Re: HCFC Ban in the EU Effective 1/1/01?
William, This is a truly valuable forum!!! Thanks for your prompt email response. Perhaps the updated version is EC No. 2037/2000. I was sent a copy of Regulation (EC) No 2037/2000 of the European Parliament and the Council of 29 June 2000 on substances that deplete the ozone layer and Article 5 of that document does seem to state that HCFCs in refrigeration and air-conditioning equipment produced after 31 December 2000 is prohibited effective 1 January 2001. Regards. Tin In a message dated Fri, 22 Dec 2000 4:46:38 AM Eastern Standard Time, William McCafferty wmccaffe...@npeurope.com writes: --0__=x7OcnNc0m8h35qI3IBjHkmA4aa8FIp8djOchKBnD0ryy77990Hk0S9NA Content-Type: text/plain; charset=us-ascii Content-Disposition: inline Dear Tin There is indeed a ban on new equipment entering the EU from 01.01.2001. The original EU Regulation, which implements the requirements of the Montreal Protocol, was called EC 3093/94. this has since been replaced with an updated version but I do not have the reference to hand. Although the ban comes into force in 2001 it has already been implemented in Sweden and Denmark in 1998 and Germany in 2000. The ban only applies to new equipment. It does not apply to second hand or used equipment as long as the date of manufacture is before the cut off date. If you need any more detailed information give me a call or send an email. Slaint --0__=x7OcnNc0m8h35qI3IBjHkmA4aa8FIp8djOchKBnD0ryy77990Hk0S9NA Content-Type: text/plain; charset=gb2312 Content-Disposition: inline ¨¦ William McCafferty Safety Quality Manager Nikon Precision Europe Tel:00 44 (0)1506 405465 Mobile: 00 44 (0)411 208 988 Fax:00 44 (0)1506 464 411 tinb...@aol.com on 12/21/2000 09:51:21 PM Please respond to tinb...@aol.com To: emc-p...@majordomo.ieee.org cc:(bcc: William McCafferty/LIV/NPEUROPE.COM) Subject: HCFC Ban in the EU Effective 1/1/01? --0__=x7OcnNc0m8h35qI3IBjHkmA4aa8FIp8djOchKBnD0ryy77990Hk0S9NA Content-Type: text/plain; charset=us-ascii Content-Disposition: inline Environmental Professionals, Is anyone familiar with a Common Position EC #19/1999, Official Journal of European Commision, 4/5/99. I was told that the EC#19/1999 is a European regulation that prohibits the shipment of equipment containing HCFC into the EU after January 1, 2001. I am curious whether this EC #19/1999 is truly a European Regulation or Directive and if so, does it really prohibit HCFC to be shipped into the EU after January 1, 20001. Regards Tin --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --0__=x7OcnNc0m8h35qI3IBjHkmA4aa8FIp8djOchKBnD0ryy77990Hk0S9NA-- --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
HCFC Ban in the EU Effective 1/1/01?
Environmental Professionals, Is anyone familiar with a Common Position EC #19/1999, Official Journal of European Commision, 4/5/99. I was told that the EC#19/1999 is a European regulation that prohibits the shipment of equipment containing HCFC into the EU after January 1, 2001. I am curious whether this EC #19/1999 is truly a European Regulation or Directive and if so, does it really prohibit HCFC to be shipped into the EU after January 1, 20001. Regards Tin --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Re: Getting Started
Chris, I am interested in knowing the basis of your response to items 1 and 2, as it is contrary to my understanding of the EMC Directive. Specifically, it was my understanding that unless the manufacturer is following ALL of the requirements specified in Standard(s), that they must follow the TCF route and obtain a report or certificate from a Competent Body, as outlined per Article 10(2) of the EMC Directive states that In the case of apparatus for which the manufacturer has not applied, or has applied only in part, the standards referred to in Article 7(1) or failing such standards, the manufacturer or his authorized respresentative established within the Community shall hold at the disposal of the relevant competent authorities, as soon as the apparatus is placed on the market, a technical construction file. This file shall describe the apparatus. and include a technical report or certificate, one or other obtained from a competent body. If a manufacturer uses their engineering rationale to waive all of the EMC testing specified in standards, they have only applied part of the standard and as such, the EMC Directive would require that the rationale and the TCF be reviewed by a European EMC Competent Body. Furthermore, I believe that UK's DTI is consistent with EMC Directive's philosophy outlined in Article 10(2). In the October 1992 DTI's Guidance Document on the Preparation of a Technical Construction File as required by EC Directive 89/336, Section 1.3 outlines the Circumstances where the TCF might be used, ii) For apparatus where harmonized standards exist but the manufacturer applied that standard in part only, eg where a manufacturer can justify that a particular type of apparatus complies with the protection requirements of the Directive without performing tests to any or all of the phenomena described in the relevant harmonized specifications. I am interested in learning whether UK has established an updated position which allows manufacturer to waive testing (altogether) and still self-declare conformity to the EMC Directive through the standards route? Regards Tin In a message dated Sun, 1 Oct 2000 2:58:00 AM Eastern Daylight Time, cdup...@cs.com writes: In a message dated 29/09/00 15:43:06 GMT Daylight Time, fr...@amcomm.com writes: I'm just getting started in the world of EMI and would like to ask a few questions. I'm not sure if I should be going the TCF route or the Standards Route. The company that I work for manufactures products which have many variants. 