Re: ETSI standards vs NEBS
Just a minute here. NEBs are requirements for Network Equipment formulated by what was the Bell Operating Companies' research arm Bellcore. (They have now been cast adrift as Telecordia). The Operating Companies have done a good job of making sure that the requirements for their equipment were not regulated and are in effect part of the commercial negotiations that take place between the buyer and the seller. If you're a big enough seller, you can negotiate on these requirements. Ciao, Vic Boersma
RE: Using RTTE directive before April 2000?
Message text written by Roger Magnuson As you know, the current Directive took much too long to implement in certain countries (no names...) and I guess this is the reason for this unusal approach. Roger, the approach is not unusual under the terms of the Treaty of Maastricht which no longer requires that the member states must transpose the Directive before it is implemented. That was one of the victories of that Treaty (some will not see it that way). The only thing unusual is that the RTTE Directive is implemented, POST MAASTRICHT, all the other ones so far were PRE MAASTRICHT. This will be the norm in the future, in particular for the new EMC Directive. Ciao, Vic
RE: internet information (worldwide electricity supplies)
I haven't checked the WEBsite (I avoid visiting WEBsites unless there is a terrible need to know) so I don't know what exactly is there. However, quite often, the useful information to have is what the permissable variations in the Electrical supply are in various parts of the world. At one time I had such a list for North America and it helped considerably in product design. My understanding is that with the privatization of the North Amercan electricity generation and distribution, the private sector operators are now establishing norms for how much deviation they will allow in the DESIGN characterisitics of a power generating and/or distribution entity, before they will let such a [provider connect to their network. (Supply contracts tend to have terrible penalty clauses for the power going down or off). These norms overall, are not in the public domain because the operators of all manner of networks have come to the realization that too much standard, makes their facilities more vulnerable to cyber attacks. Ciao, Vic Boersma
RE: FCC Part 68 Testing in the UK
And than to think that all those people operating random number generators are not even mentioned. Ciao, Vic
Part 68 Training
We have a new engineer learning Part 68/IC CS-03 that we would like to enroll in a seminar or training course. Is anyone aware of any seminars or training courses for Part 68/IC CS-03. Best Regards, Jody Leber jle...@ustech-lab.com http://www.ustech-lab.com U. S. Technologies 3505 Francis Circle Alpharetta, GA 30004 770.740.0717 Fax: 770.740.1508 Jody, Every two years or so, TIA puts on a seminar where people are led through Part 68 and CS-03. Last one was in February 1998 so perhaps it is that time again. Their price is right. If not, I am prepared to put one on at a small price. Ciao, Vic Boersma
Re: Production Line Test for -48 Vdc Equipment
I'd better start reading my UL1950/CSA950 again than. They are supposed to be identical documents and CSA does not have to satisfy OSHA, hence, it must be in the deviations for UL ??? Thanks and regards, Vic PS Is it only me, or is everybody getting these messges two or three times ??? V
Re: Production Line Test for -48 Vdc Equipment
I'd better start reading my UL1950/CSA950 again than. They are supposed to be identical documents and CSA does not have to satisfy OSHA, hence, it must be in the deviations for UL ??? Thanks and regards, Vic PS Is it only me, or is everybody getting these messges two or three times ??? V
RE: Billing tones...?
Message text written by INTERNET:t...@world.std.com A computer security device such as a logic circuit that could be connected to the machine (i.e. via a printer port) which, when interrogated, returns a unique logic code. Live and learn. We're all grateful for this bit of new information. My suspicious mind was trying to work back from the root of the word and left in strange places. Ciao, Vic
RE: Korean approvals
Mirko, this is all getting very muddy now that there is an APEC MRA on Telecom requirements and an APEC MRA on Product Safety in the offing. Combine that with Korea in the throes of changing over to a program that is more like the FCC program (before the FCC launches a Notice of Inquiry on whether to do away with Part 68) and you can conclude that things are in a state of flux. Ciao, Vic
Re: Network Equipment and UL 1459/1950
