Re: [PSES] RoHS directive

[Brian Oconnell]

The boys in our Tijuana factory were asking why so many suppliers' 
regulatory/compliance docs were hosed. Could only reply that el mundo esta 
mucho loco.

Brian

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: Friday, November 21, 2014 1:57 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS directive

And then I re-read it and see that you could interpret a DoC to mean that 
reference to 2002/95/EC means that the declaration is NOT a reference to 
2011/65/EU! Most confusing if you don’t know of Art 26 – in which case an 
Authority could reject it as out of date!! Thus I would strongly recommend that 
only 2011/65/EU be stated.

John Allen

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 21 November 2014 20:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS directive

Agreed- see Article 26 “Repeal” of 2011/65/EU, (RoHS 2) which states:
“Directive 2002/95/EC as amended by the acts listed in Annex VII, Part A is 
repealed with effect from 3 January 2013 without prejudice to the obligations 
of the Member States relating to the time limits for transposition into 
national law and application of the Directive set out in Annex VII, Part B. 
References to the repealed acts shall be construed as references to this 
Directive and shall be read in accordance with the correlation table in Annex 
VIII.”

No argument there!

John Allen
Compliance with Experience.
West London
UK
From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 21 November 2014 19:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS directive

Brian

2002 version is obsolete and should not be referenced
( it wasn't a CE marking directive either)

Regards
Charlie

Sent from my mobile

From: Brian Oconnell
Sent: ‎21/‎11/‎2014 19:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RoHS directive
The boss questioned the way declarations are written after looking at some 
other's documents where their D of C is worded thus:

"Directive 2002/95/EC (and its amendments and 2011/65/EU)"

Is not the RoHS directive now 2011/65 ? Is the 2002/95 stuff considered not 
obsolete? Any good reason to reference 2002/95?

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:174:0088:0110:en:PDF
 

Brian

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Re: [PSES] GUARDS AND PROTECTIVE DEVICES

[John Woodgate]

In message <07f8089e-0531-408d-aed0-8cd68a772...@conformance.co.uk>, 
dated Fri, 21 Nov 2014, Nick Williams  
writes:


EN 953 is a CEN standard, EN 60950 is an IEC/CENELEC standard and I 
doubt the people who wrote the two standards speak to each other much, 
if at all.


Very likely.

EN 60950 is really not a good starting place for compliance with the 
Machinery Directive (even the electrical safety aspects)


Since it's a standard for IT equipment that mostly has no moving parts 
or low-energy mechanical stuff, it's not surprising that it doesn't fit 
machines very well.


- if EN 60204-1 won’t tell you what you need to know then for 
machine designers the second port of call should be EN 60335-1 (which, 
unlike EN 60950, is listed in the OJ under the Machinery Directive).


Because household and commercial appliances very often DO contain 
significant 'machinery', not all of it low-energy (e.g. loaded washing 
machine drum at 1200 RPM).


IEC 60950 is probably the most globalised of all the safety standards 
and so it has to be acceptable to many territories outside of Europe 
where there is no local equivalent of the Machinery Directive. I 
don’t think you can expect to see it listed in the OJ under the 
Machinery Directive any time soon.


For the above reasons; anyway it's being superseded by IEC/EN 62368-1.


One key message that people who come from an electrical apparatus 
background need to understand when they start dealing with the 
Machinery Directive is that (with the possible exception of EN ISO 
12100, which contains general guidance only)  there is no one standard 
they can use as the basis of compliance with all EHSRs. Being a 
machinery designer means having familiarity with a range of typically 
20 or more standards and applying only the bits which are relevant to 
your particular application.


What jolly fun!
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] TTE Equipment and R&TTE Directive

[John Woodgate]

In message <006601d005d1$a9aaef40$fd00cdc0$@randolph-telecom.com>, dated 
Fri, 21 Nov 2014, Joe Randolph  writes:


While compliance with these standards is not a regulatory requirement, 
some manufacturers (and their customers) feel more comfortable knowing 
that a product meets these requirements.  In my judgment, the 
requirements in the TS-103 021 series are pretty reasonable, especially 
compared to the some of the per-country national requirements that were 
mandatory prior to the implementation of the TTE directive in 2000.


So, it might be appropriate to at least review the requirements in the 
TS 103 021 series and satisfy yourself that your product complies with 
those requirements.  However, that would be a purely voluntary activity 
because there is no regulatory requirement to meet those requirements.


If your product is a listen-only device that only looks for ringing, 
only a small subset of the requirements in the TS 103 021 series would 
be relevant, such as the impedance presented to ring signals and the 
applicable thresholds for ring detection.  I think you will find the 
requirements to be easy to meet.