1) Is it EC law that a manufacturer must perform EMI testing before applying the CE mark? No. In the UK, the Electromagnetic Compatibility Regulations don't require testing if you follow the Standards Route. But you must make the Declaration of Compliance before you use the CE mark and be able to provide evidence of compliance to the regulatory authorities when challenged. This can be test results, or detailed analysis, or statements etc. Again, 'testing' per se is not a particular requirement. For instance, a simple resistive convection heater could be stated to Comply because there are no non-linear elements to produce or be affected by EMI. No need to test. Having said that, testing is the only absolutely certain way of proving compliance. And don't forget that the Regulations are Criminal Law! 2) If a manufacturer follows the Standards Route, does EC law require each variant to be tested? No. There is nio statutory need to test. But you need to provide firm evidence, when asked, that the variant is not significantly different in EMC terms to the original subject of the Compliance Declaration. A detailed technical statement would suffice, but must be accurate and traceable. Again, we are taking Criminal Law here! 3) If, when testing, the limit is exceeded, can the CE mark still be applied? No. The CE mark means that ALL relevant Directives have been complied with. If EMC limits are exceeded when using the Standards Route then it doesn't comply with the EMC Directive. If the product can't be produced without exceeding the limits, then the TCF route to compliance should be used. 4) Are the services of a Competent Body required in order to put together a TCF or can the manufacturer do that on his own? A TCF is only valid when qualified by a Competent Body. A manufacturer can build his own TCF, or an external Test House/Competent Body can build it, but at the end of the day the Competent Body signs/takes responsibility for it. Think of a TCF as a new EMC standard which relates ONLY to that particular product. A simple rule is 'if it complies with the Standards then use the Standards Route, if it doesn't then use the TCF route. Hope is useful. Chris Dupres Surrey, UK. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list.
Re:GFCI equivalent in Japan
Tony, You raised a very good discussion. I have also seen a few Japanese customer specifications (and even some European customer specifications)with 30 mA GFCI, usually with a 0.1 second trip time. Based on my research, the 30 mA GFCI, 0.1 second is based on JIS C 8371 Residual Current Operated Circuit Breaker. Now, whether or not 30 mA GFCI would be considered to be suitable for personnel protection depends a lot on who you speak with? If you ask the compliance safety engineers in the U.S., they'd say Nope, 30 mA GFCIs are not for personnel protection, at least not per UL 943, which defines shock hazard as A shock hazard is considered to exist at a part of a ground-fault circuit-interrupter if: A) There would be current of 6 mA or more in a resistance of 500 ohms connected between the part in question and the grounded supply conductor, and B) The device would not operate to open the circuit to the 500-ohm resistor within the time allowed in paragraph 23.1.. For the Japanese (and even some Europeans), 30 mA, 0.1 sec. Residual Current Devices may very well be considered suitable for personnel protection because the trip current and trip time fall within Zone 2 of IEC 479-1, Usually no harmful physiological effects. Being trained under the U.S. philosophy, I probably will not admit publicly that 30 mA GFCIs is adequate for personnel protection; although it is comforting to know that if someone should expose themselves to a line to ground condition, that the 30 mA, 0.1 sec. GFCI should technically trip before any harmful physiological effect results, at least per IEC 479-1. Disclaimer: Electric shock is a very tricky science, it is not only dependent upon current and exposure time, but body impedance, frequency, location of body exposure, etc. Tin --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Re: S-Mark for industrial equipment
KISCO has recently changed their name to KOSHA. http://www.kosha.or.kr/english/english.htm --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Re: Warning label sizing.
Kyle, My response would be .08 inch minimum type size for the letter height in the laser label. per the Informative Annex B of ANSI Z535.4. RATIONALE/BASIS: Section 4.7.1 of the American National Standard Z136.1-1993, Safe Use of Lasers states Design of Signs. Sign dimensions, letter size and color, etc., shall be in accordance with American National Standard Specification for Accident Prevention Signs, ANSI Z535 Series (latest revision thereof). Figures 1a and 1b show sample signs for Class 2, Class 3a, Class 3b and Class 4 laser or laser systems. ANSI Z535.4-1998 Product Safety Signs and Labels has a section in Informative Annex B.3.2.13 addressing 'minimum letter height calculations'. B3.2.13 Minimum letter height calculations. Type size is defined in points, a term that was used to describe the space required for lead type characters. Point sizes measure from the top of the capital letters to the bottom of the lower case letters with descenders (e.g., the bottom of the letter g or j etc.). One point equals 0.01384 inches, or approximately 1/72 of an inch. Although type faces vary slightly, a practical guide for defining type size is based on using the capital letter H for measurement purposes. Since the character H has no descender, it is possible to use a conversion factor of 0.01 inches - 1 point of type size. Thus, 12 point type yields a capital H approximately 0.12 inches high. For metric purposes, use a conversion factor of 3.9 points = 1 mm of height for a capital H. Recommended Letter Heights For Favorable Reading Conditions: 2 Feet or Less: Viewing Distance (in.)/150 2 To 20 Feet: Viewing Distance ((ft.-2) X (.03)) +.16 Over 20 Feet: Viewing Distance (ft.)/28.6 Recommended Letter Heights For Unfavorable Reading Conditions (All Distances): Viewing Distance (ft.)X 0.84 Table - Examples of word message letter heights and minimum safe viewing distances. (Note: Only the first row is reflected below). Minimum Safe Viewing Distance - 1 Foot or less Minimum Letter Height for Favorable Reading Conditions - .08 inches Recommended Letter Height for Favorable Reading Conditions - .08 inches Recommended Letter Height for Unfavorable Reading Conditions - .084 inches (Note: Only the first row is reflected above). *.08 inch type is the suggested minimum type size for use on product safety signs. Regards. Tin In a message dated 10/1/99 11:43:04 AM Pacific Daylight Time, kyle.eh...@lsil.com writes: Greetings, We have been lucky in the past, but with the real estate crunch that comes with smaller products, its getting more difficult to find space to apply a warning label. For example, a 'Class 1 Laser Product'. Just how tiny can the text/graphics in a label be and still comply? Kyle - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: LVD and notified bodies
Kevin, I had that same issue with I was working with the EMC Directive. In fact, I had five very different EMC test plan signed-off by different EMC Competent Bodies. The bottom line is that interpretations do vary between Notified Bodies. The way they get around this issue, at least with EMC Directive, is that once a project has been started by one Competent Body, another one would generally not agree to take over the project. In fact, we were required to submit a Declaration of Submittal to two of our Competent Bodies stating that the product submitted were not being submitted to any other Competent Body. So my response to your question of Who rules?... It's whichever Notified Body you contracted to do the work. Once a certificate is issued by one Notified Body, another Notified Body technically cannot challenge that certification. In retrospect, I am quite in favor of this because it prevents a manufacturer from 'shopping around for the answers they want to hear'.Once the manufacturer selects the Competent or Notified Body, they should live by that decision or start with another, from scratch. The Competent Body or Notified Body should not be expected to 'adopt' the philosophy of another Competent or Notified Body. Tin In a message dated 9/2/99 1:26:16 PM Pacific Daylight Time, harr...@dscltd.com writes: Subj: LVD and notified bodies Date: 9/2/99 1:26:16 PM Pacific Daylight Time From: harr...@dscltd.com (Kevin Harris) Sender:owner-emc-p...@majordomo.ieee.org Reply-to: harr...@dscltd.com (Kevin Harris) To:emc-p...@ieee.org (EMC-PSTC (E-mail)) Hello Group, Here are some LVD protocol issues for you. If you had a product type tested by one notified body then at some later time a second notified body (doing market surveillance) determines that they feel the product does not meet the LVD ( We are assuming the type tested product was the same as the one examined by the second notified body i.e. This is an interpretation issue only) Who rules here? Can the second notified body deny the first's interpretation? Who could give an official interpretation? (the Commission?) Thanks Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 1645 Flint Road Downsview, Ontario CANADA M3J 2J6 Tel 416 665 8460 Ext. 2378 Fax 416 665 7753 - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: EU Official Languages
I also wondered... the European Commission publishes the Official Journal of the European Communities in three languages, French, German and English. Why can't we? In a message dated 6/30/99 5:05:05 AM Pacific Daylight Time, s_doug...@ecrm.com writes: We had several discussions about this issue. I presented to Engineering and Marketing the legal requirements from the directives and let them make the choice as to what languages we should actually use. In the end we decided to print in five languages - English, French, German, Spanish, Italian as a matter of course. Marketing came back with one special request to add either Swedish or Finnish, I can't remember which. We don't do any other languages. We have had no complaints as to what languages we either have or don't have. Except from our documentation people who have to make out the purchase requisitions for the translations which are very costly. Scott s_doug...@ecrm.com -Original Message- From: wo...@sensormatic.com [SMTP:wo...@sensormatic.com] Sent: Tuesday, June 29, 1999 1:44 PM To:emc-p...@majordomo.ieee.org Subject: EU Official Languages When a Directive requires information to be provided to the user, and that equipment is intended to marketed in every EU and EFTA country, what minimal set of languages must be used? I can think of the following languages that are used in these countries. Are there more languages that must be included? Can some of these be deleted? English, French, German, Spanish, Portuguese, Italian, Greek, Dutch, Danish, Swedish, Finnish, and Norwegian (EFTA) - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: Excessive smoke
Rich, Good Response! I can't agree with you more! Tin In a message dated 4/21/99 11:38:08 AM Pacific Daylight Time, ri...@sdd.hp.com writes: Hi Jeff: If a component abnormal test generates excessive and sustained smoke (several minutes), but does'nt breach reinforced or double insulation, nor emit flame from the enclosure, is it considered a failure? Intuitively, it seems like it would be, because of toxicity, but I have been unable to find anything in the safety standards to support this. I have checked EN 60950, EN 50178, UL 1012, and CSA C22.2 No. 107.1. For the purposes of product safety and compliance with safety standards, smoke is a permitted emission during fault testing. The safety issue is whether a safeguard is damaged or breached due to the heat which produced the smoke. If insulation is not damaged (as per the hi-pot test), and excessive heat or flame does not breach the enclosure (as per the cheesecloth test), then the product is considered acceptable for the purposes of product safety. Typically, product safety standards do not address the toxicity of smoke. This is because all smoke contains toxic materials. The only solution to smoke toxicity is to eliminate smoke, which means eliminating all overheating situations. Which is nearly impossible. However, any smoke from a product is likely create fear and anxiety in the mind of the user and nearby persons. Any smoke in a clean room will likely be cause for scrapping all stock in the clean room. While smoke always contains toxic materials (e.g., carbon monoxide), the concentration of the smoke (toxic material) in the volume of the room together with the room ventilation determines whether or not inhalation of the smoke is likely to cause an injury. If the volume of smoke is small compared to the volume of the room, then it is likely the concentration of toxic material will be below the TLV (threshold limit value) for that material. So, it is a good idea (for the satisfaction of your customers) to eliminate or reduce any significant smoke emissions that might occur during fault testing. Best regards, Rich - Richard Nute Product Safety Engineer Hewlett-Packard Company Product Regulations Group AiO Division Tel : +1 619 655 3329 Effective 6/12/99: +1 858 655 3329 16399 West Bernardo Drive FAX : +1 619 655 4979 Effective 6/12/99: +1 858 655 4979 San Diego, California 92127 e-mail: ri...@sdd.hp.com - - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j...@gwmail.monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: Enclosure ratings IP vs NEMA