Message text written by INTERNET:t...@world.std.com I have to agree that there shouldn't be another US (UL) standard for network equipment when the equipment can be incorporated into UL1950. UL1950 can be revised to clarify the network equipment requirements, perhaps as a deviation or an appendix (annex), or just rewording the existing sections to make it easier to follow. The reason why we went the UL1950 route was to be able to join the IECEE Schemes, where it is a prerequisite that the nation use the governing IEC Publication with a minimum of deviations. We had a bit if a difficult time with the IEC and are supposed to show how we are DECREASING the number of deviations, not increasing them. We had a difficult time to convince the data processing industry to embrace customer premises equipment. We never could get an international agreement to incorporate Central Office equipment. I may be mistaken, but I do not believe that we will get support from the main stakeholders in UL1950, to increase the number of deviations to accomodate Central Office equipment. Therefore, incorporating such requirements in a UL1459/CSA 225 product makes most sense. Even if we could get support in North America to propose modifications to IEC 60950 to accomodate CO equipment, we are talking about a process that will take years. I am afraid I start sounding like all the other would-be historians in making these comments and my white hair and arthritic knees don't help the image. Nevertheless, a bit of history helps in understanding some of these things. Regards, Vic Boersma
Re: Network Equipment and UL 1459/1950
Message text written by INTERNET:t...@world.std.com In my view, these exemptions are specifically targeted at equipment such as PBXs and network equipment that are typically installed by service personnel and include hardwired grounding. When Telecom equipment (of the non-network equipment variety) was included under IEC 950 it was a hard sell to the Data Processing equipment manufacturers, who did not want to see their Data Processing equipment standard polluted by telecom considerations. In addition, the telecom reps where not really PBX experts of any sort (with one exception). Therefore, in trying to interpret IEC 60950, one cannot assume that PBX and network equipment was targetted. There was a basic assumption that if the Mainframe computer and router equipment manufacturers could do it, than the telecom equipment manufacturers ought to be able to do it, over time. On another note, a lot of these type of requirements come from so-called, horizontal standards developed by other experts who have no knowledge of either Information or Communications technology practices. If you want to change these horizontal standards, you have to join that crowd for years till they have confidence in you, and than you might be able to change some of those things. By and large, one cannot get money for that sort of a campaign in the ICT industry. Therefore, you have to live with it. When we started the campaign for IEC950, CO voltages and currents were considered dangerous and one would have had to run telecom installations in conduit. We've come a long way. Ciao, Vic
FCC Deregulation of Equipment Certification
Message text written by INTERNET:t...@world.std.com On December 17 FCC took another big step towards getting itself out of the telecommunications equipment approval business, in order to allocate resources to enforcement of its regulations. Docket 98-68 covers both wired and wireless telecom equipment de-regulation issues, an Adobe Acrobat file version of the docket is at http://www.fcc.gov/Bureaus/Engineering_Technology/Orders/1998/fcc98338.pdf Text and Wordperfect versions also available on FCC's home page in the Headlines section. Tom, thank you very much for sharing this with us. You are correct from the perspective of what this means to Industry and Certification houses. However, you have not grasped the essence of the decision. The FCC REMAINS the Approval Authority. The TCBs only certify that the equipment meets the requirements. So, the FCC is getting out of some of parts of the approval business, but not all parts. Given that in the past one civil servant reviewed the applications for registration no matter who submitted them, and had a sixth sense for what was fishy, anything that requires more people and accredited laboratories and certification organizations WILL HAVE TO COST MORE and will probably not be as responsive, efficient and cost-effective. COMPARE THIS WITH THE MARK OF A NRTL, THE NRTL NEVER EVER SAY THEY APPROVE THE EQUIPMENT, THEY SAY THAT THE EQUIPMENT MEETS THE REQUIREMENTS OF SOME PARTICULAR STANDARD(S). THYE LIST THE EQUIPMENT ON A LIST OF EQUIPMENT THAT HAS PASSED THE TESTS. IF YOU READ THE FINE PRINT YOU FIND OUT THAT THE AUTHORITY HAVING JURISDICTION IS THE ONLY ONE WHO CAN APPROVE, AND DOES SO ON THE STRENGTH OF THE MARK OF A NRTL. PART 68 EQUIPMENT NEVER WAS APPROVED. IT WAS REGISTERED. This action amends parts 0,2,15,25, and 68 of the rules to give manufacturers the option of obtaining equipment CERTIFICATION from private entities for equipment requiring approval from the FCC. Telecommunication Certification Bodies, or TCBs, will be established to function much like the Commission by certifying a product based