Re: [PSES] For Your Information NRTL Directive Draft and Comment

[Ted Eckert]

OSHA has published an FAQ with a little more information, although Brian's 
comments appear to be on target. (I'm still interested in hearing what his cat 
has to say on the subject.)
https://www.osha.gov/dts/otpca/nrtl/nrtl_directive_faq.html

I would offer my own comments,  but they would likely be more inciteful than 
insightful. 

Ted Eckert
The opinions expressed are my own and they do not necessarily reflect those of 
my employer.

-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: Thursday, June 9, 2016 4:50 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] For Your Information NRTL Directive Draft and Comment

Nothing that follows necessarily represents the opinions or policies of my 
employer or my dog; and certainly not my cat. Did a quick browse (ok, not so 
quick - took several hours for the transformer temp to stabilize). But will 
have to clear with senior management before more of my thought-provoking, 
insightful (?) comments are formally submitted. But need to understand some 
things before these deep and meaningful thoughts are forwarded for the 
entertainment of the U.S. OSHA.

Appears that intent is to adopt/harmonize with ISO17025 and 17065 but with 
'national differences'. This is a good base-line for writing administrative 
law, but is effectively less demanding in both personnel competence and test 
equipment traceability and control (annex A) than that of some NRTLs that have 
audited my humble company lab.

Does OSHA want an NRTL to be an authoritative source, or only representative of 
the basic requirements per IEC/ISO? 

The term "Recognized" is defined per the physical site, but the text also uses 
'recognition' in the general sense for the company's personnel and labs. Is 
this intended to be same or something other than the "Accredited" definition in 
annex C?

R/S,
Brian

From: Kevin Robinson [mailto:kevinrobinso...@gmail.com]
Sent: Thursday, June 09, 2016 2:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] For Your Information NRTL Directive Draft and Comment

Hello All,

I wanted to advise you that the Draft NRTL Program Directive has been published 
on the OSHA website for public comment.  We encourage you all to review the 
draft directive and to submit any questions, comments, revisions or concerns 
you may have to OSHA.
 
In previous communications OSHA indicated that the Directive would be published 
in the Federal Register for comments.  Due to some complications in that 
process, and in the interest in sharing the draft Directive with you as soon as 
possible, we will not be publishing the Directive in or seeking comments 
through the Federal Register.
 
Please submit your comments no later than 11:59pm Eastern Time  Tuesday August 
9, 2016
 
To submit via email, send comments to nrtlprog...@dol.gov  Please title your 
submissions as “NRTL Directive Comment” .
 
To submit in hard copy, please use the following address:
 
OSHA
NRTL Program
Office of Technical Programs and Coordination Activities
200 Constitution Avenue NW, Room N3653
Washington, DC 20210
 
*** Please note, comments sent via U.S. Mail may take an additional ten days to 
be received due to security screening procedures.***
 
To submit comments via fax, please send comments to 202-693-1644.
 
Draft NRTL Directive: 
http://www.osha.gov/dts/otpca/nrtl/nrtl_draftdirective_public_comment.pdf
 
Additional information, including a list of Frequently Asked Questions may be 
found at: http://www.osha.gov/dts/otpca/nrtl/nrtlnews.html

-

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discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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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 
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For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

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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 


All emc-pstc postings are archived and searchable on the web at:
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formats), large files, etc.

Website:  

Re: [PSES] For Your Information NRTL Directive Draft and Comment

[Kevin Robinson]

Hi Brian,

You are correct that the NRTL Directive is 17025/17065 with "national
differences".  I am glad that was obvious in the first read as that was the
approach that we were trying to take.

I should have stated that the draft version of the NRTL directive is the
latest iteration of a document that was published almost 20 years ago
(loosely based off of Guide 25 & Guide 65).  The goal with this revision
was to "translate" existing OSHA policy into the common ISO 17025/17065
language that most of us speak as well as to add some clarity to some areas
that were previously ambiguous.  Our goal was not to make too many
significant changes.  More significant changes will be introduced in future
updates over the next several years

The Directive establishes the minimum performance standards that an NRTL
must meet in a given area, I would say that all of the current NRTLs exceed
these minimum standards in one or more areas.  Having worked for an NRTL,
and now working for the NRTL Program at OSHA I can say that the assessments
we conduct are probably one of the most technical assessments that a
laboratory will likely ever undergo, and I suspect that is the reason for
the high level of scrutiny that the NRTLs give to manufacturers and other
3rd party test labs.  I would say that we would lean more towards the
"authoritative source" rather that meeting only the basic ISO
requirements.  If we don't have a lot of clarity in certain areas, we are
likely working on the text for a future update  (Staff training and
qualification is one of those areas that we are looking hard at for future
updates).

