national system. I have
>>  always presumed that the choice of systems to follow in the
>>  transition time
>>  between DOA and DOW was the manufacturer's and not the
>>  notified body's.
>>  Comments?
>>
>>  Best Regards,
>>
>>
>>  Kevin Harris
>>  Manager, Approvals and CAD Services
>>  Digital Security Controls
>>  3301 Langstaff Road
>>  Concord, Ontario
>>  CANADA
>>  L4K 4L2
>>
>>  Tel: +1 905 760 3000 Ext. 2378
>>  Fax +1 905 760 3020
>>
>>  Email: kevinharr...@dsc.com
>  >
>>


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RE: FDA registration of laser

2003-06-11 Thread Colgan, Chris

As far as I know, yes, you have to register the actual product with the FDA.
That's what I have always done anyway.  The fact that the driver is FDA
registered will make it a fairly simple paperwork exercise.

If you think about it, customs will not be able to associate the driver's
FDA accession number with the product it is contained in.  The product will
need it's own accession number from the FDA (if that makes sense).

Regards

Chris Colgan
Compliance Engineer
TAG McLaren Audio Ltd
The Summit, Latham Road
Huntingdon, Cambs, PE29 6ZU
*Tel: +44 (0)1480 415 627
*Fax: +44 (0)1480 52159
* Mailto:chris.col...@tagmclaren.com
* http://www.tagmclaren.com


> -Original Message-
> From: Kim Boll Jensen [SMTP:k...@bolls.dk]
> Sent: Wednesday, June 11, 2003 9:55 AM
> To:   EMC-PSTC
> Subject:  FDA registration of laser
> 
> Hi all good people
> 
> Just a simple question.
> 
> When using a CD or DVD driver in a product (PC or audio product) and the
> driver is FDA registered, do I need to register the final product at FDA
> too. I can't find a paragraph in 21 CFR which tells me when not to
> register.
> 
> (The drives are Class I but includes a higher laser internally as fare
> as I know)
> 
> 
> Best regards,
> 
> 
> Kim Boll Jensen
> Bolls Raadgivning
> Denmark << File: Kort for Kim Boll Jensen >> 


**  
   Please visit us at www.tagmclaren.com
**

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Important Note: Any typographical, clerical or other error in this 
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the part of TAG McLaren Audio Limited. Any orders placed shall
be subject to acceptance by TAG McLaren Audio Limited on its 
standard terms and conditions of sale which shall govern the 
contract for the sale and purchase of the products ordered to the
exclusion of any other terms and conditions.

TAG McLaren Audio Ltd
The Summit, 11 Latham Road
Huntingdon, Cambs, PE29 6ZU
Telephone : 01480 415600 (+44 1480 415600)
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**  
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**



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RE: New Approach Directives and DOA and DOW

2003-06-11 Thread Barker, Neil

I would agree with you. Providing that the CPD has been enacted in the law
of the Member State in which you wish to market your product, and that
appropriate routes to compliance are available, then it should be your
decision to take that route to market in preference to the former national
system. You could take issue with the responsible government agency
concerning the actions of their Notified Body, but remembering that you are
at liberty to use any NB in the EU, I would simply go elsewhere. You don't
have to use a NB in the destination country.

Best regards,

Neil R. Barker
Compliance Engineering Manager
e2v technologies ltd
Waterhouse Lane
Chelmsford
Essex
CM1 2QU
U.K.

Tel: +44 (01245) 453616
Fax: +44 (01245) 453410
E-mail: neil.bar...@e2vtechnologies.com


> -Original Message-
> From: Kevin Harris [mailto:kevinharr...@dsc.com]
> Sent: 10 June 2003 16:00
> To: EMC-PSTC (E-mail)
> Subject: New Approach Directives and DOA and DOW
> 
> 
> 
> Hello Group,
> 
> I've just been told a story by a notified body under the Construction
> Products Directive in Europe that as far as they were 
> concerned, despite the
> fact that a standard was published in the OJ and it's DOA has 
> already passed
> that they were under no obligation to accept that standard or 
> indeed follow
> the CPD at all until the DOW (removing their national 
> standard) had passed.
> In this case, the notified body under the CPD is the same agency that
> currently is their "notified body" under their national system. I have
> always presumed that the choice of systems to follow in the 
> transition time
> between DOA and DOW was the manufacturer's and not the 
> notified body's.
> Comments?
> 
> Best Regards,
> 
> 
> Kevin Harris
> Manager, Approvals and CAD Services
> Digital Security Controls
> 3301 Langstaff Road
> Concord, Ontario
> CANADA
> L4K 4L2
> 
> Tel: +1 905 760 3000 Ext. 2378
> Fax +1 905 760 3020
> 
> Email: kevinharr...@dsc.com
> 
>


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FDA registration of laser

2003-06-11 Thread Kim Boll Jensen
This is a multi-part message in MIME format.
Hi all good people

Just a simple question.

When using a CD or DVD driver in a product (PC or audio product) and the
driver is FDA registered, do I need to register the final product at FDA
too. I can't find a paragraph in 21 CFR which tells me when not to
register.

(The drives are Class I but includes a higher laser internally as fare
as I know)


Best regards,


Kim Boll Jensen
Bolls Raadgivning
Denmark

Title: FDA registration of laser






Hi all good people


Just a simple question.


When using a CD or DVD driver in a product (PC or audio product) and the

driver is FDA registered, do I need to register the final product at FDA

too. I can't find a paragraph in 21 CFR which tells me when not to

register.


(The drives are Class I but includes a higher laser internally as fare

as I know)



Best regards,



Kim Boll Jensen

Bolls Raadgivning

Denmark




<>