I think this is very good advice.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] RoHS directive

[John Allen]

And then I re-read it and see that you could interpret a DoC to mean that
reference to 2002/95/EC means that the declaration is NOT a reference to
2011/65/EU! Most confusing if you don’t know of Art 26 – in which case an
Authority could reject it as out of date!! Thus I would strongly recommend
that only 2011/65/EU be stated.

 

John Allen

 

From: John Allen [mailto:john_e_al...@blueyonder.co.uk] 
Sent: 21 November 2014 20:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS directive

 

Agreed- see Article 26 “Repeal” of 2011/65/EU, (RoHS 2) which states:

“Directive 2002/95/EC as amended by the acts listed in Annex VII, Part A is
repealed with effect from 3 January 2013 without prejudice to the
obligations of the Member States relating to the time limits for
transposition into national law and application of the Directive set out in
Annex VII, Part B. 

References to the repealed acts shall be construed as references to this
Directive and shall be read in accordance with the correlation table in
Annex VIII.”

 

No argument there!

 

John Allen

Compliance with Experience.

West London

UK

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 21 November 2014 19:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS directive

 

Brian

2002 version is obsolete and should not be referenced
( it wasn't a CE marking directive either)

Regards
Charlie

Sent from my mobile

  _  

From: Brian Oconnell  
Sent: ‎21/‎11/‎2014 19:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RoHS directive

The boss questioned the way declarations are written after looking at some
other's documents where their D of C is worded thus:

"Directive 2002/95/EC (and its amendments and 2011/65/EU)"

Is not the RoHS directive now 2011/65 ? Is the 2002/95 stuff considered not
obsolete? Any good reason to reference 2002/95?

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:174:0088:011
0:en:PDF 

Brian

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Re: [PSES] GUARDS AND PROTECTIVE DEVICES

[Nick Williams]

Dave,

EN 60204-1 is really only any use as a means of addressing the electrical 
safety and some of the control system/interface requirements of the Machinery 
Directive. You certainly can’t use it as the basis for compliance with the 
requirements for guard design or any of the other EHSRs related to mechanical 
hazards. 

EN 953 covers the points in EHSR 1.4.1 (and more besides) although frankly 
there is not a great deal in it which is not common sense for someone 
experienced in machine design. 

EN 953 is a CEN standard, EN 60950 is an IEC/CENELEC standard and I doubt the 
people who wrote the two standards speak to each other much, if at all. EN 
60950 is really not a good starting place for compliance with the Machinery 
Directive (even the electrical safety aspects) - if EN 60204-1 won’t tell you 
what you need to know then for machine designers the second port of call should 
be EN 60335-1 (which, unlike EN 60950, is listed in the OJ under the Machinery 
Directive). 

IEC 60950 is probably the most globalised of all the safety standards and so it 
has to be acceptable to many territories outside of Europe where there is no 
local equivalent of the Machinery Directive. I don’t think you can expect to 
see it listed in the OJ under the Machinery Directive any time soon. 

One key message that people who come from an electrical apparatus background 
need to understand when they start dealing with the Machinery Directive is that 
(with the possible exception of EN ISO 12100, which contains general guidance 
only)  there is no one standard they can use as the basis of compliance with 
all EHSRs. Being a machinery designer means having familiarity with a range of 
typically 20 or more standards and applying only the bits which are relevant to 
your particular application. 

Happy to discuss/debate further if you have any more questions. 

Regards

Nick. 




> On 20 Nov 2014, at 19:26, Nyffenegger, Dave  
> wrote:
> 
> Folks,
> 
> The Machinery Directive MD 2006/42/EC ANNEX I states
> 
> 1.4. REQUIRED CHARACTERISTICS OF GUARDS AND PROTECTIVE DEVICES
> 1.4.1. General requirements
> Guards and protective devices must:
> - be of robust construction,
> - be securely held in place,
> - not give rise to any additional hazard,
> 
> We normally use EN 60204-1 Safety of machinery - Electrical equipment of 
> machines - Part 1: General requirements to certify paper and mail handling 
> machinery to the Machinery Directive.   I don't really see anything in there 
> that addressed the first and third bullets above.  
> 
> The OJ for MD harmonized standards lists  EN 953:1997+A1:2009 Safety of 
> machinery - Guards - General requirements for the design and construction of 
> fixed and movable guards.  I don't currently have a copy.  Does anyone know 
> if this standard addresses the above requirements?  Sounds like it should.  
> Is there any other harmonized standard to apply to meet these requirements?
> 
> EN 60950-1 has requirements for flammability and mechanical strength of 
> guards well defined but EN 60950-1 itself is not in the list of harmonized 
> standards for the MD.  It is applicable to the Low Voltage Directive and the 
> MD does state that the requirements of the LVD apply.I'm wondering if the 
> EN 953 standard has the same requirements in the same level of detail or if 
> they are at least consistent.
> 
> Thanks
> -Dave
> 
> David P. Nyffenegger, PMP, SM-IEEE
> Product Development Manager
> 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646

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Re: [PSES] TTE Equipment and R&TTE Directive

[Joe Randolph]

Hi Carl:

As Larry noted, for the EU, land line telecom terminals are only required to
meet the applicable requirements for safety and EMC.  For CE marking, there
are no *regulatory* requirements for compatibility with the land line
telecom network.  This has been the case ever since the TTE directive came
into effect in 2000.