"Recognition" is going to be roughly equivalent to "Accreditation"
throughout the document.   Looks like we have another definition to write.


Kevin

if you (or anyone) has any questions, feel free to contact me through my
"Official" channels:

Kevin Robinson
Director - Office of Technical Programs and Coordination Activities
NRTL Program
202-693-1911
robinson.ke...@dol.gov
or
nrtlprog...@dol.gov



On Thu, Jun 9, 2016 at 7:50 PM, Brian O'Connell 
wrote:

> Nothing that follows necessarily represents the opinions or policies of my
> employer or my dog; and certainly not my cat. Did a quick browse (ok, not
> so quick - took several hours for the transformer temp to stabilize). But
> will have to clear with senior management before more of my
> thought-provoking, insightful (?) comments are formally submitted. But need
> to understand some things before these deep and meaningful thoughts are
> forwarded for the entertainment of the U.S. OSHA.
>
> Appears that intent is to adopt/harmonize with ISO17025 and 17065 but with
> 'national differences'. This is a good base-line for writing administrative
> law, but is effectively less demanding in both personnel competence and
> test equipment traceability and control (annex A) than that of some NRTLs
> that have audited my humble company lab.
>
> Does OSHA want an NRTL to be an authoritative source, or only
> representative of the basic requirements per IEC/ISO?
>
> The term "Recognized" is defined per the physical site, but the text also
> uses 'recognition' in the general sense for the company's personnel and
> labs. Is this intended to be same or something other than the "Accredited"
> definition in annex C?
>
> R/S,
> Brian
>
> From: Kevin Robinson [mailto:kevinrobinso...@gmail.com]
> Sent: Thursday, June 09, 2016 2:10 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] For Your Information NRTL Directive Draft and Comment
>
> Hello All,
>
> I wanted to advise you that the Draft NRTL Program Directive has been
> published on the OSHA website for public comment.  We encourage you all to
> review the draft directive and to submit any questions, comments, revisions
> or concerns you may have to OSHA.
>
> In previous communications OSHA indicated that the Directive would be
> published in the Federal Register for comments.  Due to some complications
> in that process, and in the interest in sharing the draft Directive with
> you as soon as possible, we will not be publishing the Directive in or
> seeking comments through the Federal Register.
>
> Please submit your comments no later than 11:59pm Eastern Time  Tuesday
> August 9, 2016
>
> To submit via email, send comments to nrtlprog...@dol.gov  Please title
> your submissions as “NRTL Directive Comment” .
>
> To submit in hard copy, please use the following address:
>
> OSHA
> NRTL Program
> Office of Technical Programs and Coordination Activities
> 200 Constitution Avenue NW, Room N3653
> Washington, DC 20210
>
> *** Please note, comments sent via U.S. Mail may take an additional ten
> days to be received due to security screening procedures.***
>
> To submit comments via fax, please send comments to 202-693-1644.
>
> Draft NRTL Directive:
> http://www.osha.gov/dts/otpca/nrtl/nrtl_draftdirective_public_comment.pdf
>
> Additional information, including a list of Frequently Asked Questions may
> be 

Re: [PSES] For Your Information NRTL Directive Draft and Comment

[Brian O'Connell]

Nothing that follows necessarily represents the opinions or policies of my 
employer or my dog; and certainly not my cat. Did a quick browse (ok, not so 
quick - took several hours for the transformer temp to stabilize). But will 
have to clear with senior management before more of my thought-provoking, 
insightful (?) comments are formally submitted. But need to understand some 
things before these deep and meaningful thoughts are forwarded for the 
entertainment of the U.S. OSHA.

Appears that intent is to adopt/harmonize with ISO17025 and 17065 but with 
'national differences'. This is a good base-line for writing administrative 
law, but is effectively less demanding in both personnel competence and test 
equipment traceability and control (annex A) than that of some NRTLs that have 
audited my humble company lab.

