RE: European Standards in conflict with the EMC directive

1999-11-12 Thread Hougaard, Niels

Hello Kevin,

What you need to show conformity with the EMC directive is to fulfil a
harmonized standard, if such exist. (If there is no such standard that can
be used-that is another question.)
Other standards are not in question, at least not for the authorities, so
fulfil EN 50130-4, and ignore EN 54!
What costumers require can be different.

Conflicting standards and the fast growing number of standards (and so on)
has been and is a subject in the EU. The EU therefore started the SLIM
project (SLIM = Simpler Legislation for the Internal Market), with the aim
to point at where the EU legislation could be simplified. Members of the
SLIM task group were mainly people from the authorities in the EU member
states.

SLIM has beeen mentioned in this group before, so I looked in my archive:

>From 05.03.98

Hi everyone

The European Commission has just accepted that the EMC Directive is
to be one of the pieces of legislation to be reviewed under the SLIM
(Simpler Legislation for the Internal Market) initiative during 1998.
The UK had proposed a review of the directive during the last two
phases of SLIM, but had not receievd sufficient support.  This year there
was support from Austria, Denmark, France and Germany.

The review will take place during the next six months with a report
expected at the end of the year.
I do NOT expect to see major changes (such as removal of immunity)
and it is possible that there will be no changes recommended at all.  

I hope to be able to report a little more fully in the near future.

Best wishes

Brian Jones
Independent EMC Consultant, England
Telephone & Fax +44 1564 773319


Two places to find out more about the SLIM process:

www.cix.co.uk/~approval/ 
(select news article where there is a pair of articles, or search on
“SLIM”)

www.europa.eu.int/comm/dg03/directs/dg3d/d1/eleng/index.htm
it's all there. click on emc, then click on slim.

The SLIM process has brought up the Strategic Rewiev Panel (SRP) with the
aim of reviewing and when necessary simplify the world of EMC standards.
There was a SRP meeting at 29. Oktober, but I have not seen the minutes yet.

As a member of the Danish committee for EMC I have had and have the
possibility of giving inputs to both the SLIM and the SRP.
That is a way of telling that there are too many and too different and too
conflicting standards. Maybe especially for EU citizens, but I think, and
hope, that good ideas and advices are wellcome from all over the world.

Hope this can be of maybe some inspiration.
If you have comments don't hesitate to contact me

Regards

Niels Hougaard
EMC Engineer, B.Sc.E.E.
BARCO Communication Systems - Denmark
Emdrupvej 26
DK - 2100 Copenhagen
Denmark

Telephone   + 45 39 17 00 00
Direct  + 45 39 17 08 15
Fax + 45 39 17 00 10
E-mail  niels.houga...@barco.com
Web www.barco.com


> -Original Message-
> From: Kevin Harris [SMTP:harr...@dscltd.com]
> Sent: 10. november 1999 00:01
> To:   EMC-PSTC (E-mail)
> Subject:  RE: European Standards in conflict with the EMC directive
> 
> 
> Hello Again Group,
> 
> Well the group's total silence on this point is indeed interesting. Does
> nobody know how to proceed or is everyone just keeping their corporate
> heads
> down :
> Please reply offline if you feel uneasy answering this question in a
> public
> forum.
> 
> 
> Regards
> 
> Kevin Harris
> 
> 
> 
> -Original Message-
> From: Kevin Harris
> Sent: Monday, November 08, 1999 10:38 AM
> To: EMC-PSTC (E-mail)
> Subject: European Standards in conflict with the EMC directive
> 
> 
> 
> Greetings,
> 
> Is there an established procedure for demanding the withdrawal of EMC
> clauses within standards who's primary purpose is industry regulation, not
> EMC. In my company's industry there is an established product family
> standard for EMC (EN50130-4) but the good people at CENELEC seem to be
> ignoring the EMC directive, and have published within the last year or
> two,
> EN standards which include EMC testing clauses, with methods that are at
> odds with the EMC document EN50130-4 published in the OJ. Especially
> troubling to me is the fact that all of the test organisations that test
> for
> the industry regulation specification do not accept either third party or
> self declarations that the product is EMC compliant. I do not wish to test
> the same product more than once for a single market. What path do you
> recommend I follow to demand the repeal of these clauses.
> 
> 
> Best Regards,
> 
> 
> Kevin Harris
> Manager, Approval Services
> Digital Security Controls
> 3301 Langstaff Road
> Concord, Ontario
> CANADA
> L

RE: European Standards in conflict with the EMC directive

1999-11-12 Thread Crabb, John

I presume you have a copy of PD 6608:1997 = CENELEC REPORT
R079-001:1996, Guide to achieving compliance with EC directives for 
alarm systems. (I don't know if a more up-to-date version exists).
I bought this document to see what it said about safety, but it just 
said "EN 60950 shall apply".