Ray, I believe that UL's website comparison table, titled Comparison of NEMA Type and IP Code Designations, may be just what you are looking for: A HREF=http://www.ul.com/hazloc/ref/conversion.htm;Division/Zone Classifications Comparisons /A In a message dated 4/8/99 6:33:25 AM Pacific Daylight Time, ray_russ...@gastmfg.com writes: Greetings, I hope everyone had a happy holiday. I am looking for a comparison of IEC 60529 IP ratings for enclosures to the NEMA equivalents. Thank you for your assistance, Ray Russell Regulatory Compliance Engineer ray_russ...@gastmfg.com - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j...@gwmail.monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: Laser pointers
Since we are speaking of illegalities, there are in fact at least two California Penal Code sections dealing with the use of the unlawful use of laser devices: California Penal Code 247.5. Any person who willfully and maliciously discharges a laser at an aircraft, whether in motion or in flight, while occupied, is guilty of a violation of this section, which shall be punishable as either a misdemeanor by imprisonment in the county jail for not more than one year or by a fine of one thousand dollars ($1,000), or a felony by imprisonment in the state prison for 16 months, two years, or three years, or by a fine of two thousand dollars ($2,000). This section does not apply to the conduct of laser development activity by or on behalf of the United States Armed Forces. As used in this section, aircraft means any contrivance intended for and capable of transporting persons through the airspace. As used in this section, laser means a device that utilizes the natural oscillations of atoms or molecules between energy levels for generating coherent electromagnetic radiation in the ultraviolet, visible, or infrared region of the spectrum, and when discharged exceeds one milliwatt continuous wave. California Penal Code 417.25. (a) Every person who, except in self-defense, knowingly draws or exhibits a laser scope, as defined in subdivision (b), that projects a colored target on a person in a threatening manner against that person with the specific intent to cause a reasonable person apprehension or fear of bodily harm is guilty of a misdemeanor, punishable by imprisonment in a county jail for up to 30 days. For purposes of this section, the laser scope need not be attached to afirearm. (b) As used in this section, laser scope means a portable battery-powered device capable of being attached to a firearm and capable of projecting a laser light on objects at a distance. Tin In a message dated 11/10/98 5:12:59 PM Pacific Standard Time, ed.pr...@cubic.com writes: Here in thoroughly civilized and polite Southern California, it is illegal to aim a laser at (flying) aircraft. Further, for those who have some experience with laser sight aids, the observance of a red dot dancing on their torso might well lead to a more active response than mere amusement. Maybe I ought to give up sitting in my backyard at night, dry firing my laser equipped pistol at the passing police helicopters. Regards, Ed -- Ed Price ed.pr...@cubic.com Electromagnetic Compatibility Lab Cubic Defense Systems San Diego, CA. USA 619-505-2780 Date: 11/10/1998 Time: 16:59:47 -- - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j...@gwmail.monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: Agency approvals on components in CE mar
Jeff, Mr. Eszlari asked, Is it true that European safety agency approval for critical components may not be required for CE? Answer, No, it is NOT required (compulsory) for a manufacturer to use European safety agency approval for critical components. Having a certificate from an accredited testing laboratory is always a good idea for all of the reasons provided by Mr. Eszlari. The bottom line is that the manufacturer must be able to demonstrate that the product complies with the essential requirements of the applicable Directives. Standards provide a 'presumption of conformity', but it is not compulsory! Example: Annex V, 3(b) ... The manufacturer must carry out necessary research or tests on components, fittings or the complete machine to determine whether by its design or construction, the machine is capable of being erected and put into service safely.Remember that the CE marking signifies that the product meets the provisions of the applicable Directives. Unless it specifically states that components require European safety agency, it is NOT a requirement. Tin In a message dated 10/6/98 6:57:09 AM Pacific Daylight Time, e_eszl...@compuserve.com writes: Jeff, It is true that a European safety agency approval for critical components may not be required for CE, but please be aware that if you purchase such a component you should check the declaration and be sure the component was tested according to the correct standard with all amendments. You may also want to request a copy of the test report for your file. By purchasing European safety agency approved components you can be sure the component was tested according to the correct standard, and can back it up with the component license. Also, if a customer happens to require a European safety mark on your product, they will either ask for the component licenses or have to spend quite a bit of time reviewing the declarations and reports. Hope this helps in your decision. Regards, Edward Eszlari TUV Rheinland of N.A., Inc. Boston office 508-460-0792 - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j...@gwmail.monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: CE technical file format
Gary, UK's DTI published a Guidance Document on the Preparation of a Technical Construction File as Required by EC Directive 89/336 dated October 1992, which contains some helpful information on what a manufacturer should include within a Technical Construction File. The key parts of that Guidance Document were also captured within Annex B (Technical Construction File Route to Compliance of the DTI's UK Regulations April 1993 Product Standards, Electromagnetic compatibility. You should be able to obtain the above documents from DTI directly. For your convenience, I have included the relevant excerpts below: Annex B - Technical Construction File Route to Compliance BASIC REQUIREMENTS FOR A TCF Part I: Description of the apparatus: i) identification of apparatus; ii) a technical description. Part II: Procedures used to ensure conformity of the apparatus to the protection requirements: i) a technical rationale; ii) details of significant design elements; iii) test evidence where appropriate. Part Ill: A report or certificate from a 'Competent Body'. SPECIFIC REQUIREMENTS FOR A TCF The level of detail required in each of the above sections of the TCF will depend on individual circumstances, but might include the following: Identification of the apparatus (a) brand name; (b) model number; (c) name and address of manufacturer or agent; (d) a description of the intended function of the apparatus; (e) for installations - physical location; (f) external photographs; (g) any limitation on the intended operating environment. Technical description of the apparatus (a) a block diagram showing the interrelationship between the different functional areas of the apparatus; (b) relevant technical drawings, including circuit diagrams, assembly diagrams, parts list, installation diagrams; (c) description of intended interconnections with other products. devices etc. (d) descriptions of product variants. Technical rationale (a) a brief exposition of the rationale underpinning the inclusion and balance of the evidence given. Detail of significant design aspects (a) design features adopted specifically to address EMC problems; (b) relevant component specifications (e.g. the use of cabling products known to minimise EMC problems); (c) an exposition of the procedures used to control variants in the design together with an explanation of the procedures used to assess whether a particular change in the design will require the apparatus to be retested; (d) details and results of any theoretical modelling of performance aspects of the apparatus. Test data (a) a list of the EMC tests performed on the product. and test reports relating to them, including details of test methods, etc. (b) an overview of the logical processes used to decide whether the tests performed on the apparatus were adequate to ensure compliance with the directive; (c) a list of tests performed on critical sub-assemblies, and test reports or certificates relating to them. Report or certificate from a competent body (a) reference to the exact build state of the apparatus assessed, cross referencing with Part I of the basic requirements of a TCF; (b) comment on the technical rationale; (c) statement of work done to verify the contents and authenticity of the design information in the TCF, cross-referencing with Part II (ii) of the basic requirements of a TCF; (d) comment, where appropriate, on the procedures used to control variants, and on environmental, installation and maintenance factors which may be relevant; (e) contain an analysis of the tests performed either by the manufacturer, an authorised third party, or the competent body itself, and the results obtained, so as to assess whether those tests indicate that the apparatus should comply with the essential requirements of the Directive, cross- referencing with Part II (iii) of the basic requirements of a TCF. It is envisaged that Parts I and II of the TCF will be written by the manufacturer in cooperation or consultation with the Competent Body. The report from the Competent Body should therefore not need to repeat much of the information contained in Parts I and II. At the end of the report a detachable certificate will be supplied. This can be used by the manufacturer as an
Fwd: CE Demo Units
Scott, MACHINERY DIRECTIVE I don't know which Directive your new product falls under, but the Machinery Directive has specific exclusions dealing with demo products, Whereas, for trade fairs, exhibitions, etc., it must be possible to exhibit machinery which does not conform to this Directive; whereas, however, interested parties should be properly informed that the machinery does not conform and cannot be purchased in that condition;. Article 2(3) of the Machinery Directive also states, At trade fairs, exhibitions, demonstrations, etc., Member States shall not prevent the showing of machinery or safety components which do not conform to the provisions of this Directive, provided that a visible sign clearly indicates that such machinery or safety components does not conform and that they are not for sale until they have been brought into conformity by the manufacturer or his authorized representative established in the Community. During demonstrations, adequate safety measures shall be taken to ensure the protection of persons. (89/392/EEC as ammended by 93/44/EEC). In addition, the European Commission (DGIII) also published a Machinery Working Party, 89/392/EEC Committee, Document 93.6 rev. 1 specifically answering this question: PQ.53 If a manufacturer installs machinery on the premises of a potential customer for him to evaluate it but the machinery is not sold and remains the property of the manufacturer, does it have to bear the CE Marking and meet the other requirements applicable to it? PA.53 This is a typical case because as long as the machinery remains the property of the manufacturer and as long as the operators are the manufacturer's employeed the machinery has not been placed on the market; as soon as the satisfied customer takes delivery the machinery has to comply with the Directive, bear the CE Marking, etc. The manufacturer has to make sure that a notice is affixed in the vicinity saying that the machinery is not in conformity with the Directive (Article 2(3)). The situation is different if the manufacturer has supplied the machinery for evaluation by the potential customer. In this case, the machinery has to be considered as placed on the market (handed over provisionally but handed over all the same) and placed in service in accordance with Article 2(2) and must be entirely in conformity with the Directive. EMC DIRECTIVE Although this issue is not specifically addressed in the text of the EMC Directive, the general philosophy above is fairly consistently applied for products falling under the EMC Directive. Specifically, if a product is 'placed on the market' or 'put into service', it would require to be fully compliant with the EMC Directive. The position is backed up by a European Commission's publication, Guidelines on the application of Council Directive 89/336/EEC of 3 May 1989 on the Approximation of the Laws of the Member States relating to Electromagnetic Compatibility Brussels, 25 26 October 1993. (I believe a more recent draft or perhaps even the final updated of this Guidelines has just been released and is even posted in the RCIC in electronic format, http://uc.com/bin/dbml.dll?template=rcic/emcguide). Article 2.1 of this Guideline hadn't changed too much and it notes specifically that The placing of a product on the market does not concern: - the disposal of the product from the manufacturer to his authorized representative established within - the Community who is responsible for the manufacturer for ensuring compliance with the Directive; - importation into the Community market for the purpose of re-exportation, i.e., under the processing traffic system - the manufacture of the product in the Community market for the purpose of exportation to a third country; - the display of the product at trade fairs and exhibitions. SUMMARY (PERSONAL COMMENT/INTERPRETATION): Based on the above sources, my comment is that as long as the product in question is not being placed on the market (meaning the system is not sold and is being demo'd by the manufacturer's personnel only) or put into service, and a notice stating that product is not in conformity, you may ship a non-CE Marking product. There's no maximum time period that I am aware for a system to be considered as a display at the trade fair and no specific paperwork other than the notice needed. Depending on your product, it may have initial problems entering the EU, so a letter or declaration stating that the product is only intended to be a demo product and will not be placed on the market operated or put into service, may be a good idea. Hope this helps. Regards, Tin In a message dated 97-09-22 12:42:56 EDT, sdoug...@ecrm.com writes: Hi To All, In the process of developing a new product we hit a snag. We bought very expensive ($10,000) components for a new product. This happened just before the manufacturer implemented CE compliance changes. In order to get these components CE
Fwd: Where to get Mil-Std
Jim, Great information on the Mil Spec document distributor. One slight update... I called the Navy Publishing and Printing Service, they told me that the automatic faxback system is no longer available because they are now charging 9 cents per page, 55 pages and under is $5. Method of payment is VISA, Mastercard, Check or Money (quite reasonable still). Also, their fax number is now (215) 697-1462. Tin In a message dated 97-08-29 10:37:27 EDT, jly...@gtech.com writes: MIL specs and handbook documents are available at no charge from: Navy Publishing and Printing Service 700 Robbins Avenue Building 4D Philadelphia, PA 19111-5094 Tel (215) 697-2179 (customer assistance) Fax (215) 697-2978 Automatic Ordering (215) 697-1187 - Forwarded message: From: jly...@gtech.com (Jim Lyons) Sender: owner-emc-p...@majordomo.ieee.org Reply-to: jly...@gtech.com (Jim Lyons) To: emc-p...@majordomo.ieee.org, t...@uc.com List-Post: emc-pstc@listserv.ieee.org Date: 97-08-29 10:37:27 EDT MIL specs and handbook documents are available at no charge from: Navy Publishing and Printing Service 700 Robbing Avenue Building 4D Philadelphia, PA 19111-5094 Tel (215) 697-2179 (customer assistance) Fax (215) 697-2978 Automatic Ordering (215) 697-1187 Call the customer assistance number and set up an account. When you have the account number, you can call in to the automatic ordering number and use the touch tone keys to enter your order for documents, or to check the status of an existing order. You can order up to five copies of each document, and order multiple documents per call. If you need more, just call back and place an additional order. There is no charge for the documents or the shipping as of the last time I used this service. Global and other such organizations likely get the documents for free just like I do and then charge for copying and delivery. Jim Lyons Manager - Product Compliance GTECH Corp. __ Reply Separator _ Subject: Where to get Mil-Std Author: Tom Bao t...@uc.com at internet List-Post: emc-pstc@listserv.ieee.org Date:8/28/97 11:30 AM Anyone please tell me where to get Mil-Std? I used to know it's somewhere in Princeton, NJ or Philidelphia area. Your help is greatly appreciated. Regards, Tom RCIC - http://www.rcic.com Regulatory Compliance Information Center
Re: Names of Voltage Levels
To expand on Eric Henning's comment on voltage definition, EN 60204 (similar to IEC 204), has yet a different definition for PELV: 6.4 Protection by the use of PELV (Protective Extra Low Voltage) This measure is intended to protect persons against electric shock from direct contact and indirect contact (see IEC 364-4-41). PELV circuits shall satisfy all of the following conditions: a) limitation of maximum nominal voltage to 25 V a.c. or 60 V d.c.; b) limitation of maximum current (in case of failure) to 1 A a.c. or 0.2 A d.c.; c) limitation to 80 mm2 of any area not protected against direct contact; d) usage only indoors with dry conditions; e) the source of supply and live parts of such circuits shall be separated or isolated from circuits with higher voltages according to 6.3.3 and 15.1.3; f) one side of the circuit or one point of the source of the supply of that circuit shall be connected to the protective bonding circuit associated with the higher voltages; g) exposed conductive parts associated with such circuits shall be either separated or isolated from higher voltage circuits in accordance with 6.3.3 or connected to the protective bonding circuit associated with the higher voltages; h) plugs and socket-outlets shall comply with the following: 1) plugs shall not be able to enter socket-outlets not in accordance with this subclause; and 2) socket-outlets shall exclude plugs of circuits not in accordance with this subclause; i) where such circuits are used as control circuits, they shall also fulfil the relevant requirements of clause 9. So, I certainly agree that not all ELVs are equal.