Does OSHA want an NRTL to be an authoritative source, or only representative of 
the basic requirements per IEC/ISO? 

The term "Recognized" is defined per the physical site, but the text also uses 
'recognition' in the general sense for the company's personnel and labs. Is 
this intended to be same or something other than the "Accredited" definition in 
annex C?

R/S,
Brian

From: Kevin Robinson [mailto:kevinrobinso...@gmail.com] 
Sent: Thursday, June 09, 2016 2:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] For Your Information NRTL Directive Draft and Comment

Hello All,

I wanted to advise you that the Draft NRTL Program Directive has been published 
on the OSHA website for public comment.  We encourage you all to review the 
draft directive and to submit any questions, comments, revisions or concerns 
you may have to OSHA.
 
In previous communications OSHA indicated that the Directive would be published 
in the Federal Register for comments.  Due to some complications in that 
process, and in the interest in sharing the draft Directive with you as soon as 
possible, we will not be publishing the Directive in or seeking comments 
through the Federal Register.
 
Please submit your comments no later than 11:59pm Eastern Time  Tuesday August 
9, 2016
 
To submit via email, send comments to nrtlprog...@dol.gov  Please title your 
submissions as “NRTL Directive Comment” .
 
To submit in hard copy, please use the following address:
 
OSHA
NRTL Program
Office of Technical Programs and Coordination Activities
200 Constitution Avenue NW, Room N3653
Washington, DC 20210
 
*** Please note, comments sent via U.S. Mail may take an additional ten days to 
be received due to security screening procedures.***
 
To submit comments via fax, please send comments to 202-693-1644.
 
Draft NRTL Directive: 
http://www.osha.gov/dts/otpca/nrtl/nrtl_draftdirective_public_comment.pdf
 
Additional information, including a list of Frequently Asked Questions may be 
found at: http://www.osha.gov/dts/otpca/nrtl/nrtlnews.html

-

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 


All emc-pstc postings are archived and searchable on the web at:
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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.

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For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] For Your Information NRTL Directive Draft and Comment

[John Allen]

Thanks Kevin!!




John Allen | President | Product Safety Consulting, Inc.

Your Outsourced Compliance Department®

http://www.productsafetyinc.com

630-238-0188


From: Kevin Robinson 
Sent: Thursday, June 9, 2016 4:09 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] For Your Information NRTL Directive Draft and Comment

Hello All,

I wanted to advise you that the Draft NRTL Program Directive has been published 
on the OSHA website for public comment.  We encourage you all to review the 
draft directive and to submit any questions, comments, revisions or concerns 
you may have to OSHA.

In previous communications OSHA indicated that the Directive would be published 
in the Federal Register for comments.  Due to some complications in that 
process, and in the interest in sharing the draft Directive with you as soon as 
possible, we will not be publishing the Directive in or seeking comments 
through the Federal Register.

Please submit your comments no later than 11:59pm Eastern Time  Tuesday August 
9, 2016

To submit via email, send comments to 
nrtlprog...@dol.gov
  Please title your submissions as "NRTL Directive Comment" .

To submit in hard copy, please use the following address:

OSHA
NRTL Program
Office of Technical Programs and Coordination Activities
200 Constitution Avenue NW, Room N3653
Washington, DC 20210

*** Please note, comments sent via U.S. Mail may take an additional ten days to 
be received due to security screening procedures.***

To submit comments via fax, please send comments to 
202-693-1644.


Draft NRTL Directive: 
http://www.osha.gov/dts/otpca/nrtl/nrtl_draftdirective_public_comment.pdf

Additional information, including a list of Frequently Asked Questions may be 
found at: http://www.osha.gov/dts/otpca/nrtl/nrtlnews.html
-


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 
>

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)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas >
Mike Cantwell >

For policy questions, send mail to:
Jim Bacher >
David Heald >

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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 


All emc-pstc postings are archived and searchable on the web at:
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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)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

[PSES] For Your Information NRTL Directive Draft and Comment

[Kevin Robinson]

Hello All,


I wanted to advise you that the Draft NRTL Program Directive has been
published on the OSHA website for public comment.  We encourage you all to
review the draft directive and to submit any questions, comments, revisions
or concerns you may have to OSHA.



In previous communications OSHA indicated that the Directive would be
published in the Federal Register for comments.  Due to some complications
in that process, and in the interest in sharing the draft Directive with
you as soon as possible, *we will not be publishing the Directive in or
seeking comments through the Federal Register.*



*Please submit your comments no later than 11:59pm Eastern Time  Tuesday
August 9, 2016*



To submit via email, send comments to nrtlprog...@dol.gov
  Please title your
submissions as “NRTL Directive Comment” .



To submit in hard copy, please use the following address:



OSHA

NRTL Program

Office of Technical Programs and Coordination Activities

200 Constitution Avenue NW, Room N3653

Washington, DC 20210



*** Please note, comments sent via U.S. Mail may take an additional ten
days to be received due to security screening procedures.***



To submit comments via fax, please send comments to 202-693-1644.





Draft NRTL Directive:
http://www.osha.gov/dts/otpca/nrtl/nrtl_draftdirective_public_comment.pdf



Additional information, including a list of Frequently Asked Questions may
be found at: http://www.osha.gov/dts/otpca/nrtl/nrtlnews.html

-

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 


All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

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For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Warning Label: Disconnect from Mains

[Nyffenegger, Dave]

That is the procedure I prefer to follow on our products- try to stick with 
ANSI/ISO text-less pictograms on the product and include the pictogram and 
text/translations in the manuals.   And hope they include the manual in the 
glove box for the rental car.  It gives the co-pilot something to do.

-Dave

From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org]
Sent: Thursday, June 09, 2016 1:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Warning Label: Disconnect from Mains

Brian et al,

   This is a non-ending topic – hazard markings on equipment (note 
that WARNING is a specific key-word so I use the term hazard marking).

   It was a detailed discussion at the recent PSES ISPCE meeting in 
Anaheim (check the proceedings) .  The crux of the problem is that symbols are 
not generally understood without a lot of training and exposure/experience.  
The behavioral/human factors folks keep pointing this out and will be called in 
by the lawyers to condemn your markings if they don’t contain the needed 
textual information.  The US/ANSI standard properly implements a defendable 
approach which includes the words along with the pictograms.

   Do you feel comfortable with all of the symbols in the cockpit 
of any imported car?  We’re beginning to learn what they mean as Americans but 
it still is not always clear and difficult to quickly make changes while also 
driving under difficult conditions (how do you do in a rental car taking it out 
in a rainstorm after dark).

   This is a dilemma for companies that ship products worldwide.   
My ongoing recommendation for companies which design for the North American 
market and also ship worldwide is to use ANSI markings which include the 
pictograms then include each marking in the manual as a picture/illustration 
plus include the text in the body of the document in a way that it will be 
translated whenever the manual is translated into another language.

   Hope this helps.

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

p.perk...@ieee.org

From: Brian Gregory [mailto:brian_greg...@netzero.net]
Sent: Monday, May 4, 2015 1:25 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Warning Label: Disconnect from Mains


Hello again, Brian;

It sure does sound to me like you've done your basic diligence;  are the ANSI 
compliant symbols any different from the JIT compliant symbols?  Even when I 
was with an NRTL/NB organization, I was often irked by standards requirements 
that were not requested or considered useful by actual customers.

That being said, I've got the feeling that an informed answer would require a 
fairly detailed account of "getting dinged in Europe"

 Regards,

Brian Gregory
[Colorado]
720-450-4933


-- Original Message --
From: "Kunde, Brian" >
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Warning Label: Disconnect from Mains
Date: Fri, 1 May 2015 18:15:40 +
Thanks Doug and Colorado Brian. We liked the look of the new ANSI labels so we 
switch over all the warning labels on our products to this style a few years 
ago. But now we are getting dinged in Europe and have to replace the labels 
with symbols only or with the text in the language of the country we sold in. 
This is difficult to do because sometime we ship instruments to our sales 
offices in Europe but we don’t know what country it might be sold in until it 
is purchased.

Why don’t the EU just decide on one language like the Chinese did? (Those are 
fighting words).

We do explain the meaning of our warning symbols in the User’s Manual and the 
manuals are translated into different languages depending on the country it is 
sold and what our customers want. The users of our type of instruments are 
generally well educated (scientists, chemists, engineers, technicians, etc.) 
and most of the time they are happy with English only. But when other languages 
are requested we try to provide them translated copies fairly quickly. It’s 
very costly , too.

Most of our customers send their Users for training at our facility in the US. 
Classes are in English Only.

The other Brian

From: dougp01 [mailto:doug...@gmail.com]
Sent: Friday, May 01, 2015 1:48 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Warning Label: Disconnect from Mains

I agree with Colorado Brian. It seems that more and more, IEC-based standards 
are requiring a full explanation of symbols and warnings in the user 
documentation. As it turns out, many clients of mine leave the user manuals to 
the very last and they are usually very lacking. Where possible using symbols 
only is an economical option.

One exception to using just symbols might be in certain 

Re: [PSES] CSA/cUL Certification

[Pete Perkins]

Amund,

 

   This topic seems to have languished for some time and,
perhaps, you have resolved your question and are happily on your way toward
North American certification.  

 

   Since you mentioned multimedia A/V but not the particular EN
standard I presume that you have been working to certify to 60065.  If so,
you are quite well prepared to move ahead with the NA cULus certifications
since this is a harmonized standard with NA.  The battery power might raise
additional questions and the cert house can invoke other requirements that
are not explicitly stated in the harmonized standard to provide what they
consider to be the needed protection.  

 

   Depending upon your level of uncertainness you could consider
opening a preliminary investigation to get the requirements clearly laid out
before moving ahead  with the certification itself.  I have done this in the
past to ensure that  the client would not be surprised by the ongoing
certification discussion nor stopped in their tracks because of a difficult
non-compliance issue.  

 

   I hope this helps.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

  p.perk...@ieee.org

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: Tuesday, May 5, 2015 12:18 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CSA/cUL Certification

 

Product: Multimedia (audio/video) powered by 12V battery or AC/DC adapter.

 

Before even start making an approach towards CSA and UL, are there any
important technical issues that should be addressed before getting on?

I mean, the product is finished developed (for Europe market) and maybe a
kind of quick check will point out if CSA/cUL Certification is possible at
all .

 

Thanks.

 

Best regards

Amund

 

-


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
 >

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)  
List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators:
Scott Douglas  >
Mike Cantwell  > 

For policy questions, send mail to:
Jim Bacher  >
David Heald  > 


-

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 


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)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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For policy questions, send mail to:
Jim Bacher:  
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Re: [PSES] fire safety test methods for different country standards

[Richard Nute]

> This is my recollection of where 240VA came from and
> how it was used.

In a 1966 UL meeting with industry on the requirements in UL 478, the minutes 
report:

"Where high current is available at potentials down to about 2 volts, enough 
energy is available to melt and splatter metal from neck chains, eyeglass 
frames, watchbands, bracelets, rings, and other personal metal objects 
unintentionally out across hot bus or between such bus and ground by operators 
or servicemen, thereby giving rise to a severe burn hazard.  One of the 
industry representatives reported that his company reduces this hazard in such 
areas by limiting the apparent power available to 240 volt-amperes and the 
available energy to 10 Joules."

Given that 1 volt-ampere-second is 1 Joule.  If 10 Joules is the limit, 240 
volt-amperes cannot be available for longer than 0.04 milliseconds!  Because a 
Joule includes time, any source would eventually exceed 10 Joules!

To be fair, the final requirement did not include the 10-Joule limit, although 
it was applied to the energy stored in a capacitor.  

In IEC TC108, in 2003, the Japanese delegation reported that testing showed 
that 5 volts, 2 amperes (10 volt-amperes) is generally enough for necklaces to 
become hot (more than 100 degrees C) if they are slightly tensioned.

The 240 VA requirement did not do the job of protecting against a burn due to 
hot metal.  The standard was never tested to determine if the requirement was 
effective.


Rich

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formats), large files, etc.

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Re: [PSES] Warning Label: Disconnect from Mains

[Pete Perkins]

Brian et al,

 

   This is a non-ending topic – hazard markings on equipment
(note that WARNING is a specific key-word so I use the term hazard marking).


 

   It was a detailed discussion at the recent PSES ISPCE meeting
in Anaheim (check the proceedings) .  The crux of the problem is that
symbols are not generally understood without a lot of training and
exposure/experience.  The behavioral/human factors folks keep pointing this
out and will be called in by the lawyers to condemn your markings if they
don’t contain the needed textual information.  The US/ANSI standard properly
implements a defendable approach which includes the words along with the
pictograms.  

 

   Do you feel comfortable with all of the symbols in the
cockpit of any imported car?  We’re beginning to learn what they mean as
Americans but it still is not always clear and difficult to quickly make
changes while also driving under difficult conditions (how do you do in a
rental car taking it out in a rainstorm after dark).  

 

   This is a dilemma for companies that ship products worldwide.
My ongoing recommendation for companies which design for the North American
market and also ship worldwide is to use ANSI markings which include the
pictograms then include each marking in the manual as a picture/illustration
plus include the text in the body of the document in a way that it will be
translated whenever the manual is translated into another language.  

 

   Hope this helps.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

  p.perk...@ieee.org

 

From: Brian Gregory [mailto:brian_greg...@netzero.net] 
Sent: Monday, May 4, 2015 1:25 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Warning Label: Disconnect from Mains

 

 

Hello again, Brian; 

 

It sure does sound to me like you've done your basic diligence;  are the
ANSI compliant symbols any different from the JIT compliant symbols?  Even
when I was with an NRTL/NB organization, I was often irked by standards
requirements that were not requested or considered useful by actual
customers.

 

That being said, I've got the feeling that an informed answer would require
a fairly detailed account of "getting dinged in Europe"

 

 Regards,

 

Brian Gregory

[Colorado] 
720-450-4933



-- Original Message --
From: "Kunde, Brian" 
>
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Warning Label: Disconnect from Mains
Date: Fri, 1 May 2015 18:15:40 +

Thanks Doug and Colorado Brian. We liked the look of the new ANSI labels so
we switch over all the warning labels on our products to this style a few
years ago. But now we are getting dinged in Europe and have to replace the
labels with symbols only or with the text in the language of the country we
sold in. This is difficult to do because sometime we ship instruments to our
sales offices in Europe but we don’t know what country it might be sold in
until it is purchased. 

 

Why don’t the EU just decide on one language like the Chinese did? (Those
are fighting words). 

 

We do explain the meaning of our warning symbols in the User’s Manual and
the manuals are translated into different languages depending on the country
it is sold and what our customers want. The users of our type of instruments
are generally well educated (scientists, chemists, engineers, technicians,
etc.) and most of the time they are happy with English only. But when other
languages are requested we try to provide them translated copies fairly
quickly. It’s very costly , too.

 

Most of our customers send their Users for training at our facility in the
US. Classes are in English Only. 


The other Brian

 

From: dougp01 [mailto:doug...@gmail.com] 
Sent: Friday, May 01, 2015 1:48 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] Warning Label: Disconnect from Mains

 

I agree with Colorado Brian. It seems that more and more, IEC-based
standards are requiring a full explanation of symbols and warnings in the
user documentation. As it turns out, many clients of mine leave the user
manuals to the very last and they are usually very lacking. Where possible
using symbols only is an economical option. 

 

One exception to using just symbols might be in certain industries where
using an ANSI/IEC compliant labeling system is required.  ‎In this case some
verbiage is required. The text should simply describe the problem and how to
avoid it. Nothing more. Proper use of the keywords Danger, Warning, and
Caution are also essential.  Since overstating the hazard is not advisable.

 

All the best, Doug

 

 


From: Brian Gregory

Sent: Friday, May 1, 2015 11:31 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG 

Re: [PSES] fire safety test methods for different country standards

[Richard Nute]

> The 240VA "Energy Hazard" was not a
> consideration for the protection against Fire but a limit
> value for accessible parts by the User.

The energy hazard requirement (in the 950-series standards) is that the 
conductors shall not be bridged by the test finger (which has a spherical tip). 
 If the conductors are on a planar circuit board, the conductors cannot be 
bridged by the spherical tip.

The requirement does not specify that the conductors must not be accessible, 
although this is the conventional interpretation of the requirement. 


Rich

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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 


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)
List rules: http://www.ieee-pses.org/listrules.html

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For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] EU OJ today

[Michael Derby]

Thanks Charlie.

 

I think you make a good point.

 

The fact is that for the EMC Directive; using a harmonised standard on a 
presently valid OJ gives you presumption of conformity.

Of course need to do a risk assessment that nothing has been missed out by your 
device being ahead of the standards; but generally you can apply the standard 
and relax a little.

 

If you do not use harmonised standards, then you need to write yourself a 
justification of what you did and why you did it.   (See ‘note 1’ below)

(use of an EMCD Notified Body is never mandatory, of course)

 

So, if you take the argument that the arrival of the new OJ makes the old one 
void; then you could use the harmonised standard from the old EMCD OJ, which we 
could say no longer gives you immediate ‘presumption of conformity’ and write 
yourself a justification (‘note 1’) that you are doing it because the same 
standard was accidentally left out of the new OJ.

 

Job done.

 

I feel like market surveillance has got more to worry about than chasing that 
little problem around and around in circles.

 

 

Michael.

 

 

 

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 08 June 2016 18:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU OJ today

 

Scott

 

No argument with your comments, except that I would expect you’ll be a long 
time waiting for a “whoops, we got it wrong, please ignore what we published in 
the Official Journal on the 13th May, but please don’t ignore anything else we 
have published in it” – there’s no mechanism for it, all that can be done is a 
new one published.

 

The reality is that you need a way forward, and whilst HS provide a 
“presumption of conformity”, you don’t *need* a “presumption of conformity” 
before you CE mark – so whilst the OJ listing is not fully correct, the 
Directive already provides an acceptable route forward.

 

I’m sure the corrected list will be published as soon as possible, but in the 
meantime you need a way forward, and that was my suggestion.

 

Regards

Charlie

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 08 June 2016 17:58
To: Charlie Blackham
Cc: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] EU OJ today

 

Hi Charlie,

 

According to their guide, we can follow the old list if no new list is 
published for the new EMCD.  However the old list for old EMCD is not valid due 
to the 1st list for the new EMCD.  The new list is for new EMCD.  EU should 
notify the public for next step - awaiting for new one and apply the last one 
while new list is being prepared.

 

HS is the key for manufacturers to do presumption of conformity using module A 
route.

 

 

Regards,

 

Scott

 

 

On 9 Jun 2016, at 12:17 AM, Charlie Blackham  > wrote:

 

Scott

 

Remember EN 50561-1:2013 will only supersede EN55022 for equipment that is 
within its scope, i.e. PLT/PLC.

 

 

 
http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/electromagnetic-compatibility/index_en.htm
 is actually listing the OJ C 173 of 13/05/2016  as well as the previous OJ C 
014 of 16/01/2015 

 

As Harmonised Standards are not mandatory for the EMCD, I would just ignore the 
13 May edition, as it’s got some “known” errors in it, and follow the standards 
and DOCOPOCOSS listed in the 16 Jan edition.

 

Regards

Charlie

 

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 08 June 2016 13:15
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] EU OJ today

 

Is there any progress about the latest update that both EN 55022 and EN 55032 
will be replaced by EN EN 50361and EN 55013 removed?

 

Scott

 

 

On 14 May 2016, at 2:27 AM, John Allen <  
john_e_al...@blueyonder.co.uk> wrote:

 

“Someone” needs a really good “talking to”, I would think. :(

 

John E Allen

W.London, UK

 

From: Charlie Blackham [  
mailto:char...@sulisconsultants.com] 
Sent: 13 May 2016 19:11
To:   EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU OJ today

 

Martin

 

>I can't see EN 55022 or EN 55032 listed under the EMCD.
>Did I miss something?

 

No, they’re missing.

 

It has been noted and I understand that the Commission EMC consultant is aware 
and presume that he is following up with the Commission.

 

Regards

Charlie

 

From: Martin E. Cormier [  
mailto:mcorm...@matrox.com] 
Sent: 13 May 2016 18:32
To:   EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU OJ today

 

Thank you, Mr. Pickard.

But, it must be time for me to leave for the weekend: I can't see EN 55022 or 
EN 55032 listed under the EMCD.