I am NOT an EMC expert, so all I can do is quote 2 statements from
this document : -
"EMC 89/336 Immunity, the product family standard for immunity 
EN 50130-4 shall be used".

"For the time being the Commission did not decide which procedure
is applicable accordingly to Article 13.4 of the CPD Directive. In 
addition to that no Harmonized Standards for components of fire
detection and fire alarm systems have been published in the OJ of
the EU, neither bodies have been notified to issue European Technical
Approvals. Therefore, the CPD is not yet applicable."

I don't know if any this helps, or just adds to the confusion !!
Regards,
John Crabb, Development Excellence (Product Safety) , 
NCR  Financial Solutions Group Ltd.,  Kingsway West, Dundee, Scotland. DD2
3XX
E-Mail :john.cr...@scotland.ncr.com
Tel: +44 (0)1382-592289  (direct ). Fax +44 (0)1382-622243.   VoicePlus
6-341-2289.


> -Original Message-
> From: Ing. Gert Gremmen [SMTP:cet...@cetest.nl]
> Sent: 12 November 1999 08:43
> To:   Kevin Harris
> Cc:   Emc-Pstc
> Subject:  RE: European Standards in conflict with the EMC directive
> Importance:   High
> 
> 
> Here Kevin
> 
> The difference is between
> 
> EN 50130-4  for components of 
> EN 54  ...  for systems as a whole
> 
> The latter deals with requirements of reliability and safety for the whole
> installation
> the earlier deals with protection of the frequency spectrum (EMC
> directive)
> and functional immunity.
> 
> It would have been very nice if the two were made up from the same test
> suite with
> different criteria. They aren't, partially because different people made
> it,
> partially because systems are much larger and don't fit into the 130-4
> suite, and partially because the requirements are different.
> 
> There is also difference in enforcement of the two and in compliance
> routes
> (as you probably noted).
> 
> Regards,
> 
> Gert Gremmen Ing.
> 
> == Ce-test, Qualified testing ==
> Consultants in EMC, Electrical safety and Telecommunication
> Compliance tests for European standards and ce-marking
> Member of NEC/IEC voting committee for EMC.
> Our Web presence: http://www.cetest.nl
> List of current harmonized standards http://www.cetest.nl/emc-harm.htm
> 
> -Original Message-----
> From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org] On Behalf
> Of
> Kevin Harris
> Sent: woensdag 10 november 1999 18:16
> To:   EMC-PSTC (E-mail)
> Subject:  RE: European Standards in conflict with the EMC directive
> 
> 
> Hello All,
> 
> Well judging by the responses I worded my question poorly. I was trying to
> avoid specifics because I felt the general case would be more of interest
> to
> the group at large. So let me restate the problem.
> 
> 
> Generically
> 
> 1. There is a EMC family product specification for a product published in
> the OJ as a method of  showing compliance to the EMC directive.
> 
> 2. There is a CENELEC document which is published as a EN which is not
> part
> of any new approach directive. It contains (among a lot of other things)
> EMC
> testing clauses.
> 
> 3. CENELEC regulations require national standard organisations to
> implement
> European standards
> 
> 4.The EMC directive requires member countries to adopt standards published
> in the OJ for that directive
> 
> 5.Both CENELEC and the EMC directive require conflicting standards to be
> withdrawn.
> 
> 6.The EMC product family standard and the CENELEC standard have EMC tests
> and test methods which are at odds with each other. They therefor are
> conflicting standards.
> 
> 
> In my case specifically,
> 
> 1.The products are fire systems or components of fire systems
> 
> 2. The EMC family product spec is EN50130-4
> 
> 3. The CENELEC document is EN54 (In several parts) which is a performance
> standard for Fire detection systems
> 
> So my question would be
> 
>  Is there an established procedure for making requests that these groups
> harmonise and follow their own regulations? Does one complain to CENELEC,
> the European Commission or both or someone else entirely?
> 
> Jon Curtis mentioned in his reply that he thought  "attempting to change
> the
> way CENELEC does business is futile". but I think that still I must try
> for
> several reasons.
> 1. This double testing costs large companies like

RE: European Standards in conflict with the EMC directive

1999-11-12 Thread Ing. Gert Gremmen

Here Kevin

The difference is between

EN 50130-4  for components of 
EN 54  ...  for systems as a whole

The latter deals with requirements of reliability and safety for the whole
installation
the earlier deals with protection of the frequency spectrum (EMC directive)
and functional immunity.