Fwd: input current rating versus input circuit protection
Bob,
There are a few references to the 125% rule (or 80% rule) in the National
Electrical Code (NFPA 70):
1. NEC Article 384-16(c) for Panelboards- Continuous Load. The total load
on any overcurrent device located in a panelboard shall not exceed 80 percent
of its rating where, in normal operation, the load will continue for three
hours or more.
Exception: An assembly, including the overcurrent device, shall be permitted
to be used for continuous operation at 100 percent of its rating where it is
listed for this purpose.
2. NEC Article 210-22 for Branch Circuit - Other Loads. The rating of the
branch-circuit overcurrent device serving continuous loads, such as store
lighting and similar loads, shall be not less than the noncontinuous load
plus 125 percent of the of the continuous load. The minimum branch-circuit
conductor size, without the application of any adjustment or correction
factors, shall have an allowable ampacity equal to or greater than the
non-continuous load plus 125 percent of the continuous load.
Exception: Circuits supplied by an assembly, together with its overcurrent
devices, that is listed for continuous operation at 100 percent of its
rating.
Hope this helps.
Tin
-
Forwarded message:
From: bris...@mail.dec.com (Bob Brister)
Sender: owner-emc-p...@majordomo.ieee.org
Reply-to: bris...@mail.dec.com (Bob Brister)
To: emc-p...@ieee.org ('emc-p...@ieee.org')
List-Post: emc-pstc@listserv.ieee.org
Date: 97-04-25 09:06:53 EDT
Hello,
Are there requirements or guidelines around what a power supply input
breaker should be rated for a given nominal input current assuming the
power cord is rated appropriately? Looking through the harmonized 950
standard I did not come across anything.
I seem to recall seeing a 125% figure once but don't remember where that
was. I would assume that the circuit breaker would be some percent
higher than the nominal input current rating to prevent nuisance trips
and to take into account surge current or perhaps this is addressed by
the trip characteristics of the breaker.
To give an example, if the unit has an input current rating of 16amps,
is there a rule which states the input circuit breaker must fall within
some rating range.
Regards,
Bob Brister
DIGITAL
bris...@mail.dec.com
Fwd: ERGONOMICS/Color Red Restrictions
Don,
I am not sure what industry you are in, but for Industrial Machinery, I know
of two standards addressing the use of red colored indicator lights. Hope
this helps:
EN 60204-1 - Safety of Machinery - Electrical equipment of machines, Part 1,
Table 3: Color for indicator lights and their meanings with respect to
condition of the machine. (Note: I have modified the layout in order to fit
into this email)
Colour: RED
Meaning: Emergency
Explanation: Hazardous condition
Action by operator: Immediate action to deal with hazardous condition (e.g.,
by operating emergency stop)
Examples of application: Pressure/temperature out of safe limits; Voltage
drop; Breakdown; Overtravel of a stop position.
NFPA 79 - Electrical Standard for Industry Machinery, Table 8 - Color coding
for pushbuttons, indicator (pilot) lights, and illuminated pushbuttons:
(Note: I have only included the Red color for indicator (pilot) lights and
again modified the format to fit into this email)
Color: RED
Device Type: Pilot Light
Typical Function: Danger or alarm, abnormal condition requiring immediate
attention
Examples: Indicatoin that a protective device has stopped the machine, e.g.,
overload
By the way, I don't interpret the above color code to be directly applicable
for visual display terminals, although I wouldn't put it pass third parties
to interpret it so.
Regards.
Tin
In a message dated 97-01-22 15:54:58 EST, umbdens...@sensormatic.com
(UMBDENSTOCK, DON) writes:
Does anyone know if there are any formal restrictions to using red
colored lights for front panel displays and indicators?
Is there a harmonized European standard or regulation or a specific
national regulation that requires the restriction of the color red for
warning, danger, etc.
-
Forwarded message:
From: umbdens...@sensormatic.com (UMBDENSTOCK, DON)
Sender: owner-emc-p...@majordomo.ieee.org
Reply-to: umbdens...@sensormatic.com (UMBDENSTOCK, DON)
To: emc-p...@ieee.org ('EMC-PSTC Discussion Group')
List-Post: emc-pstc@listserv.ieee.org
Date: 97-01-22 15:54:58 EST
Does anyone know if there are any formal restrictions to using red
colored lights for front panel displays and indicators?
Is there a harmonized European standard or regulation or a specific
national regulation that requires the restriction of the color red for
warning, danger, etc.
It seems it may have been a German ergonomic requirement before various
standards were harmonized. Can anyone shed some light on this issue?