Did I 

Re: [PSES] fire safety test methods for different country standards

[Kunde, Brian]

Ralph,

This might be true but that is not how we saw it way back when. The 240VA 
"Energy Hazard" was not a consideration for the protection against Fire but a 
limit value for accessible parts by the User. We still today consider 
accessible circuits, regardless of the voltage, to be "Hazardous Live" if the 
circuit exceeds 240VA. This requirement is not specifically called out in our 
working safety standard (IEC/EN 61010-1 for Laboratory Equipment) but we still 
take this condition under consideration especially with products that exposes 
the user to high currents at low voltages such as Electrode Furnaces (similar 
to a welder).

In Tempest Computers which fell under the IEC950, the hard drives had to be 
made removable so they could be easily taken with during an invasion or 
destroyed in a giant shredder machine. The opening in the front of the computer 
gave the User access to a small backplane card and the data and power 
connectors for the hard drive. The backplane had to be limited to less than 
240VA if the User could touch it.  Fire was a completely different evaluation.

My step dad was working on a car a got his metal watch band between the starter 
solenoid and the chassis. It instantly welded his watch to the car and turned 
the band into a glowing red hot heating element within a second. He was able to 
break it loose and get the watch off but not before he was badly burned. Almost 
required skin grafts. However, according to most safety standards, 12 volts at 
high current is NOT considered hazardous live and does not limit access to 
Users. Yes, it is a fire hazard but I don't think that is where the 240VA 
requirement comes from.

Like the watch band, I have heard where people have reached inside of a piece 
of electronic gear and shorted out a circuit with their wedding ring. If this 
condition is possible, I believe the circuit would have to be limited to 240VA.

This is my recollection of where 240VA came from and how it was used. I do not 
have any current documented support for it use today. But we still consider it 
for circuits accessible to the User to determine an Energy Hazard.

The Other Brian

-Original Message-
From: Ralph McDiarmid [mailto:ralph.mcdiar...@schneider-electric.com]
Sent: Wednesday, June 08, 2016 4:31 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] fire safety test methods for different country standards

So, for the protection against FIRE, we have two energy rates, 100VA and 240VA, 
used across quite a number of standards, and the units are wrong.  Should be 
Watts.

Ralph McDiarmid
Product Compliance
Engineering
Solar Business
Schneider Electric




*Please consider the environment before printing this e-mail



-Original Message-
From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
Sent: Wednesday, June 08, 2016 1:27 PM
To: Ralph McDiarmid ; 
EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] fire safety test methods for different country standards

EN 60950-1:2006  2.5  uses 100 VA for LPS and is also referenced for fire 
enclosure requirements in section 4.7.2.1.

-Dave

-Original Message-
From: Ralph McDiarmid [mailto:ralph.mcdiar...@schneider-electric.com]
Sent: Wednesday, June 08, 2016 3:11 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] fire safety test methods for different country standards

Hi Chuck,

A poor choice of words on my part.  I should have written, "in most of the 
standards I have worked in".   Those include CSA107.1, UL1741, UL1012, and 
IEC62109-1

The 240VA (I think they meant 240W) must have come from some base standard as a 
normative reference.  I don't know what is special about that number, but some 
committee somewhere may have concluded that power (rate of energy) below that 
threshold was unlike to be a source of ignition.  I've seen 30V and 8A used to 
define an energy limited, extra-low voltage circuit. (UL calls that a Class 2 I 
think).   The product of 8A and 30V gives 240VA as a third criterion.   I'm not 
sure it's that simple though.

Regards,

Ralph McDiarmid
Product Compliance
Engineering
Solar Business
Schneider Electric





*Please consider the environment before printing this e-mail



-Original Message-
From: Chuck August-McDowell [mailto:chu...@meyersound.com]
Sent: Wednesday, June 08, 2016 11:22 AM
To: Ralph McDiarmid 
Subject: RE: [PSES] fire safety test methods for different country standards

Hi Ralph,

I live in the IEC/EN/UL 60065 standard world.

Could you point at "most standards appear to limit rate of energy transfer 
(e.g. 240W)" standard?
IEC/EN/UL 62368-1?
IEC/EN/UL 60950-1?

Thank you,

Chuck McDowell
Compliance Specialist
Meyer Sound Laboratories Inc.


-Original Message-
From: Ralph McDiarmid [mailto:ralph.mcdiar...@schneider-electric.com]
Sent: Wednesday, June 08, 2016 9:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] fire safety test methods for