It would have been very nice if the two were made up from the same test
suite with
different criteria. They aren't, partially because different people made it,
partially because systems are much larger and don't fit into the 130-4
suite, and partially because the requirements are different.

There is also difference in enforcement of the two and in compliance routes
(as you probably noted).

Regards,

Gert Gremmen Ing.

== Ce-test, Qualified testing ==
Consultants in EMC, Electrical safety and Telecommunication
Compliance tests for European standards and ce-marking
Member of NEC/IEC voting committee for EMC.
Our Web presence: http://www.cetest.nl
List of current harmonized standards http://www.cetest.nl/emc-harm.htm

-Original Message-
From:   owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org] On Behalf Of
Kevin Harris
Sent:   woensdag 10 november 1999 18:16
To: EMC-PSTC (E-mail)
Subject:    RE: European Standards in conflict with the EMC directive


Hello All,

Well judging by the responses I worded my question poorly. I was trying to
avoid specifics because I felt the general case would be more of interest to
the group at large. So let me restate the problem.


Generically

1. There is a EMC family product specification for a product published in
the OJ as a method of  showing compliance to the EMC directive.

2. There is a CENELEC document which is published as a EN which is not part
of any new approach directive. It contains (among a lot of other things) EMC
testing clauses.

3. CENELEC regulations require national standard organisations to implement
European standards

4.The EMC directive requires member countries to adopt standards published
in the OJ for that directive

5.Both CENELEC and the EMC directive require conflicting standards to be
withdrawn.

6.The EMC product family standard and the CENELEC standard have EMC tests
and test methods which are at odds with each other. They therefor are
conflicting standards.


In my case specifically,

1.The products are fire systems or components of fire systems

2. The EMC family product spec is EN50130-4

3. The CENELEC document is EN54 (In several parts) which is a performance
standard for Fire detection systems

So my question would be

 Is there an established procedure for making requests that these groups
harmonise and follow their own regulations? Does one complain to CENELEC,
the European Commission or both or someone else entirely?

Jon Curtis mentioned in his reply that he thought  "attempting to change the
way CENELEC does business is futile". but I think that still I must try for
several reasons.
1. This double testing costs large companies like ourselves tens of
thousands of dollars in added testing cost per year for no particular good
reason.
2. When it gets down to it, CENELEC actually is responsible for the EMC
document EN 50130-4 as well as the fire standard EN54. If we accept that
groups within the same standards organisation can't harmonise where does
that leave us on global standardisation.


BTW For those who think I'm advocating less stringent tests or missing
certain tests that is not my intent. EN50130-4 call out a much more
comprehensive test suite than EN54 and it uses test methods that are newer
than EN54.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel   +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020








-Original Message-
From: Grant, Tania (Tania) [mailto:tgr...@lucent.com]
Sent: Tuesday, November 09, 1999 9:42 PM
To: EMC-PSTC (E-mail); 'Kevin Harris'
Subject: RE: European Standards in conflict with the EMC directive



Kevin,

I cannot believe that we are all cowards here.   However, it may be that we
are unfamiliar with your subject matter.   I, for one, have never heard of
the EMC standard EN50130-4, don't know if it falls under the new approach
EMC Directive or not, and don't know what other EN standards it may be in
conflict with.   In other words, I cannot shed light on your subject.   I
would not be surprised if many have the same problem.   It might help if you
get a bit more specific here, such as, what are the conflicting EN
standards, and what are the specific conflicting clauses.

Tania Grant,   tgr...@lucent.com 
Lucent Technologies, Communications Applications Group


--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Tuesday, November 09, 1999 3:01 PM
To:  EMC-PSTC (E-mail)
Subject:  RE: European Standards in conflict with the EMC directive


Hello Again Group,

Well the group's total silence on this point is indeed inte

Re: European Standards in conflict with the EMC directive

1999-11-11 Thread Paul Cook

Kevin  & Listmates

I broke down and decided to check out EN 50103-4.  Here is what I found:

CENELEC EN 50130-4:1995 Alarm systems - Part 4: Electromagnetic
compatibility - Product family standard: Immunity requirements for
components of fire, intruder and social alarm systems

There is an amendment  -  Amendment A1:1998 to EN 50130-4:1995

It supercedes generic standards, but will not be a manadatory replacement
for them until
Jan 01, 2001.

Several observations:

1) EN 50130-4 can hardly conflict with the EMC directive.  The directive is
a bland
motherhood and apple pie document saying thou shall not make alot of noise,
and thou
should not be really susceptible to noise & legal signals.

