re: CE without LVD?
John,
Ah! but there is such a thing as information overload!
Richard
From: john.al...@era.co.uk [mailto:john.al...@era.co.uk]
Sent: Monday, June 30, 2003 12:20 PM
To: richhug...@aol.com; nick.willi...@conformance.co.uk
Cc: emc-p...@majordomo.ieee.org
Subject: RE: CE without LVD?
Richard
Not arguing the point either way!
Just adding to the pot of information (or so I thought!)
My general reaction to this type of situation is:
- The left hand?
- The right hand??
- The one in the middle???
(think about it!)
Regards
John Allen
From: richhug...@aol.com [mailto:richhug...@aol.com]
Sent: 30 June 2003 13:22
To: john.al...@era.co.uk; nick.willi...@conformance.co.uk
Cc: emc-p...@majordomo.ieee.org
Subject: Re: CE without LVD?
John,
If proof were needed that one branch of the Commission doesn't know what the
other branch is doing then [COM(2003) 252 Final, of 12 May 2003] is it.
All I can say is that many times now I have sat in rooms in Brussels with
the European Commission; the DTI and their counterparts in other Member
States; industry representatives, consumer groups; and standards bodies
where the revision of the LVD has been under discussion in the Working
Group LVD Update since May 2001 {in fact, even before that if you take into
account the discussions within the full LVD Working Party (Working Party of
Governmental Experts on Directive 73/23/EEC}. As indicated in my message
late last Friday, the Commission ARE producing a draft revision to the LVD
that goes down to zero volts. As I also indicated before, it is not (quite)
a done deal that the LVD will do down to zero volts with the upper voltage
limits remaining the same (unlike the RTTED, which has now lower limits and
no higher limits either).
I have previously provided this group with the latest information on the
changes to the LVD that, to my knowledge, exists within the public domain.
Of course John, if you want a second opinion then please contact the DTI
yourself: subsequently, please let this group know I was correct all along.
Thanks,
Richard Hughes
Safety Answers Ltd.
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RE: CE without LVD?
Richard
Not arguing the point either way!
Just adding to the pot of information (or so I thought!)
My general reaction to this type of situation is:
- The left hand?
- The right hand??
- The one in the middle???
(think about it!)
Regards
John Allen
From: richhug...@aol.com [mailto:richhug...@aol.com]
Sent: 30 June 2003 13:22
To: john.al...@era.co.uk; nick.willi...@conformance.co.uk
Cc: emc-p...@majordomo.ieee.org
Subject: Re: CE without LVD?
John,
If proof were needed that one branch of the Commission doesn't know what the
other branch is doing then [COM(2003) 252 Final, of 12 May 2003] is it.
All I can say is that many times now I have sat in rooms in Brussels with the
European Commission; the DTI and their counterparts in other Member States;
industry representatives, consumer groups; and standards bodies where the
revision of the LVD has been under discussion in the Working Group LVD
Update since May 2001 {in fact, even before that if you take into account the
discussions within the full LVD Working Party (Working Party of Governmental
Experts on Directive 73/23/EEC}. As indicated in my message late last Friday,
the Commission ARE producing a draft revision to the LVD that goes down to
zero volts. As I also indicated before, it is not (quite) a done deal that
the LVD will do down to zero volts with the upper voltage limits remaining the
same (unlike the RTTED, which has now lower limits and no higher limits
either).
I have previously provided this group with the latest information on the
changes to the LVD that, to my knowledge, exists within the public domain.
Of course John, if you want a second opinion then please contact the DTI
yourself: subsequently, please let this group know I was correct all along.
Thanks,
Richard Hughes
Safety Answers Ltd.
_
This e-mail has been scanned for viruses by MCI's Internet Managed Scanning
Services - powered by MessageLabs. For further information visit
http://www.mci.com
*
Copyright ERA Technology Ltd. 2003. (www.era.co.uk). All rights reserved.
The information supplied in this Commercial Communication should be treated
in confidence.
No liability whatsoever is accepted for any loss or damage
suffered as a result of accessing this message or any attachments.