In the late 1990s, TBR 21 was ETSI's attempt to come up with a harmonized EU
standard for equipment that interfaces to the analog land line telephone
network.  The intention was to use TBR 21 as the basis for a harmonized
regulatory standard called CTR 21, which would have applied under an earlier
regulatory scheme that was replaced by the TTE directive.

Since the TTE directive eliminated any regulatory requirements on the
parameters covered by TBR -21, some manufacturers were uneasy having no
official guidance on compatibility with the analog land-line phone network.
For this reason, ETSI continued to update and evolve TBR 21 for many years
as an "advisory" standard that was purely voluntary.  I think the current
version is a set of documents called TS 103 021-1, TS 103 021-2, and TS 103
021-3.

While compliance with these standards is not a regulatory requirement, some
manufacturers (and their customers) feel more comfortable knowing that a
product meets these requirements.  In my judgment, the requirements in the
TS-103 021 series are pretty reasonable, especially compared to the some of
the per-country national requirements that were mandatory prior to the
implementation of the TTE directive in 2000.

So, it might be appropriate to at least review the requirements in the TS
103 021 series and satisfy yourself that your product complies with those
requirements.  However, that would be a purely voluntary activity because
there is no regulatory requirement to meet those requirements.

If your product is a listen-only device that only looks for ringing, only a
small subset of the requirements in the TS 103 021 series would be relevant,
such as the impedance presented to ring signals and the applicable
thresholds for ring detection.  I think you will find the requirements to be
easy to meet.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
j...@randolph-telecom.com
http://www.randolph-telecom.com



-Original Message-
From: Larry K. Stillings [mailto:la...@complianceworldwide.com] 
Sent: Wednesday, November 19, 2014 3:27 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] TTE Equipment and R&TTE Directive

Hi Carl,

What you have surmised is correct. You are not required to meet any line
standards is order to comply with the directives. 

The DoCs you are seeing, is the voluntary testing to ETSI standards to show
that the line interface device is compatible with the phone network. I asked
several times a joint NIST - EU meetings (in the
2000's) about the implementation of TTE standards under the R&TTE directive
and always got the same response. There are no formal complaints and
therefore no implementation of mandatory standards will occur. Also, the
other reason the directive is going to become the Radio Equipment Directive
(RED), as that is all it has ever really covered.

Of course being a test lab whom does those tests, we can only make a mild
suggestion you should test, as to this day we still have product showing up
that don't comply with the ETSI TBR and or ES 203 021-x standards, but that
is always a financial / business decision on what the risk is of performing
no testing.


Larry K. Stillings
Compliance Worldwide, Inc. 
Test Locally, Sell Globally and Launch Your Products Around the World! 
FCC - Wireless - Telecom - CE Marking - International Approvals - Product
Safety
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com

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-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Wednesday, November 19, 2014 3:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] TTE Equipment and R&TTE Directive

Dear List Members,

I haven't worked with land-line telecom hardware for many years.  I have a
device intended for use by handicapped persons that will enable a visual
alarm if the land-line phone is ringing, so the device is listen-only.

I've found what appears to be good and reliable guidance concerning TTE
equipment at this link which indicates that TTE equipment need only co

Re: [PSES] RoHS directive

[John Allen]

Agreed- see Article 26 “Repeal” of 2011/65/EU, (RoHS 2) which states:

“Directive 2002/95/EC as amended by the acts listed in Annex VII, Part A is
repealed with effect from 3 January 2013 without prejudice to the
obligations of the Member States relating to the time limits for
transposition into national law and application of the Directive set out in
Annex VII, Part B. 

References to the repealed acts shall be construed as references to this
Directive and shall be read in accordance with the correlation table in
Annex VIII.”

 

No argument there!

 

John Allen

Compliance with Experience.

West London

UK

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 21 November 2014 19:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS directive

 

Brian

2002 version is obsolete and should not be referenced
( it wasn't a CE marking directive either)

Regards
Charlie

Sent from my mobile

  _  

From: Brian Oconnell  
Sent: ‎21/‎11/‎2014 19:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RoHS directive

The boss questioned the way declarations are written after looking at some
other's documents where their D of C is worded thus:

"Directive 2002/95/EC (and its amendments and 2011/65/EU)"

Is not the RoHS directive now 2011/65 ? Is the 2002/95 stuff considered not
obsolete? Any good reason to reference 2002/95?

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:174:0088:011
0:en:PDF 

Brian

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Re: [PSES] RoHS directive

[Charlie Blackham]

Brian

2002 version is obsolete and should not be referenced
( it wasn't a CE marking directive either)

Regards
Charlie

Sent from my mobile

From: Brian Oconnell
Sent: ‎21/‎11/‎2014 19:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RoHS directive

The boss questioned the way declarations are written after looking at some 
other's documents where their D of C is worded thus:

"Directive 2002/95/EC (and its amendments and 2011/65/EU)"

Is not the RoHS directive now 2011/65 ? Is the 2002/95 stuff considered not 
obsolete? Any good reason to reference 2002/95?

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:174:0088:0110:en:PDF

Brian

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Re: [PSES] GUARDS AND PROTECTIVE DEVICES

[Pete Perkins]

Dave, et al,

Presumably you developed the need for a guard as part of your risk
assessment.  

You could do another assessment of the situation with the guard in
place and document your rationale for meeting the requirements listed in
your TF.  Robustness is a quantifiable; relating it against an EN makes it
easy.  No further hazards will fall out of your reassessment after the guard
is applied.  

The TF coverage is the key to showing acceptability of the issue.  

:>) br, Pete
 
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe  97281-3427
 
503/452-1201 fone/fax
p.perk...@ieee.org
 
_ _ _ _ _

Folks,

The Machinery Directive MD 2006/42/EC ANNEX I states

1.4. REQUIRED CHARACTERISTICS OF GUARDS AND PROTECTIVE DEVICES 1.4.1.
General requirements Guards and protective devices must:
- be of robust construction,
- be securely held in place,
- not give rise to any additional hazard,

We normally use EN 60204-1 Safety of machinery - Electrical equipment of
machines - Part 1: General requirements to certify paper and mail handling
machinery to the Machinery Directive.   I don't really see anything in there
that addressed the first and third bullets above.  

The OJ for MD harmonized standards lists  EN 953:1997+A1:2009 Safety of
machinery - Guards - General requirements for the design and construction of
fixed and movable guards.  I don't currently have a copy.  Does anyone know
if this standard addresses the above requirements?  Sounds like it should.
Is there any other harmonized standard to apply to meet these requirements?

EN 60950-1 has requirements for flammability and mechanical strength of
guards well defined but EN 60950-1 itself is not in the list of harmonized
standards for the MD.  It is applicable to the Low Voltage Directive and the
MD does state that the requirements of the LVD apply.I'm wondering if
the EN 953 standard has the same requirements in the same level of detail or
if they are at least consistent.

Thanks
-Dave

David P. Nyffenegger, PMP, SM-IEEE
Product Development Manager

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Re: [PSES] GUARDS AND PROTECTIVE DEVICES

[Charlie Blackham]

Dave



You can read the scope of any standard for free at http://www.evs.ee/shop and 
read (on-line for 24 hours) the whole standard for 2 Euro



Your risk assessment should determine whether the guard needs to be assessed 
against the requirements detailed in an appropriate standard, or just more 
generally against Annex I.  If you are going to use a standard, I would use one 
Harmonised under the MD.



Regards

Charlie



-Original Message-
From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
Sent: 20 November 2014 19:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] GUARDS AND PROTECTIVE DEVICES



Folks,



The Machinery Directive MD 2006/42/EC ANNEX I states



1.4. REQUIRED CHARACTERISTICS OF GUARDS AND PROTECTIVE DEVICES 1.4.1. General 
requirements Guards and protective devices must:

- be of robust construction,

- be securely held in place,

- not give rise to any additional hazard,



We normally use EN 60204-1 Safety of machinery - Electrical equipment of 
machines - Part 1: General requirements to certify paper and mail handling 
machinery to the Machinery Directive.   I don't really see anything in there 
that addressed the first and third bullets above.



The OJ for MD harmonized standards lists  EN 953:1997+A1:2009 Safety of 
machinery - Guards - General requirements for the design and construction of 
fixed and movable guards.  I don't currently have a copy.  Does anyone know if 
this standard addresses the above requirements?  Sounds like it should.  Is 
there any other harmonized standard to apply to meet these requirements?



EN 60950-1 has requirements for flammability and mechanical strength of guards 
well defined but EN 60950-1 itself is not in the list of harmonized standards 
for the MD.  It is applicable to the Low Voltage Directive and the MD does 
state that the requirements of the LVD apply.I'm wondering if the EN 953 
standard has the same requirements in the same level of detail or if they are 
at least consistent.



Thanks

-Dave



David P. Nyffenegger, PMP, SM-IEEE

Product Development Manager



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