2) I asume you meant to say that EN 50130-4 and its ammendments conflict
with
the generic immunity standards for residential or immuEN 50082-1 or 82-2.
But they are intended to do exactly that.  The dirty little secret of
immunity testing is that the generic standards are so generic, they are
almost meaingless.  Product family standards seek to improve this situation
by giving more specific deatils on testing such as operating configuration
of the EUT and specific pass fail criteria that better addresses the purpose
and function of products in that specific product family standard.

3)

>(snip)  . . What path do you
>recommend I follow to demand the repeal of these clauses?.
>

Were these international standards, such as the IEC, IEEE, SAE etc, you
might have some path for appeal.  CENELEC and EN standards are focused on
Europe, and the great unwashed mongol hordes of the rest of the world
(Americans, Canadians, etc.) don't amount to even a hill of beans.:):)  Some
would even suggest that's why they built fortress Europe, to make your life
more difficult. :):)

4) Sometimes there just isn't much you can do to avoid multiple testing.  If
you need lab A to bless your product, and they wont take your EMC data, then
you need to have them retest it or not have lab A bless your product.
Probably the best way to handle things is to do your own internal testing to
standards higher than the Europeans mandatory reqs, make your product pass
it, and then coast thru the final Eurpoean compliance test at Lab A for
certification.  Several companies I know have internal EMC standards that
are more severe than the European standards, because they have found out the
hard way that it really is a cold cruel world out there, with real unhappy
customers caused by preventable immunity failures.


I hope this helps.


Best Regards,

Paul Cook
NARTE Certified EMC Engineer
Alpha EMC Inc
8540 West River Rd
Minneapolis, Minnestoa 55444
Tel # (612)-561-2844
Fax #(612)-561-3400
E-mailpaulc...@skypoint.com
Specialty  -  EMC Consulting






-Original Message-
From: Grant, Tania (Tania) 
To: EMC-PSTC (E-mail) ; 'Kevin Harris'

List-Post: emc-pstc@listserv.ieee.org
Date: Tuesday, November 09, 1999 10:48 PM
Subject: RE: European Standards in conflict with the EMC directive


>
>Kevin,
>
>I cannot believe that we are all cowards here.   However, it may be that we
>are unfamiliar with your subject matter.   I, for one, have never heard of
>the EMC standard EN50130-4, don't know if it falls under the new approach
>EMC Directive or not, and don't know what other EN standards it may be in
>conflict with.   In other words, I cannot shed light on your subject.   I
>would not be surprised if many have the same problem.   It might help if
you
>get a bit more specific here, such as, what are the conflicting EN
>standards, and what are the specific conflicting clauses.
>
>Tania Grant,   tgr...@lucent.com 
>Lucent Technologies, Communications Applications Group
>
>
>--
>From:  Kevin Harris [SMTP:harr...@dscltd.com]
>Sent:  Tuesday, November 09, 1999 3:01 PM
>To:  EMC-PSTC (E-mail)
>Subject:  RE: European Standards in conflict with the EMC directive
>
>
>Hello Again Group,
>
>Well the group's total silence on this point is indeed interesting. Does
>nobody know how to proceed or is everyone just keeping their corporate
heads
>down :
>Please reply offline if you feel uneasy answering this question in a public
>forum.
>
>
>Regards
>
>Kevin Harris
>
>
>
>-Original Message-
>From: Kevin Harris [mailto:harr...@dscltd.com]
>Sent: Monday, November 08, 1999 10:38 AM
>To: EMC-PSTC (E-mail)
>Subject: European Standards in conflict with the EMC directive
>
>
>
>Greetings,
>
>Is there an established procedure for demanding the withdrawal of EMC
>clauses within standards who's primary purpose is industry regulation, not
>EMC. In my company's industry there is an established product family
>standard for EMC (EN50130-4) but the good people at CENELEC seem to be
>ignoring the EMC directive, and have published within the

RE: European Standards in conflict with the EMC directive

1999-11-10 Thread Kevin Harris

Hello All,

Well judging by the responses I worded my question poorly. I was trying to
avoid specifics because I felt the general case would be more of interest to
the group at large. So let me restate the problem. 


Generically

1. There is a EMC family product specification for a product published in
the OJ as a method of  showing compliance to the EMC directive.

2. There is a CENELEC document which is published as a EN which is not part
of any new approach directive. It contains (among a lot of other things) EMC
testing clauses.

3. CENELEC regulations require national standard organisations to implement
European standards

4.The EMC directive requires member countries to adopt standards published
in the OJ for that directive

5.Both CENELEC and the EMC directive require conflicting standards to be
withdrawn.

6.The EMC product family standard and the CENELEC standard have EMC tests
and test methods which are at odds with each other. They therefor are
conflicting standards.