_
This e-mail has been scanned for viruses by MCI's Internet Managed Scanning
Services - powered by MessageLabs. For further information visit
http://www.mci.com
Re: CE without LVD?
John,
If proof were needed that one branch of the Commission doesn't know what the
other branch is doing then [COM(2003) 252 Final, of 12 May 2003] is it.
All I can say is that many times now I have sat in rooms in Brussels with the
European Commission; the DTI and their counterparts in other Member States;
industry representatives, consumer groups; and standards bodies where the
revision of the LVD has been under discussion in the Working Group LVD
Update since May 2001 {in fact, even before that if you take into account the
discussions within the full LVD Working Party (Working Party of Governmental
Experts on Directive 73/23/EEC}. As indicated in my message late last Friday,
the Commission ARE producing a draft revision to the LVD that goes down to
zero volts. As I also indicated before, it is not (quite) a done deal that
the LVD will do down to zero volts with the upper voltage limits remaining the
same (unlike the RTTED, which has now lower limits and no higher limits
either).
I have previously provided this group with the latest information on the
changes to the LVD that, to my knowledge, exists within the public domain.
Of course John, if you want a second opinion then please contact the DTI
yourself: subsequently, please let this group know I was correct all along.
Thanks,
Richard Hughes
Safety Answers Ltd.
Re: CE without LVD?
I read in !emc-pstc that drcuthb...@micron.com wrote (in E6F64B42266D6 54b80a0f7f4b98212a50ec...@ntxboimbx03.micron.com) about 'CE without LVD?' on Fri, 27 Jun 2003: Yes I once had a device that was SELV and this caused some confusion. We designed it to meet EN61010 as it was a piece of lab equipment. It was powered by a 5 volt, 40 amp power supply. We designed/tested for single component faults, temperature, etc. In the end, a large safety testing company informed us that no testing was required at all since it was SELV. I still do not agree with their assessment. 200 W input under normal operating conditions! You could have arranged to have one burn up in their CEO's office to prove your point! -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
re: CE without LVD?
Nick, Agreed it is not yet a done deal and the UK does have one or two other Member States on its side. However, unless significantly more Member States (and certain parts of industry I may add) come over to the UK way of looking at things, then it seems highly likely that the output document from the existing Commission working group will have the lower voltage limits. Of course, there are many more procedures to be gone through before the draft that is presently being discussed between the Commission and certain other interested parties sees its way into the Official Journal as a Directive (whether that be an amendment or a replacement for 73/23/EEC - TBD still). The Parliament and various other EU bodies have to have their say and so change is certainly possible. Also, once the Directive has been published there will be a period for Member States to amend their existing national legislation to bring it into line with the new version. So 'soon' is unlikely to be less than 2 1/2 years and could easily be 5 years or even longer. Therefore, many consumer products will have been placed on the market, retired and their successors also withdrawn from the market before those companies have to start worrying about complying with the amended LVD. Of course, if you make products with a very long lifetime (then about now may be time to start planning for what may happen in the future). But don't take my word for it, speak to the DTI or the Commission yourself! Richard Hughes Safety Answers Ltd. From: nick.willi...@conformance.co.uk [mailto:nick.willi...@conformance.co.uk] Sent: Friday, June 27, 2003 6:43 PM To: dcerece...@pelco.com Cc: ri...@sdd.hp.com; david.gelf...@memotec.com; emc-p...@majordomo.ieee.org Subject: RE: CE without LVD? The removal of the lower voltage limits from the definition of the LVD scope is not yet a 'done deal'. In particular, the official UK position is that the costs to industry which would result from this change would outweigh the benefits and so our current position (as of 30 May 2003) is that we oppose the change. Rgds Nick. Opinions of the author do not necessarily reflect those of the UK Government, and vice versa. :-) At 10:26 -0700 27/6/03, Cereceres, David wrote: Mr. Nute, In regards to your suggestions below, would it not be wise to take into consideration the future plans of the LVD? My understanding is that the LVD will soon be called the EPSD. Part of this change will encompass what is referred as No Risk / Low Risk equipment. Would it be safe to say that the current definition of equipment designed for use with a voltage rating of 50-1000 V ac will change to equipment for use with a voltage rating of 0-1000V ac? the opinions of this group are always appreciated, David Cereceres Safety Engineer Pelco This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: CE without LVD?