on the test results of one representative sample. THE COMMISSION DID NOT DO MUCH CERTIFYING IN THE PAST. THEY REGISTERED. TCBs must have the technical expertise and capability to test the equipment it will certify, although a TCB can accept manufacturer's data or data from subcontractors - the TCB will be responsible for subcontractor results. The Docket also adopts rule changes to implement Mutual Recognition Agreements (MRAs) for product approvals with the European Community (EC), THE CHANGE IN THE RULES WAS INSTIGATED BY THE MRAs. IT IS NOT PROBABLE THAT THE RULES WOULD HAVE BEEN CHANGED AS THEY ARE, IF IT WEREN'T FOR THE MRAs. the Asia Pacific Economic Cooperative (APEC), and others. TCBs will be private entities in the US, designated entities in other countries. WHETHER THE ENTITY IS PRIVATE OR PUBLIC HAS NOTHING TO DO WITH DESIGNATION. THE US DESIGNATES QUALIFIED LABORATORIES TO THE EUROPEAN COMMUNITY. THE EUROPEAN COMMUNITY DESIGNATES QUALIFED LABORATORIES TO THE US. THE US DESIGNATING AUTHORITY MUST ASSURE ITSELF THAT THE LABORATORIES THEY DESIGNATE ARE CAPABLE OF DOING THE JOB. BECAUSE THEY CANNOT TREAT FOREIGN BODIES DIFFERENT THAN NATIONAL BODIES, THEY HAD TO INSTITUTE THIS ACCREDITATION BUSINESS, OR MAKE IT A FREE-FOR-ALL. THEY CHOSE THE ACCREDITATION CHURCH, WHICH WILL DRIVE THE PRICE OF TELECOM PRODUCTS IN NORTH AMERICA UP FOR THE CONSUMERS. (I AM NOT ARGUING THAT THEY SHOULD HAVE GONE THE FREE-FOR-ALL ROUTE. I AM MERELY STATING THAT WE WENT FROM A SIMPLE AND INEXPENSIVE APPROVALS ROUTE TO A MORE COMPLEX AND COSTLY ROUTE, IN THE HOPE AND EXPECTATION THAT WE WILL GAIN FROM THE INCREASE IN BUSINESS.) TCBs will be accredited to ISO/IEC Guide 65 and ISO/IEC Guide 25. NIST will be responsible for accrediting TCBs, FCC will DESIGNATE QUALIFIYING TCBs TO THE EUROPEAN UNION. SUCH DESIGNATIONS WILL BE ANNOUNCED via Public Notice. (NOTE: THE EU HAS THE RIGHT TO QUESTION US DESIGNATIONS, THE US HAS THE RIGHT TO QUESTION EU DESIGNATIONS. BEING DESIGNATED DOES NOT NECCESSARILY MEAN YOU'RE IN. I HAVEN'T CAREFULLY READ THE FCC DOCUMENT, SO I AM NOT SURE THAT THE FCC NEEDS TO DESIGNATE LABS FROM THE US, FOR THE US. I WOULD EXPECT THAT THE FCC WILL PROVIDE A PUBLIC NOTICE ON WHAT FOREIGN DESIGNATIONS IT DID ACCEPT). Once TCBs have been established, FCC will no longer process or issue certifications for pc's and pc peripherals (new para 15.101) There has been no limit put on the number of TCBs that will be accepted. TCBs will be able to perform all the equipment CERTIFICATION functions currently performed by FCC, with the following caveats and exceptions: - TCBs are not to impose their own requirements and conform test and certification procedures with FCC rules and requirements - TCBs will not be permitted to waive rules. Waivers and new or novel rule applications or interpretations will be done by FCC - Grantees of
Blowing steam
Anybody willing to help Peter -- Forwarded Message -- From: AIKAT Peter -EAS, INTERNET:peter.b.ai...@extott14.x400.gc.ca TO: Vic Boersma, 102126,156 DATE: 15/05/97 20:08 RE: Blowing steam Excerpt from Pressure Vessels chat group: = With wet (50 psig, 99% quality) steam flowing at about 100 feet per second in a pipeline, what micron size droplet distribution might be expected? This information is needed to specify mist eliminator performance, and we do not want to specify more equipment than is necessary. Information on droplet size distributions in a blowdown flash tank would also be of interest. =
Re: TREG or EMC-PSTC
Tom, for me, you are asking the wrong questions, but than that is for me. I am interested only in general regulatory and compliance issues, which is a field of its own in our global community. I don't have time to read all the good stuff from the techies on how they diddle modems to pass the UK requirements. I'm not saying that is not good and worthwhile stuff, but if you're trying to track the global regulations for Information and Communications Technology equipment, than these details become chaff in the wind. You don't have time for it. I found that the EMC-PS forum had too much technical detail and not enough information to make it worth my while. I'm getting to a point where I start questioning the value of the TREG, if the trend for going down technical ratholes continues. Once again, I'm not saying that the technical stuff is not valuable, to the contrary, in the days that I had to get approvals for stuff, that would have been an invaluable source. It is just that the, what I call electro-political part of this business has grown to a size that does notpermit sidetracking on finer technical points any longer. Hence your questionaire poses a problem for me. I am interested in the general aspects of all the fields you mention, BUT NOT FROM A TECHNICAL PERSPECTIVE. Thanks anyway for giving us an opportunity to express our thoughts on this. Vic Boersma WE NEVER ADMITTED BEING IGNORANT IN THE FIELDS WE WORKED For a copy of our rates please hang on to your seat.
Re: Proposed changes to UL 1950 3rd Edition
As a founding member of the bi-national committee, I have objected to ANY and ALL deviations from IEC-950 in the BiNet. Obviously, not very succesfully. I believe that if I still were a member of that illustrious group, I would object to there being a national committee in any country that thinks up deviations to IEC 950. The job of national committees ought to be the preparation of inputs into TC74, and inside, the removal of existing deviations in the national code (and fix the CEC and NAC, while at it). The notion that a good citizen in Preoria Ill needs to go to Geneva to change the national requirements, does not sit very well with many. However, that is the only way we're going to bring sanity to this global market place. There will be a good deal of pain in that procedure, but the only pragmatic way to deal with the problem is to go through the pain. In the mean time, if you have a customer who only buys equipment with gold-plated bases, you will do the plating, if he has the money. Happy not to contribute to any controversy. Vic
Re: Re[2]: Proposed changes to UL 1950 3rd Edition
My comments are the rock in the big pond. YES. However, just back from INTER COMM 97. Anybody who thinks that in three years from now, when PCS is taking hold, when CATV companies offer dial tone and telcos are offering TV, we will be operating the old T1 pipe infrastructure, is ready for a rude awakening. We are in for a VERY competitive ICT (Information and Communications Technologies) business period, that will involve a restructuring of our infrastructures. You won't even be able to sell the equipment as second hand equipment to developing countries. They'll be leapfrogging those technologies. IEC-950 and its derivatives (EN 60 950, UL 1950, CSA 950) will probably have to change as well. They were never intended for the technologies we are inventing as we go. Aren't I lucky that I am part of an interesting world in my dotage. Ciao, Vic Buy stock in equipment and software providers. Sell stock in competing service providers you don't believe will make it. VB
Re: IEC-950 4th Amendment
Just received notice that Amendment 4 to IEC Publication 950 was published in August 1996. It was prepared by IEC TC 74 which prepares requirements for the safety and energy efficiency of information technology equipment, including electrical business and telecommunications equipment. Price is 219.00 Swiss francs. For more info contact Mr. Nelson at: Tel: +41 22 919 0228 Fax: +41 22 919 0300 Internet:d...@iec.ch Ciao, Vic Boersma
Re: TCADD
You need to do some mouth rinsing. At one time it was the CE Mark. However, fundamentalists in the EU Parliament objected to that terminology because it was reminiscent of the mark of the beast. Hence, it was changed to CE-marking. CE-Stamp, my Lord Vic Boersma To join this club, you have to send a message to the EMC-PSTC address shown above, believe it is emc-p...@ieee.org and say subscribe. You than will receive all sorts of information that you can sort.
Re: What is EN-41003?
Don't think so Roger. IEC 950 = EN 60 950, was meant for Information Technology Equipment, including Electrical Business Equipment. EN 41 003 has a checkered history, but was mainly intended to provide additional requirements for any type of equipment that connects to a Telecom network. That could be Informatlon technology equipment or a coffeepot that is started via a telephone line. Indeed, EN 41 003 is pretty much Clause 6 of IEC 950, so far. The scientists have now put much of the content of Clause 6 of IEC 950, throughout the body of that Publication, so that it is no longer immediately obvious that something is or is not Telecom related by virtue of it being in Clause 6. UL 1459 is definitely NOT included in UL-1950. UL-1459 was the first UL try to create a Telecom equipment standard, based on UL-114. This was going on at about the same time that CSA was involved in a similar endeavour, first C22.2 No. 0.7 and later C22.2 No. 225. There was a bit of an effort to keep UL-1459 and CSA 225 more or less compatible, till it struck the membership as ludricous to keep this construct, while the rest of the world was moving to IEC-950 for these converging technologies. Hence, the BiNat Task Force created the BiNat or Binational standard, issued by both UL and CSA as UL-1950 and CSA C22.2 No. 950, identical. The price is comparable and you'll have to decide on what logo has more appeal when you go out to buy a copy. The BiNat is also BiCult in that it not only covers two nations, the US and Canada, it also covers two cultures, Information Technology and Telecommunications Technology. The document is based on IEC-950 with a number of deviations imposed by the National Electrical Codes of the USA and Canada and the much reviled overvoltage requirements which try to account for the fact that in much of North America, electricity and telephone service is brought to the residence via pole lines, where the telephone cable runs on the same Poles as the Electrical wiring, giving rise to a certain amount of induction as well as the possibility of high power getting on to the telephone cable in cases where the electrical wire breaks and falls onto the telephone cable. Regards, Vic PS Ringing voltage is not 48 Volts
Re: TTE Directive as it applies to VSATs
You should have come to the seminar we gave last week in Toronto and San Jose as it was stimulated by the proposed new CTE (Connected Telecommunications Equipment) Directive. The proposal is still being worked and if there is a draft text, it is not out yet. However, one of the facets of the new proposal is to do away with all a-priori testing and rely on a-posteriori surveillance, for all telecom terminal equipment. It is going to be a couple of years before you see it. By that time, if you get a-posteriori surveilled, you'd better have your act together because any equipment that fails to meet the essential requirements of the new Directive (NOT ETSI Standards) will be found defective and subject to the full force of the Product Liability Directive with fines up to 70 M ecus. Ciao, Vic
RE: Mexican Product Safety (NOM)
For Information Technology Equipment and Telecommunications Equipment, the responsible standards organization in Mexico is NYCE (Normalizacion y Certificacion Electronica). The VP in charge of Certification is Victor-Hugo Perez-Salinas, the operating manager is Julio Nunez. Victor-Hugo is ex-Motorola, Julio is ex Alcatel. Both speak fluent English. They can be reached at: 011-525-687-3932, 687-3852, 536-3378, 543-3639, 536-3408 or fax at 543-4070. The Mexican high-tech industry would like to switch to IEC-950 and Mexican representatives now participate in the work of IEC TC74. However, under Mexican law, if they switch to IEC-950, that is the only standard they can use. That would play havoc with Mexican pencil sharpener manufacturers, etc., etc. Hence they are looking for a way to accomodate that concern. In addition, Mexico, and many other 3rd world countries, do not have an infrastructure that allows them to have many laboratories that are equipped to measure to high-tech standards. They can not promolgate standards that no Mexican laboratory can test to. Hence, they will have to earn the money to pay for that expertise, in their country, by any and all means. It is unacceptable that stuff would be tested by foreign laboratories to Mexican requirements, because Mexico can't do it. I estimate that they will need about $ 300 M in regulatory revenue on high tech equipment, to do that. We are going to pay that money, one way or the other. (SWAG=Scientific Wild Arsed Guess). Ciao, Vic
Re: Why 42.4Vac/60Vdc - or 250V
This whole debate points to a lack in the standards development world that I have lamented for many years (and done something about whenever I could). THERE IS NO RATIONALE STATEMENT WITH THE REQUIREMENTS Time and again, one butts up against a wall, when one wants to change something, that goes somewhat like, Well those folks must have known what they were doing, and I don't want to change it unless I know why it was so in the first place. Those folks probably did have a rationale, but not necessarily a good one, and not necessarily one that is still valid today. Unless the standard tells me what the rationale was, what it was that they were trying to protect against, I must assume, as a catalyst for change, that it is probably invalid today. Hence, EVERY REQUIREMENT IN A STANDARD OR TECHNICAL REGULATION, MUST HAVE A RATIONALE STATEMENT, OR THE REQUIREMENT SHALL BE DEEMED OUTDATED. Ciao, Vic
CLC/BTWG 74-3(SG)40
At the EU seminar we were provided with copies of a new CENELEC document Information on the Links Between Products, Directives and Standards in the Electrotechnical Field. The document comes in 3 parts Part 1, in golden rod, Directive - Product - Standard Part 2, in green, Standard - Product - Directive Part 3, in yellow, Product - Standard - Directive It is almost .5 inch of paper, printed on both sides, so don't ask me to copy it for you. Try and get a copy from Mrs. A. Colman at the Central Secretariat of CENELEC, Rue de Stassart 35, B-1050, Brussels in Belgium. Document Number CLC/BTWG 74-3(SG)40 Regards, Vic
Re: Documentation Legal rqmts
EU authorities prefer if the file is held by a European entity, but donot insist on that. However, there appears to be an unwritten law that expects you to be able to produce the darn thing with 24 hour notice. There is genberal unhappiness with the fact that some manufacturers don't seem to be able to do that, for silly reasons such as bankruptcy and such. Hence the proposed new CTE wants all files held by a competent body, which is not allowed to look at the darn thing, just hold it. Even the most liberal of the competent bodies object to becoming a filing cabinet, so we'll see what happens. Regards, Vic
Re: Australian Requirements
I believe there is a confusion factor creeping into this debate. Neither AUSTEL, OFTEL in the UK, the FCC in the US or Industry Canada have any business accepting IECEE CB certificates. IECEE CB certificates pertain only to Electrical Safety. The agreement to accept such certificates is between participating PRIVATE SECTOR organizations. BSI, VDE, UL, ETL, CSA and such organizations are members of the scheme and are expected to accept certificates from other members, and allow the manufacturer to affix the mark of the national organization in the receiving country. For example, upon receipt of a certificate from UL, that the equipment has passed all applicable requirements with respect to Electrical Safety in Germany, VDE will allow an American manufacturer to affix the VDE mark to such equipment (provided the proper follow-up procedures are in place etc., etc.) The appropriate German Telecom authorities have nothing to do with how the American manufacturer obtained the right to affix the VDE mark, they only note that the equipment does carry that mark with the permission of VDE. In many countries, telecom equipment will not be approved to the telecom requirements, UNLESS, it has first been approved w.r.t. electrical safety and EMC. The IECEE CB scheme, so far, can only be used for the electrical safety part. Regards, Vic
Re: Australian Requirements
The IECEE CB scheme is very much alive and well and more countries are joining every year. The scheme recently has been expanded to include not only a CB scheme, but as well, an EX and a FC scheme. Not all that familiar with the EX scheme as that is intended for equipment used in explosive atmospheres (which I try to avoid), but the IECEE FCS (Full Certification Scheme) will start up very soon. To the best of my knowledge, the biggies such as UL and CSA have all qualified for that scheme. There is a meeting this week in Geneva of the IECEE management committee where some new accomodations are being debated. If you want to know the latest and the best, sign up for one of the Seminars (Toronto or San Jose) in the first week of July, where Joe Gryn will have session on that very topic. Regards, Vic Boersma
Re: EMC severity levels: an update
Large Corporations indeed do have their in-house standards, so do any number of small corporations. Those standards are the result of years of study on failed products, an investment that often is far from trivial. Those standards are what gives those corporations their competitive edge in the market place and makes some brands a household name, because of their reliability. Obviously, those corporations know that the standards aren't enough AND, what is enough. Any employee of any corporation that has made that investment and tells this forum how to compete with his organization, should not expect a raise. Regards, Vic
Re: Pack of CE Marks?
I don't know from what perspective you are asking the question, BUT, in the final analysis, the only things that count (assuming that the product is covered under one or more of the New Approach Directives is: Was the product subjected to the Conformity Assessment procedures prescribed in the applicable Directives AND Does the product meet the essential requirements of the applicable Directives Unless you can answer YES to both questions, you are in violation of the law. Regards, Vic Boersma
Re: Ethernet Compliance
You're asking an unaswerable question, in my opinion. (1) Many buildings are prewired and can't handle any more wire, you've got to make do with what is there, or make rewiring part of the contract. You're not likely going to be the lowest bidder on the job, if you do. (2) If the people who do the wiring know what they are doing, you can have very good results using either coax or CAT 5. If the people doing the wiring don't know what they are doing, they are likely going to make a mess out of either. Believe me, I have seen people making a horrible mess out of either. (3) You have not mentionned running fiber (4) You have not mentionned doing a wireless distribution I suggest you take a building distribution specialist group on to discuss this further. I have included a number of my friends of that persuasion in the distribution. Regards, Vic Boersma
Re: European Power cords
In response to Nick Rouse's comments: I stand to be corrected. Indeed, Member States may thwart the intent of the Directives by doing weird and wonderful things when they transpose/approximate. At times their reasons me not be the purest, but in the UK case, it is clear to the rest of the world that a good plug has a fuse. I believe that every principality has something or other that says that you should use plugs in that country that fit the sockets they are likely going to be plugged in to. The issue in that case is that an ill-fiting plug may cause heating, fire and other unpleasant things. The question now is, if you supply the customer with a box that has a cord and plug that may not fit the local sockets PLUS a cord and plug that WILL fit the local sockets, will that cause enough confusion to lead to unpleasant events. Remember, you meet the letter of the local law that says that you shall provide the proper plug. The issue is whether the improper plug, also included in the package, will be considered likely to cause problems. My take is that this may well vary from country to country. The worst case is if the plug almost fits and people who can not read the instructions are going to try. Given the complexities of all the possible combinations, I change my tune and now believe that probably you should not be allowed to give the customer a choice of cords in the box, because it may well be a violation of the LVD essential requirements. Regards, Vic Boersma Vic
Conformity Assessment of Integrated products
There has been a spate of comments on this channel lately about the problems encountered when a product is an integration of several other products. Doug Probstfeld of INTEL in Hillsboro, OR, has produced a white paper on the topic and makes some recommendations on how to deal with it. Not everybody may agree with Doug's approach, but I think it is a good start. (I don't like the use of the word modules in Doug's paper, as it confuses the EU Conformity Assessment modules, with components used in an integrated product, in the reader's minds.) In the paper he goes into each of the problem areas in great detail and attaches a copy of the Notice of Proposed Rulemaking by the FCC to deal with the EMC aspects in the USA, under Part 15 of the FCC Rules and Regs. The FCC also has put in place a mechanism to deal with the telecom aspects of integrated packages, under Part 68 of the FCC Rules and Regs. Greg Slingerland of MITEL was instrumental in getting that one off the ground. UL has a special Task Force looking at the Electrical Safety aspects of the plug and play scenario. (Believe that INTEL and MITEL are on that Task Force). The telecom industry has always lived with this problem, as it always was composed of bits and pieces from different manufacturers, assembled in the field. There never was a complete PBX in one place, to be certified. We're now doing that with computer systems with servers from one manufacturer and controllers from another manufacturer to printers and terminals of yet other manufacturers, on a large scale. On the small scale, we're buying keyboards, mouses, monitors, motherboards, printers, power supplies and all manner of cards to go into the tower of our choice, to make our PC system. When we upgrade to a faster modem, a larger monitor screen a more powerful this and a faster that, we don't bring this thing back to the manufacturer. The smart ones will take it to a reputable integrator, the poor ones will take screwdriver in hand and do it themselves. That is the reality we live in. We should try and avoid different solutions to this challenge and opportunity, in every principality on mother Earth, and work on some global solutions. Regards, Vic Doug Probsfeld and Greg Slingerland can be reached at the eMail addresses above.
European Power Cords
Mark Montrose wrote: RE:European Power Cords This question relates to the use and application of power cords provided into the EU when shipped from the USA. A company builds one version of a highly configurable product. The user chooses any combination of optional pwbs (over 20 different options) plugged anywhere into a large backplane along with a choice of several different power supply assemblies (universal auto-voltage detect, redundant, non-redundant, etc.). The product is handled by European distributors who order a large number of units for their warehouses for reshipment to any country within Europe, including non-European countries. The manufacturer, located in the USA, has no idea what country the unit will be sold to or how it is finally configured since this is up to the European distributor to configure and sell the unit. I don't think the authorities having jurisdiction give a damn about all this. WHO makes the Declaration of Conformity and WHO holds the technical file, the manufacturer or the distributor ??? The USA manufacturer provides a North American power cord set as a default item to all shipping assemblies, since most units sold are to North America. The company, at no charge, will provide to the distributor a power cord appropriate to the end country's application This power cord is purchased from a European power cord manufacturer, located in the UK, and dropped shipped to the distributor, also located in the UK (one of several European distributors throughout the continent). Once again, all this is irrelevant, WHO is the responsible party ? Do you farm that responsibility out to your distributors, or are you responsible The following issues have now been raised by a sales manager in the UK which we are unable to answer. 1. Is it legal to ship North American, 120VAC power cords into the UK, knowing that these cords will be thrown away upon receipt? Please provide the statutory Instrument in UK law that says 120 VAC rated cords are illegal for importation, even if they will never be used. Wrong question. You can ship whatever you want into the UK. The issue is whether you can put it on the market in the UK, or anywhere IThe only questions that you need to answer are in else. Putting on the market is making it available to a third party, for the purpose of distribution and/or use. By the way, storage is not considered placing on the market. Selling to distributors is. It is a bit US ethnocentric to expect UK law or EU law to say something about US, 120VAC, 60 Hz powercords. In any event, the issue here is not UK Statutes, but EU Directives, which are legally binding laws of the European Union that become mandatory by their transposition into national laws of the Members States. The UK has transposed the Low Voltage Directive but that is not relevant either, because you are distributing all over the map out of the UK. Boxes that go to Upper Slobovia, do not have to meet EU and EEA requirements. They probably will have to meet Upper Slobovian requirements, once they get there. 2. Please provide the UK statutory Instrument (and any other European Country National Law) that mandates products received from North America must contain a power cord appropriate to their national electric requirements, plug specific. The UK statute is not relevant. EU Directives are. The EU Member States must allow free movement of goods that meet the essential requirements of all relevant Directives. Since the plugs are different in every EU Member State, making having a specific plug an essential requirement would immediately stop all trade in electrical equipment. 3. In examining the LVD and EN 60950, no mention is made regarding the legal requirement to ship a particular power cord into Europe. The LVD para 3.2.4 mandates electrical requirements and type of cordage required. The LVD does not have a para 3.2.4, IEC-950 derivatives do, but will not specify the plug. Reason is that IEC-950 is not a catalogue of possible plugs but a safety standard. In addition, good business acumen dictates providing the equipment with a usable plug in the country where you sell (and instructions in a language the local populace can understand). 4. If the USA manufacturer cannot stock variations of European power cords, then how does your company handle this issue of multiple power cordsets for use worldwide. Any USA manufacturer who wants to, can stock any number of European power cords he wants to. However, he may find it to his advantage to let that be handled by his distributors. That has nothing to do with technical requirements, it has something to do with the economics of any given operation. 5. Are their any other statutory Instruments or requirements related to power cord usage within the EU not addressed above. YES, ANNEX I of the LVD, in particular the
Re: Excluded Installation Revisited
Alan, We know what is excluded from needing a CE mark: (1) Products for which there are no legal requirements as to their technical characteristics (2) Products for which there only exist national requirements as to their technical characteristics (3) Products for which the requirements as to their technical characteristics are laid down in EC directives OUTSIDE the new approach Many of the authorities having jurisdiction now feel that we should consider as apparatus only components of a complex nature and that simple modular components such as for instance, diodes or integrated circuits, need not comply with the essential requirement, need not be subjected to any conformity assessment practices and need no marking. That, would not exclude your CBT system. The questions I would ask myself are: Are there legal EU requirements as to the technical characteristics of a CBT system ? If so, are they inside or outside directives under the new approach ? I suspect that the answer to the first question is NO, thus exempting your CBT system. Please note that this would NOT exempt the components of you CBT system from having to carry the CE marking. Having said that, I am convinced that each part of a system can be as safe as all get-up, but if assembled by somebody not steeped in the arts, may result in a dangerous package. This particularly holds for distributed systems such as PBXs, LANs, etc. Regards, Vic
Re: Approvals
I hate to disagree with my customers BUT: In Canada and the USA, the CSA certification and UL listing do NOT constitute APPROVAL. The Authorities Having Jurisdiction (AHJs), for our purposes the electrical inspection authorities in the States or Provinces do the approving. They normally do that by observing whether or not the equipment carries the mark of an accredited certification or listing agency. If they see that mark, they approve and stop their investigation there. (THEY DON'T HAVE TO !) If they don't see that mark, they may choose to investigate the product themselves, or, they may instruct the manufacturer to go and get it tested in a place of their liking. They will than approve or disapprove on the basis of that investigation. The certification organizations are NOT in the business of approving equipment, they are in the business of certifying that the equipment meets specific requirements. An electrical inspector is responsible for determining whether an installation should be approved. I believe you could sue the pants of him if he did NOT approve, because the equipment does not carry his preferred mark. However, if the equipment does NOT carry that mark, he is not going to approve before he has received assurances in one way or another that the equipment meets the applicable requirements. He usually is ill-equipped to do that verification himself. Regards, Vic
Re: Who can apply the CE Mark?
I attended a conference in Amsterdam on March 18th (had to dump my poor wife in a motel on Cocoa Beach for the week-end to do it) where Mr. Joergen Richter of DG XIII introduced a draft for the new Connected Telecommunications Directive (CTE). The gist of the story is that the Commission is having a change of heart on how to best regulate. The point was made repeatedly that under the current system they can't track the original parties that made the declaration. They want to go even so far that they want the notified bodies to hold the files WITHOUT LOOKING AT THE FILES and require that the EC mark comes with the number of the notified body that holds the files, even for a Module A conformity assessment. (Needless to say, the Notified Bodies were less than enthralled with that notion). The fun is only beginning. Regards, Vic
Re: Dates on MDoC
Hi Jon, Perhaps this is a very good time to remind all and sundry that most of the Directives have been modified at one time or another by other Directives. To the best of my knowledge, one is expected to cut out relevant parts of new Directives and glue them into the old Directives. I know of one commercial service that does this for you, on a subscription basis, for selective Directives. Do not think that because you have the Directive in your hot little hand, you have the latest version of the Directive. Regards, Vic
Dumb Question
In the grey past, we obtained certification/listing from our friendly certification houses. If we thought that something was wrong with the application of an old standard to a new product, we would have a heart-to-heart talk with our certification organization. If we had a good, solid and valid argument, chances were that our certification organization would agree and certify us to the spirit of the standard. In addition, it was likely that our certification organization would propose changes to the standard, to rectify the anomaly. In the brave new world of Declaration of Conformity, the only time you have to explain yourself is, when you get caught. The question will be whether the regulatory police will consist of intelligent people who think like you, or will they be dummies who think unlike you ? If they think unlike you, your organization may be in for extraordinarily expensive times, where the fact that they don't have you on the payroll any longer, will not offset the costs. Question: How are we going to best protect our owners and ourselves in this new environment Ciao, Vic Boersma
Re: Product Liability Directive
RON, There are three Directives you may want to look at: 85/374/EEC The Product Liability Directive 92/59 /EEC The Product Safety Directive 91/C 12/11 The proposed Services Liability Directive regards, Vic -- Forwarded Message -- From: Bjorn Hansen, INTERNET:b.n.han...@bnr.co.uk TO: Ron Pickard, INTERNET:r...@ncgwpc.syntellect.com EMC-PSTC, INTERNET:emc-p...@ieee.org TREG, INTERNET:t...@sdd.hp.com DATE: 10/01/96 13:23 RE: Re: Product Liability Directive Sender: owner-emc-p...@mail.ieee.org Received: from mail.ieee.org (rab.ieee.org [140.98.2.3]) by arl-img-7.compuserve.com (8.6.10/5.950515) id MAA17062; Wed, 10 Jan 1996 12:54:09 -0500 Received: by mail.ieee.org (8.6.12/8.6.12) id MAA14501; Wed, 10 Jan 1996 12:17:49 -0500 Message-Id: 9601101713.1...@storax.bnr.co.uk X-Sender: b...@storax.bnr.co.uk X-Mailer: Windows Eudora Version 1.4.4 Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii List-Post: emc-pstc@listserv.ieee.org Date: Wed, 10 Jan 1996 17:09:09 + To: Ron Pickard r...@ncgwpc.syntellect.com, EMC-PSTC emc-p...@ieee.org, TREG t...@sdd.hp.com From: b.n.han...@bnr.co.uk (Bjorn Hansen) Subject: Re: Product Liability Directive Sender: owner-emc-p...@mail.ieee.org Precedence: bulk Reply-To: b.n.han...@bnr.co.uk (Bjorn Hansen) X-Resent-To: Multiple Recipients emc-p...@mail.ieee.org X-Listname: emc-pstc X-List-Description: Product Safety Tech. Committee, EMC Society X-Info: Help requests to emc-pstc-requ...@mail.ieee.org X-Info: [Un]Subscribe requests to majord...@mail.ieee.org X-Moderator-Address: emc-pstc-appro...@mail.ieee.org Ron, This is the one you are looking for: Directive: 85/374/EEC, 25-Jul-85 Approximation of the laws, regulations and administrative provisions of the Member States concerning liability for defective products Regards, Bjorn Hansen At 09:38 10/01/96 PST, Ron Pickard wrote: Hello to all, I have read many articles that relate to the EU's Product Liability Directive, but there has been no mention to its document number (e.g., 73/23/EEC = LVD). I have also asked a few people for this, without success. I would like to purchase this document, but I cannot at this time because of the above dilemma. To this end, would any of you who know this information be able to provide me with it? Any help would be greatly appreciated. Thanks in advance for your help. Regards, Ron Pickard r...@syntellect.com Bjorn Hansen BNR Europe Ltd, Harlow, Essex b.n.han...@bnr.co.uk, ESN 742-3265, +44.1279.403265, Fax: +44 1279 451866
Re: World wide source for EMC amd Safety regulations and updates.
There are a number of private enterprisers that will provide you with copies of various directives on CD ROM or Floppies and provide updates every three months on a subscription basis. I know of at least one but there are probably more (Cost about $350 per year). If you need to me, drop me a line. Your favorite certification agency should have updated information on applicable standards, as that situation changes so that you can get IECEE Scheme Certifcates to back up your declarations. If you don't have a favorite protection house, drop me a line. Regards, Vic