In my case specifically,

1.The products are fire systems or components of fire systems

2. The EMC family product spec is EN50130-4

3. The CENELEC document is EN54 (In several parts) which is a performance
standard for Fire detection systems

So my question would be

 Is there an established procedure for making requests that these groups
harmonise and follow their own regulations? Does one complain to CENELEC,
the European Commission or both or someone else entirely?

Jon Curtis mentioned in his reply that he thought  "attempting to change the
way CENELEC does business is futile". but I think that still I must try for
several reasons. 
1. This double testing costs large companies like ourselves tens of
thousands of dollars in added testing cost per year for no particular good
reason.
2. When it gets down to it, CENELEC actually is responsible for the EMC
document EN 50130-4 as well as the fire standard EN54. If we accept that
groups within the same standards organisation can't harmonise where does
that leave us on global standardisation.


BTW For those who think I'm advocating less stringent tests or missing
certain tests that is not my intent. EN50130-4 call out a much more
comprehensive test suite than EN54 and it uses test methods that are newer
than EN54.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel   +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020 








-Original Message-
From: Grant, Tania (Tania) [mailto:tgr...@lucent.com]
Sent: Tuesday, November 09, 1999 9:42 PM
To: EMC-PSTC (E-mail); 'Kevin Harris'
Subject: RE: European Standards in conflict with the EMC directive



Kevin,

I cannot believe that we are all cowards here.   However, it may be that we
are unfamiliar with your subject matter.   I, for one, have never heard of
the EMC standard EN50130-4, don't know if it falls under the new approach
EMC Directive or not, and don't know what other EN standards it may be in
conflict with.   In other words, I cannot shed light on your subject.   I
would not be surprised if many have the same problem.   It might help if you
get a bit more specific here, such as, what are the conflicting EN
standards, and what are the specific conflicting clauses.  

Tania Grant,   tgr...@lucent.com   
Lucent Technologies, Communications Applications Group


--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Tuesday, November 09, 1999 3:01 PM
To:  EMC-PSTC (E-mail)
Subject:  RE: European Standards in conflict with the EMC directive


Hello Again Group,

Well the group's total silence on this point is indeed interesting. Does
nobody know how to proceed or is everyone just keeping their corporate heads
down :
Please reply offline if you feel uneasy answering this question in a public
forum.


Regards

Kevin Harris



-Original Message-
From: Kevin Harris [mailto:harr...@dscltd.com]
Sent: Monday, November 08, 1999 10:38 AM
To: EMC-PSTC (E-mail)
Subject: European Standards in conflict with the EMC directive



Greetings,

Is there an established procedure for demanding the withdrawal of EMC
clauses within standards who's primary purpose is industry regulation, not
EMC. In my company's industry there is an established product family
standard for EMC (EN50130-4) but the good people at CENELEC seem to be
ignoring the EMC directive, and have published within the last year or two,
EN standards which include EMC testing clauses, with methods that are at
odds with the EMC document EN50130-4 published in the OJ. Especially
troubling to me is the fact that all of the test organisations that test for
the industry regulation specification do not accept either third party or
self declarations that the product is EMC compliant. I do not wish to test
the same product more than once for a single market. What path do you
recommend I follow to demand the repeal of these cl

RE: European Standards in conflict with the EMC directive

1999-11-10 Thread Rate, Simon

Dear Kevin,

I used to work in the alarm industry, and in fact sat on the CENELEC TC
developing EN50130-4 the EMC Immunity Standard For Components of Fire,
Intruder and Social Alarm Systems.

I believe your e mail may be referring to the product performance standards
such as EN 54 for Fire Alarm Systems (I believe there may be an equivalent
for Intruder Alarms by now) that include EMC requirements.   My
understanding is that these requirements are voluntary and that as they are
not listed in the OJ, are not therefore required by the EMC Directive or CE
marking.

You do raise a valid question however, as to why CENELEC has kept the EMC
clauses in these performance standards.

I would be happy to discuss this further with you off line.

Regards,

Simon Rate
Engineering Manager
Product Safety
Gateway Products

Ph: 605 232 2230, Ext 26953
Fax: 605 232 2814
E Mail: simon.r...@gateway.com





-Original Message-
From: Jon D. Curtis [mailto:j...@curtis-straus.com]
Sent: Wednesday, November 10, 1999 7:23 AM
To: Kevin Harris
Cc: EMC-PSTC (E-mail)
Subject: Re: European Standards in conflict with the EMC directive



I suspect that given the group's proclivity to talk endlessly on almost any
topic that the real reason that you got no response was that no one
understood
your question sufficiently to answer it.  You obviously have an alarm
system.
You have some other EN standard which is in conflict with the alarm EMC
standard.  You have some authorizing bodies which don't accept your data.
You
are unhappy about the situation.