The removal of the lower voltage limits from the definition of the LVD scope is not yet a 'done deal'. In particular, the official UK position is that the costs to industry which would result from this change would outweigh the benefits and so our current position (as of 30 May 2003) is that we oppose the change. Rgds Nick. Opinions of the author do not necessarily reflect those of the UK Government, and vice versa. :-) At 10:26 -0700 27/6/03, Cereceres, David wrote: Mr. Nute, In regards to your suggestions below, would it not be wise to take into consideration the future plans of the LVD? My understanding is that the LVD will soon be called the EPSD. Part of this change will encompass what is referred as No Risk / Low Risk equipment. Would it be safe to say that the current definition of equipment designed for use with a voltage rating of 50-1000 V ac will change to equipment for use with a voltage rating of 0-1000V ac? the opinions of this group are always appreciated, David Cereceres Safety Engineer Pelco This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: CE without LVD?
Hi David: In regards to your suggestions below, would it not be wise to take into consideration the future plans of the LVD? The original question was specific to the LVD. My response was specific to the LVD. You raise a new question with regard to a future EU directive, the requirements of which may very well be quite onerous, and possibly quite out of line with the three-block models for injury and safety, from what I've heard. Each manufacturer should keep abreast of the EU activity, and decide for himself as to what action he should take now in anticipation of a future directive. Best regards, Rich This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: CE without LVD?
I also heard the future incarnation of the LVD will start at 0V From: Cereceres, David [mailto:dcerece...@pelco.com] Sent: Friday, June 27, 2003 1:27 PM To: 'Rich Nute'; david.gelf...@memotec.com Cc: emc-p...@majordomo.ieee.org Subject: RE: CE without LVD? Mr. Nute, In regards to your suggestions below, would it not be wise to take into consideration the future plans of the LVD? My understanding is that the LVD will soon be called the EPSD. Part of this change will encompass what is referred as No Risk / Low Risk equipment. Would it be safe to say that the current definition of equipment designed for use with a voltage rating of 50-1000 V ac will change to equipment for use with a voltage rating of 0-1000V ac? the opinions of this group are always appreciated, David Cereceres Safety Engineer Pelco -Original Message- From: Rich Nute [mailto:ri...@sdd.hp.com] Sent: Friday, June 27, 2003 9:00 AM To: david.gelf...@memotec.com Cc: emc-p...@majordomo.ieee.org Subject:Re: CE without LVD? Hi David: It is being suggested that this product does not need safety testing and does not need to include the reference to EN 60950 and the LVD in the CE DoC, since it is SELV circuits only. The LVD applies to products with voltage ratings between 50 and 1000 V ac and between 75 and 1500 V dc. SELV does not exceed 30 V ac and 60 V dc. Therefore, the LVD does not apply to a product that operates from a SELV source of supply. (We may be able to say that the LVD does not apply to a Class III product.) However, it is appropriate to indicate in the DoC that the LVD does not apply to the product because the product voltage is below the lower limits of the LVD. HOWEVER... EN 60950 applies to products powered from a SELV source of supply. The electric shock requirements do not apply to such products, but the other EN 60950 requirements do apply to such products. These other requirements include the so-called energy hazard requirements, mechanical requirements, and fire requirements. So, the product does indeed require safety testing, but not with respect to the LVD. The DoC should indicate compliance with EN 60950. Pragmatically, since you must test for compliance to EN 60950 for these other requirements, it is just as easy to indicate compliance to the LVD via EN 60950 and thereby avoid any future argument whether the LVD applies or not. Most of our inkjet printer products are powered by an external SELV source of supply. We test to EN 60950 and declare compliance with the LVD. Best regards, Rich This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: CE without LVD?
Mr. