RE: European Standards in conflict with the EMC directive
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
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
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
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
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
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 > > - > > - > 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). -- 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 - 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). - This
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 > > - > > - > 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). -- 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 - 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: European Standards in conflict with the EMC directive
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 - - 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). - 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: European Standards in conflict with the EMC directive
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). > > > - 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: 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 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). - 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: 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).
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).