What standard is in conflict with the alarm standard?
Why is it being applied to your product?
Does your product fall into multiple product families?
What approvals are you approaching a certifier for?
Who is the certifier?

BTW: attempting to change the way CENELEC does business is futile.  You will
be
attempting a remedy on government time frames for a problem with commercial
time
frames.  You are advocating from a small constituency (alarm systems)
against
what is likely a larger constituency.  Your best bet is to figure out what
they
want, the easiest way to do it, and give it to them.

Kevin Harris wrote:

> Hello Again Group,
>
> Well the group's total silence on this point is indeed interesting. Does
> nobody know how to proceed or is everyone just keeping their corporate
heads
> down :
> Please reply offline if you feel uneasy answering this question in a
public
> forum.
>
> Regards
>
> Kevin Harris
>
> -Original Message-
> From: Kevin Harris [mailto:harr...@dscltd.com]
> Sent: Monday, November 08, 1999 10:38 AM
> To: EMC-PSTC (E-mail)
> Subject: European Standards in conflict with the EMC directive
>
> Greetings,
>
> Is there an established procedure for demanding the withdrawal of EMC
> clauses within standards who's primary purpose is industry regulation, not
> EMC. In my company's industry there is an established product family
> standard for EMC (EN50130-4) but the good people at CENELEC seem to be
> ignoring the EMC directive, and have published within the last year or
two,
> EN standards which include EMC testing clauses, with methods that are at
> odds with the EMC document EN50130-4 published in the OJ. Especially
> troubling to me is the fact that all of the test organisations that test
for
> the industry regulation specification do not accept either third party or
> self declarations that the product is EMC compliant. I do not wish to test
> the same product more than once for a single market. What path do you
> recommend I follow to demand the repeal of these clauses.
>
> Best Regards,
>
> Kevin Harris
> Manager, Approval Services
> Digital Security Controls
> 3301 Langstaff Road
> Concord, Ontario
> CANADA
> L4K 4L2
>
> Tel   +1 905 760 3000 Ext. 2378
> Fax +1 905 760 3020
>
> -
>
> -
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Curtis-Straus LLC j...@curtis-straus.com
Laboratory for EMC, Safety, NEBS, SEMI-S2 and Telecom
527 Great Roadvoice (978) 486-8880
Littleton, MA 01460   fax   (978) 486-8828
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Re: European Standards in conflict with the EMC directive

1999-11-10 Thread Jon D. Curtis

I suspect that given the group's proclivity to talk endlessly on almost any
topic that the real reason that you got no response was that no one understood
your question sufficiently to answer it.  You obviously have an alarm system.
You have some other EN standard which is in conflict with the alarm EMC
standard.  You have some authorizing bodies which don't accept your data.  You
are unhappy about the situation.

What standard is in conflict with the alarm standard?
Why is it being applied to your product?
Does your product fall into multiple product families?
What approvals are you approaching a certifier for?
Who is the certifier?

BTW: attempting to change the way CENELEC does business is futile.  You will be
attempting a remedy on government time frames for a problem with commercial time
frames.  You are advocating from a small constituency (alarm systems) against
what is likely a larger constituency.  Your best bet is to figure out what they
want, the easiest way to do it, and give it to them.

Kevin Harris wrote:

> Hello Again Group,
>
> Well the group's total silence on this point is indeed interesting. Does
> nobody know how to proceed or is everyone just keeping their corporate heads
> down :
> Please reply offline if you feel uneasy answering this question in a public
> forum.
>
> Regards
>
> Kevin Harris
>
> -Original Message-
> From: Kevin Harris [mailto:harr...@dscltd.com]
> Sent: Monday, November 08, 1999 10:38 AM
> To: EMC-PSTC (E-mail)
> Subject: European Standards in conflict with the EMC directive
>
> Greetings,
>
> Is there an established procedure for demanding the withdrawal of EMC
> clauses within standards who's primary purpose is industry regulation, not
> EMC. In my company's industry there is an established product family
> standard for EMC (EN50130-4) but the good people at CENELEC seem to be
> ignoring the EMC directive, and have published within the last year or two,
> EN standards which include EMC testing clauses, with methods that are at
> odds with the EMC document EN50130-4 published in the OJ. Especially
> troubling to me is the fact that all of the test organisations that test for
> the industry regulation specification do not accept either third party or
> self declarations that the product is EMC compliant. I do not wish to test
> the same product more than once for a single market. What path do you
> recommend I follow to demand the repeal of these clauses.
>
> Best Regards,
>
> Kevin Harris
> Manager, Approval Services
> Digital Security Controls
> 3301 Langstaff Road
> Concord, Ontario
> CANADA
> L4K 4L2
>
> Tel   +1 905 760 3000 Ext. 2378
> Fax +1 905 760 3020
>
> -
>
> -
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> To cancel your subscription, send mail to majord...@ieee.org
> with the single line: "unsubscribe emc-pstc" (without the
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> jim_bac...@monarch.com, ri...@sdd.hp.com, or
> roger.volgst...@compaq.com (the list administrators).

--
Jon D. Curtis, PE

Curtis-Straus LLC j...@curtis-straus.com
Laboratory for EMC, Safety, NEBS, SEMI-S2 and Telecom
527 Great Roadvoice (978) 486-8880
Littleton, MA 01460   fax   (978) 486-8828
http://www.curtis-straus.com



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RE: European Standards in conflict with the EMC directive

1999-11-10 Thread WOODS

I can understand your frustration Kevin. Consider how standards come to be.
First the Commission gives a mandate to CENELEC to develop a standard in
support of the essential requirements of a particular directive. The
Commission monitors the development of the standard, so they have a strong
influence over its contents. Once the standard has been approved by CENELEC,
you can bet that the standard is also acceptable to the Commission. It is
then published in the OJ. Therefore, it is not CENELEC that you should be
throwing darts at, rather it is the Commission. Also remember that the
standards are voluntary. You can always build a technical construction file
and not abide by the tests you feel are unnecessary if you can get a
Notified Body to agree with you.

Richard Woods

--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Tuesday, November 09, 1999 6:01 PM
To:  EMC-PSTC (E-mail)
Subject:  RE: European Standards in conflict with the EMC directive


Hello Again Group,

Well the group's total silence on this point is indeed interesting.
Does
nobody know how to proceed or is everyone just keeping their
corporate heads
down :
Please reply offline if you feel uneasy answering this question in a
public
forum.


Regards

Kevin Harris



-Original Message-
From: Kevin Harris [mailto:harr...@dscltd.com]
Sent: Monday, November 08, 1999 10:38 AM
To: EMC-PSTC (E-mail)
Subject: European Standards in conflict with the EMC directive



Greetings,

Is there an established procedure for demanding the withdrawal of
EMC
clauses within standards who's primary purpose is industry
regulation, not
EMC. In my company's industry there is an established product family
standard for EMC (EN50130-4) but the good people at CENELEC seem to
be
ignoring the EMC directive, and have published within the last year
or two,
EN standards which include EMC testing clauses, with methods that
are at
odds with the EMC document EN50130-4 published in the OJ. Especially
troubling to me is the fact that all of the test organisations that
test for
the industry regulation specification do not accept either third
party or
self declarations that the product is EMC compliant. I do not wish
to test
the same product more than once for a single market. What path do
you
recommend I follow to demand the repeal of these clauses.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel   +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020 


-

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Re: European Standards in conflict with the EMC directive

1999-11-10 Thread Richard Lanzillotto

I recommend you contact the Technical committee at Cenelec responsible for
authoring the standard to ascertain the reason for the clauses. They may
shed some light on what you consider to be inconsistencies in the
regulations.

Rich Lanzillotto
-Original Message-
From: Kevin Harris 
To: EMC-PSTC (E-mail) 
List-Post: emc-pstc@listserv.ieee.org
Date: Tuesday, November 09, 1999 6:23 PM
Subject: RE: European Standards in conflict with the EMC directive


>
>Hello Again Group,
>
>Well the group's total silence on this point is indeed interesting. Does
>nobody know how to proceed or is everyone just keeping their corporate
heads
>down :
>Please reply offline if you feel uneasy answering this question in a public
>forum.
>
>
>Regards
>
>Kevin Harris
>
>
>
>-Original Message-
>From: Kevin Harris [mailto:harr...@dscltd.com]
>Sent: Monday, November 08, 1999 10:38 AM
>To: EMC-PSTC (E-mail)
>Subject: European Standards in conflict with the EMC directive
>
>
>
>Greetings,
>
>Is there an established procedure for demanding the withdrawal of EMC
>clauses within standards who's primary purpose is industry regulation, not
>EMC. In my company's industry there is an established product family
>standard for EMC (EN50130-4) but the good people at CENELEC seem to be
>ignoring the EMC directive, and have published within the last year or two,
>EN standards which include EMC testing clauses, with methods that are at
>odds with the EMC document EN50130-4 published in the OJ. Especially
>troubling to me is the fact that all of the test organisations that test
for
>the industry regulation specification do not accept either third party or
>self declarations that the product is EMC compliant. I do not wish to test
>the same product more than once for a single market. What path do you
>recommend I follow to demand the repeal of these clauses.
>
>
>Best Regards,
>
>
>Kevin Harris
>Manager, Approval Services
>Digital Security Controls
>3301 Langstaff Road
>Concord, Ontario
>CANADA
>L4K 4L2
>
>Tel   +1 905 760 3000 Ext. 2378
>Fax +1 905 760 3020
>
>
>-
>
>-
>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).
>
>
>


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RE: European Standards in conflict with the EMC directive

1999-11-10 Thread Grant, Tania (Tania)

Kevin,

I cannot believe that we are all cowards here.   However, it may be that we
are unfamiliar with your subject matter.   I, for one, have never heard of
the EMC standard EN50130-4, don't know if it falls under the new approach
EMC Directive or not, and don't know what other EN standards it may be in
conflict with.   In other words, I cannot shed light on your subject.   I
would not be surprised if many have the same problem.   It might help if you
get a bit more specific here, such as, what are the conflicting EN
standards, and what are the specific conflicting clauses.  

Tania Grant,   tgr...@lucent.com   
Lucent Technologies, Communications Applications Group


--
From:  Kevin Harris [SMTP:harr...@dscltd.com]
Sent:  Tuesday, November 09, 1999 3:01 PM
To:  EMC-PSTC (E-mail)
Subject:  RE: European Standards in conflict with the EMC directive


Hello Again Group,

Well the group's total silence on this point is indeed interesting. Does
nobody know how to proceed or is everyone just keeping their corporate heads
down :
Please reply offline if you feel uneasy answering this question in a public
forum.


Regards

Kevin Harris



-Original Message-
From: Kevin Harris [mailto:harr...@dscltd.com]
Sent: Monday, November 08, 1999 10:38 AM
To: EMC-PSTC (E-mail)
Subject: European Standards in conflict with the EMC directive



Greetings,

Is there an established procedure for demanding the withdrawal of EMC
clauses within standards who's primary purpose is industry regulation, not
EMC. In my company's industry there is an established product family
standard for EMC (EN50130-4) but the good people at CENELEC seem to be
ignoring the EMC directive, and have published within the last year or two,
EN standards which include EMC testing clauses, with methods that are at
odds with the EMC document EN50130-4 published in the OJ. Especially
troubling to me is the fact that all of the test organisations that test for
the industry regulation specification do not accept either third party or
self declarations that the product is EMC compliant. I do not wish to test
the same product more than once for a single market. What path do you
recommend I follow to demand the repeal of these clauses.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel   +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020 


-

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RE: European Standards in conflict with the EMC directive

1999-11-09 Thread Kevin Harris

Hello Again Group,

Well the group's total silence on this point is indeed interesting. Does
nobody know how to proceed or is everyone just keeping their corporate heads
down :
Please reply offline if you feel uneasy answering this question in a public
forum.


Regards

Kevin Harris



-Original Message-
From: Kevin Harris [mailto:harr...@dscltd.com]
Sent: Monday, November 08, 1999 10:38 AM
To: EMC-PSTC (E-mail)
Subject: European Standards in conflict with the EMC directive



Greetings,

Is there an established procedure for demanding the withdrawal of EMC
clauses within standards who's primary purpose is industry regulation, not
EMC. In my company's industry there is an established product family
standard for EMC (EN50130-4) but the good people at CENELEC seem to be
ignoring the EMC directive, and have published within the last year or two,
EN standards which include EMC testing clauses, with methods that are at
odds with the EMC document EN50130-4 published in the OJ. Especially
troubling to me is the fact that all of the test organisations that test for
the industry regulation specification do not accept either third party or
self declarations that the product is EMC compliant. I do not wish to test
the same product more than once for a single market. What path do you
recommend I follow to demand the repeal of these clauses.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel   +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020 


-

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European Standards in conflict with the EMC directive

1999-11-08 Thread Kevin Harris

Greetings,

Is there an established procedure for demanding the withdrawal of EMC
clauses within standards who's primary purpose is industry regulation, not
EMC. In my company's industry there is an established product family
standard for EMC (EN50130-4) but the good people at CENELEC seem to be
ignoring the EMC directive, and have published within the last year or two,
EN standards which include EMC testing clauses, with methods that are at
odds with the EMC document EN50130-4 published in the OJ. Especially
troubling to me is the fact that all of the test organisations that test for
the industry regulation specification do not accept either third party or
self declarations that the product is EMC compliant. I do not wish to test
the same product more than once for a single market. What path do you
recommend I follow to demand the repeal of these clauses.


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel   +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020 


-
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