Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Nyffenegger, Dave
Thanks for reminding me.  I remember now, the published OJ harmonized standards 
lists will have the in force date listed for each standard.
Thanks
-Dave

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Monday, July 20, 2015 9:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

In message
, dated Mon, 20 Jul 2015, "Nyffenegger, Dave" 
 writes:

>At the risk of going off topic,  I don't see anything identified at 
>http://eur-lex.europa.eu/homepage.html  for harmonized standards for 
>the new 2014/30/EU EMC and 2014/35/EU LVD directives that go into force 
>April 2016.  Time to start getting prepared.  Am I missing something or 
>is it just too soon for them to be published?

You are not missing anything. The reason you haven't seen anything yet is 
complicated and largely irrelevant. The lists will not change significantly due 
to the changes of Directive alone.
>
>The same line of thinking could apply as to whether or not to start 
>using newer standards sooner than later.  A benefit would be not having 
>to go through the cost of additional testing to a newer standard only 
>months later.

You almost never *have* to re-test to a new standard only months later; there 
is a transition period which is normally 36 months. You can
*choose* to apply a new edition of a standard as soon as it is notified in the 
Official Journal, but you don't have to.
--
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] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread John Woodgate
In message 
utlook.com>, dated Mon, 20 Jul 2015, "Nyffenegger, Dave" 
 writes:


At the risk of going off topic,  I don't see anything identified at 
http://eur-lex.europa.eu/homepage.html  for harmonized standards for 
the new 2014/30/EU EMC and 2014/35/EU LVD directives that go into force 
April 2016.  Time to start getting prepared.  Am I missing something or 
is it just too soon for them to be published?


You are not missing anything. The reason you haven't seen anything yet 
is complicated and largely irrelevant. The lists will not change 
significantly due to the changes of Directive alone.


The same line of thinking could apply as to whether or not to start 
using newer standards sooner than later.  A benefit would be not having 
to go through the cost of additional testing to a newer standard only 
months later.


You almost never *have* to re-test to a new standard only months later; 
there is a transition period which is normally 36 months. You can 
*choose* to apply a new edition of a standard as soon as it is notified 
in the Official Journal, but you don't have to.

--
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] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Nyffenegger, Dave
At the risk of going off topic,  I don't see anything identified at 
http://eur-lex.europa.eu/homepage.html  for harmonized standards for the new 
2014/30/EU EMC and 2014/35/EU LVD directives that go into force April 2016.  
Time to start getting prepared.  Am I missing something or is it just too soon 
for them to be published?  

The same line of thinking could apply as to whether or not to start using newer 
standards sooner than later.  A benefit would be not having to go through the 
cost of additional testing to a newer standard only months later.

-Dave

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Monday, July 20, 2015 5:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

In message <85d45e15f71741059f90847883213...@thhste15d1be4.hs20.net>,
dated Mon, 20 Jul 2015, Charlie Blackham 
writes:

>The discussion concluded that whilst final responsibility would always 
>rest with the manufacturer (and Notified Body if used), that using the 
>latest state of the art standard would be perfectly acceptable or 
>perhaps even the better decision.
>
> 
The committee that wrote the referencing standard decided to use dated 
references, and that was voted on and accepted. So how can it be a 'better 
decision' to ignore that?

While the advantages of dated and undated references are pretty evenly 
balanced, the main point in favour of dating is that the user ***is in no doubt 
which edition of the reference standard to apply***. Teaching people to 
disregard that seems extremely perverse.
--
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] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread John Woodgate
In message <85d45e15f71741059f90847883213...@thhste15d1be4.hs20.net>, 
dated Mon, 20 Jul 2015, Charlie Blackham  
writes:


The discussion concluded that whilst final responsibility would always 
rest with the manufacturer (and Notified Body if used), that using the 
latest state of the art standard would be perfectly acceptable or 
perhaps even the better decision.


 
The committee that wrote the referencing standard decided to use dated 
references, and that was voted on and accepted. So how can it be a 
'better decision' to ignore that?


While the advantages of dated and undated references are pretty evenly 
balanced, the main point in favour of dating is that the user ***is in 
no doubt which edition of the reference standard to apply***. Teaching 
people to disregard that seems extremely perverse.

--
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] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Charlie Blackham
David

I’ll offer a slightly different angle.

Newer standards, whilst not referenced in the product standard, do represent 
“state of the art”.

There was a discussion recently in the R&TTE compliance association related to 
the fact that several product type EN 301 489-X standards referenced EN 301 
489-1 version 1.8.1 or even 1.4.1.
The discussion concluded that whilst final responsibility would always rest 
with the manufacturer (and Notified Body if used), that using the latest state 
of the art standard would be perfectly acceptable or perhaps even the better 
decision.

I’m not suggesting that the lab did the correct thing, but the choice of basic 
EMC standard is only a part of demonstrating EMC compliance and a smaller part 
of the whole CE marking compliance jigsaw and if that was the only area that 
wasn’t perfect, then you would be in a pretty good place ☺

Regards
Charlie


From: Dave Heald [mailto:emcp...@gmail.com]
Sent: 20 July 2015 19:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

Hi John,
  I agree, and this has been my stance with the lab and with our ODM who 
contracted the lab & had the testing done.

Also, the problem doesn't stop with the 55022 reference - for *EVERY* dated (& 
thus "specific") basic EMC standard that has a newer version, the newer 
standard was used.  For a few, the test method has changed, and this is the 
sticking point - the lab wants us to pay for any delta testing to the old 
standards that they technically should have used in the first place.