Don Umbdenstock
Sensormatic
Fwd: IEC 1010-1 Safety Switch
Mark, You may want to check EN 418 'Functional Aspect of Machine Emergency Stop Equipment.' In it, it does cover some of the constructional requirements noted in your email. Particularly, 4.4.1 The emergency stop actuators shall be designed for easy actuation by the operator and others who may need to operate them. Types of actuators that may be used include: - mushroom-type push buttons; - wires, ropes, bars; - handles; - in specific applications, foot-pedals without protective cover... 4.4.2 The emergency stop actuators shall be positioned for easy access and for non-hazardous operation by the operator and others who may need to operate them. NOTE. Measures against inadvertent operation should not impair accessibility. Personal Comment: You may be interested in knowing that EN418 does not either require or prohibit the use of a shroud/collar/guard. While some standards (e.g. ANSI/RIA 15.06) specifically calls out 'unguarded'. 4.4.3 The emergency stop actuators shall be colored red. As far as a background exists behind the actuator and as far as it is practicable, it shall be colored yellow. 4.1.2 The control device and its actuator shall apply the principle of positive mechanical action (see 3.5 of EN 292-2). NOTE. A control switch with positive opening operation, is an example of a suitable control device. According to EN 60947-5-1 (3rd part, subclause 2.2), positive opening operation (of a contact element) is ?the achievement of contact separation as the direct result of a specified movement of the switch actuator through non-resilient members (e.g., not dependent upon springs)?. Personal Comment: FYI. Some European testing laboratory interprets this as requiring a dual contact EMO actuator. Hope this helps! TinBear In a message dated 97-01-10 16:01:50 EST, mar...@vivanet.com (markjc) writes: I have a question concerning IEC 1010-1 section 6.12.2.3. According to the standard, equipment whose function may give rise to a hazard shall have an emergency switch... Since my equipment has a hazard accessible in-order to operate properly (i.e. it has an accessible part which goes up to 3200 Volts and 5 mA), I need to have an emergency switch. My question is that this standard doesn't give any more information about this emergency switch. I am guessing that it has to be on the front panel so it is always easily accessible. Will a standard Power Switch on the front panel be acceptable? Is there a specific size requirement? Is there a specific color requirement? Is there a specific standard for this switch? Any help would be greatly appreciated. - Forwarded message: From: mar...@vivanet.com (markjc) Sender: owner-emc-p...@majordomo.ieee.org Reply-to: mar...@vivanet.com (markjc) To: emc-p...@ieee.org List-Post: emc-pstc@listserv.ieee.org Date: 97-01-10 16:01:50 EST I have a question concerning IEC 1010-1 section 6.12.2.3. According to the standard, equipment whose function may give rise to a hazard shall have an emergency switch... Since my equipment has a hazard accessible in-order to operate properly (i.e. it has an accessible part which goes up to 3200 Volts and 5 mA), I need to have an emergency switch. My question is that this standard doesn't give any more information about this emergency switch. I am guessing that it has to be on the front panel so it is always easily accessible. Will a standard Power Switch on the front panel be acceptable? Is there a specific size requirement? Is there a specific color requirement? Is there a specific standard for this switch? Any help would be greatly appreciated.
Weight (Mass) Marking on Components - CE Marking
Product Safety Professionals, Annex I, Section 1.7.3 of the Machinery Directive for Markings states, Where a machine part must be handled during use with lifting equipment, its mass must be indicated legibly, indelibly and unambiguously. (91/68/EEC) Questions: 1. Does 'handled during use' include maintenance and servicing? 2. Does 'with lifting equipment' mean only those parts which are intended to be lifted with lift assist device are required to be marked with weight? 3. Does anyone know of any standard (Occupational, Ergonomics or Product Safety) which requires weight to be marked on parts or whole equipment? I would really appreciate the standard title and number of the standard, section and direct verbage. Regards. Tin P.S. - This is a great forum!
Standards Route vs. Essential Requirements Route
Product Safety Professionals, The 'New Approach' adopted by most European Directives is intended to enable manufacturers to declare conformity via EITHER the 'essential requirements' OR the 'harmonized standards' -- With the understanding that conformance to harmonized standards (as listed in the Official Journal of the European Communities) provides a 'presumption of conformity' to the Directives. For manufacturers who are currently declaring conformity via the harmonized standards route for Machinery and/or Low Voltage Directive, I would really be interested in the following: 1. When a manufacturer declares conformity to a list harmonized standards, are they also, in effect, declaring conformity to all of the 'Normative References' called out within the harmonized standards? 1A. Follow-up to Question No. 1: If the harmonized standards you declare against references other PrEN or IEC standards in the 'Normative References' that are NOT specifically listed in the Official Journal of the European Communities for the Directive? 2. If a manufacturer chooses to pursue the harmonized standards route, who determines whether the manufacturer has actually applied ALL of the applicable standards. In the case of a large, multi-module industrial machinery, a manufacturer can easily be expected to comply with EN 60204, EN 292, EN 349, EN 418, EN 294, EN 457, EN 1050, etc. (Keep in mind that even if you utilize a Competent or Notified Body, the manufacturer is still self-declaring!) 3. For manufacturers that declare conformance to the standards route, what happens when new PrEN standards become harmonized and published in the O.J.? Will the manufacturer be expected to stop all shipment or is there an official body who will allow manufacturers a certain grace period to bring their products into compliance with the new requirements?I ask this question because I have never seen any grace period allotted when the European Commission publishes an update adding more and more harmonized standards to the Directive. 4. Rhetorical Question (I think): Which route opens up more product liability to manufacturers, standards route or essential requirements route? I would really appreciate any feedback, ESPECIALLY IF THE RESPONSE IS BACKED BY A PUBLISHED POSITION FROM AN OFFICIAL EUROPEAN SOURCE (SUCH AS THE EUROPEAN COMMISSION OR EUROPEAN COMPETENT AUTHORITIES). Best Regards. Tin
