Re: [PSES] HAR factories for marked cable
Looking at the LVD guidance, (and of course it's guidance not law) http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , page 28 Products Scope of LVD Examples of productsComments Cables Yes [picture of cable] Marked with HAR to increase tractability Regards Charlie -Original Message- From: Cortland Richmond [mailto:k...@earthlink.net] Sent: 26 April 2013 06:36 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] HAR factories for marked cable It looks very much as if this is a NGO, an association of firms who have trademarked a useful indicator of compliance, but one that is in no way required for entry to the EU marketplace If it were to become a required mark, however, that could compare to the situation of some decades ago, when localities and States in the US sometimes required a UL (tm) mark on electrical equipment, thus restricting testing to that one firm's labs. This was eventually ruled an unlawful barrier to competition, and we now use the term Nationally Recognized Test Laboratory (NRTL) to describe all the recognized labs whose marks are acceptable. I suspect a similar logic might then apply, were a non-EU cable manufacturer to find his product denied entry for lack of the HAR mark. Could be wrong: I am not a lawyer. Cortland Richmond - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
In message 3f0347ac6ed9504191f91f07629fbb0c0155b...@thhsle14mbx2.hslive.net, dated Fri, 26 Apr 2013, Charlie Blackham char...@sulisconsultants.com writes: Looking at the LVD guidance, (and of course it's guidance not law) http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , page 28 Products Scope of LVD Examples of products Comments Cables Yes [picture of cable] Marked with HAR to increase tractability 'tractability' - the quality of being easily managed I suspect weasel wording here. The Commission has no business apparently elevating a private marking scheme to a requirement under a Directive. So using a confusing word may be a way to 'fog' the issue. Some people will assume it's a typo for 'traceability'. Participation in the HAR scheme is *effectively* restricted to certification bodies (it's not a manufacturers' organization) in Europe because ENs and HDs must be in force in the country - from the HAR site: QUOTE Within the country of the applicant, the European ENs and HDs must have formally entered into force; any conflicting national standards must have been withdrawn. Assessment of capability and qualification of the candidate by a HAR assessment team, according to harmonised requirements; positive results to be formally endorsed by the HAR Group. ENDQUOTE This restriction must, in fact, bear some responsibility for the widespread presence of dangerous fake 'HAR' marked cables. I have a sample alleged to have 0.75 mm^2 conductors, which are barely 0.3 mm^2 in fact, fitted with a fake British 13 A plug marked '10 A' but without a fuse. The point is that if you use a test house and the cable isn't HAR marked, the test house may well want to test the cable to whichever of HD 21, HD 22, EN 50525, EN 50143, EN 50214, EN 60702 or EN 61138 applies, and that is extremely costly. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist burns unit - and made me learn 'To a haggis'. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
Something seems to have got lost along the way here: The original question was not who can grant the HAR mark?, but (paraphrased) must the cable factory be in the EU? The answer to the factory question is No, as millions of consumer products made outside the EU with HAR marked cable shows. (and yes there is falsely marked cable too) John C. -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 26 April 2013 09:06 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] HAR factories for marked cable In message 3f0347ac6ed9504191f91f07629fbb0c0155b...@thhsle14mbx2.hslive.net, dated Fri, 26 Apr 2013, Charlie Blackham char...@sulisconsultants.com writes: Looking at the LVD guidance, (and of course it's guidance not law) http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , page 28 Products Scope of LVD Examples of products Comments Cables Yes [picture of cable] Marked with HAR to increase tractability 'tractability' - the quality of being easily managed I suspect weasel wording here. The Commission has no business apparently elevating a private marking scheme to a requirement under a Directive. So using a confusing word may be a way to 'fog' the issue. Some people will assume it's a typo for 'traceability'. Participation in the HAR scheme is *effectively* restricted to certification bodies (it's not a manufacturers' organization) in Europe because ENs and HDs must be in force in the country - from the HAR site: QUOTE Within the country of the applicant, the European ENs and HDs must have formally entered into force; any conflicting national standards must have been withdrawn. Assessment of capability and qualification of the candidate by a HAR assessment team, according to harmonised requirements; positive results to be formally endorsed by the HAR Group. ENDQUOTE This restriction must, in fact, bear some responsibility for the widespread presence of dangerous fake 'HAR' marked cables. I have a sample alleged to have 0.75 mm^2 conductors, which are barely 0.3 mm^2 in fact, fitted with a fake British 13 A plug marked '10 A' but without a fuse. The point is that if you use a test house and the cable isn't HAR marked, the test house may well want to test the cable to whichever of HD 21, HD 22, EN 50525, EN 50143, EN 50214, EN 60702 or EN 61138 applies, and that is extremely costly. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist burns unit - and made me learn 'To a haggis'. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
In message 7878A08362FE46DCBD64C291ACE4BA2F@LENVOR61iJOHN, dated Fri, 26 Apr 2013, John Cotman john.cot...@conformance.co.uk writes: Something seems to have got lost along the way here: The original question was not who can grant the HAR mark?, but (paraphrased) must the cable factory be in the EU? The answer to the factory question is No, as millions of consumer products made outside the EU with HAR marked cable shows. (and yes there is falsely marked cable too) The original question was 'A cable supplier has mentioned that cables cannot bear the HAR marking if they are not manufactured within an EU country. This seems to be buried in HAR agreement documents that are out of my reach. Can anyone confirm this? ' Note 'Cannot bear the HAR marking'. I don't think anything much has been lost. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist burns unit - and made me learn 'To a haggis'. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] inane EDN article
There are too many 'What The Heck Were You Thinking' moments for such a short article. Classic example of how NOT to test, then submit a relatively hi-power piece of equipment to an NRTL/CSS. http://www.edn.com/electronics-blogs/tales-from-the-cube/4412240/The-product -that-made-me-downright-certifiable - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