If it is generally acceptable or "good enough" to use the newer standards, I 
don't want to stand in the way of product release while we get the testing 
re-done (we know what happens to employees that take stands on technicalities 
that aren't important in the grand scheme of things & it's not good)
However, I also don't want to give in without some input from other experts on 
how important this is to compliance assessment.

Thanks,
-David

On Mon, Jul 20, 2015 at 12:18 PM, John Woodgate 
mailto:j...@jmwa.demon.co.uk>> wrote:
In message 
mailto:ca%2bnn315eg5krv5rgtjbmfqbhkancteqsbuwjkhobpopurog...@mail.gmail.com>>,
 dated Mon, 20 Jul 2015, Dave Heald 
mailto:emcp...@gmail.com>> writes:
Even though the EN 301 489-1 standard's Normative References list specific 
dates (and according to the standard, *only* those versions of the standard 
should be used), is it OK to use the most recent versions of the Reference 
standards to claim compliance?

If a reference is dated, that edition must be used. If it is not dated, the 
latest edition must be used.
--
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] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread John Woodgate
In message 
, 
dated Mon, 20 Jul 2015, Dave Heald  writes:


If it is generally acceptable or "good enough" to use the newer 
standards, I don't want to stand in the way of product release while we 
get the testing re-done (we know what happens to employees that take 
stands on technicalities that aren't important in the grand scheme of 
things & it's not good)
However, I also don't want to give in without some input from other 
experts on how important this is to compliance assessment.


It's impossible to generalize; there are three cases:

1. The new edition is *exactly* the same as the earlier one for every 
cross-reference in the referencing standard;


2. The new edition is *exactly* the same for some cross-references, but 
not others;


3. The new edition is a complete re-write, so that the cross-references 
in the referencing standard are meaningless.


Case 1. is the only one that doesn't spell trouble. *exactly* means 
word-for-word and includes any Notes or examples.

--
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] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Dave Heald
Hi John,
  I agree, and this has been my stance with the lab and with our ODM who
contracted the lab & had the testing done.

Also, the problem doesn't stop with the 55022 reference - for *EVERY* dated
(& thus "specific") basic EMC standard that has a newer version, the newer
standard was used.  For a few, the test method has changed, and this is the
sticking point - the lab wants us to pay for any delta testing to the old
standards that they technically should have used in the first place.

If it is generally acceptable or "good enough" to use the newer standards,
I don't want to stand in the way of product release while we get the
testing re-done (we know what happens to employees that take stands on
technicalities that aren't important in the grand scheme of things & it's
not good)
However, I also don't want to give in without some input from other experts
on how important this is to compliance assessment.

Thanks,
-David

On Mon, Jul 20, 2015 at 12:18 PM, John Woodgate 
wrote:

> In message <
> ca+nn315eg5krv5rgtjbmfqbhkancteqsbuwjkhobpopurog...@mail.gmail.com>,
> dated Mon, 20 Jul 2015, Dave Heald  writes:
>
>  Even though the EN 301 489-1 standard's Normative References list
>> specific dates (and according to the standard, *only* those versions of the
>> standard should be used), is it OK to use the most recent versions of the
>> Reference standards to claim compliance?
>>
>
> If a reference is dated, that edition must be used. If it is not dated,
> the latest edition must be used.
> --
> 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
>
>
> -
> 
> 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://www.ieee-pses.org/list.html (including how to
> unsubscribe)
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>
> For help, send mail to the list administrators:
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> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher:  
> David Heald: 
>

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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread John Woodgate
In message 
, 
dated Mon, 20 Jul 2015, Dave Heald  writes:


Even though the EN 301 489-1 standard's Normative References list 
specific dates (and according to the standard, *only* those versions of 
the standard should be used), is it OK to use the most recent versions 
of the Reference standards to claim compliance?  


If a reference is dated, that edition must be used. If it is not dated, 
the latest edition must be used.

--
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] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Charlie Blackham
David

Strictly speaking there’s no conflict as the only relevant standard is EN 301 
489-1. The fact that EN 55022 is also listed in the OJ is coincidental  - the 
applicable standard, EN 301 489-1, is referencing a product standard for 
emissions rather than, say, a basic standard as is the case for immunity.

That said, I don’t think you would have any issue with using the 2010 version 
of EN 55022, but it should be noted somewhere in the report that it is a 
deviation.

Regards
Charlie

From: Dave Heald [mailto:emcp...@gmail.com]
Sent: 20 July 2015 18:30
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 
489-1 v1.9.2

I have a technical question on the OJ vs References in standards.

Here is the conflict:  EN 301 489 -1 V1.9.2 is the "current standard" in the 
R&TTE OJ.

However, 301 489-1 V 1.9.2, it lists several "specific" standards in it's 
Normative References chapter... and one of these standards (EN 55022: 2006 + A1 
(2007) expired in the R&TTE OJ in 2013.

Even though the EN 301 489-1 standard's Normative References list specific 
dates (and according to the standard, *only* those versions of the standard 
should be used), is it OK to use the most recent versions of the Reference 
standards to claim compliance?


Any advice on this?


Thanks & Best Regards,
-David Heald
-


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[PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

2015-07-20 Thread Dave Heald
I have a technical question on the OJ vs References in standards.

Here is the conflict:  EN 301 489 -1 V1.9.2 is the "current standard" in
the R&TTE OJ.

However, 301 489-1 V 1.9.2, it lists several "specific" standards in it's
Normative References chapter... and one of these standards (EN 55022: 2006
+ A1 (2007) expired in the R&TTE OJ in 2013.

Even though the EN 301 489-1 standard's Normative References list specific
dates (and according to the standard, *only* those versions of the standard
should be used), is it OK to use the most recent versions of the Reference
standards to claim compliance?


Any advice on this?


Thanks & Best Regards,
-David Heald

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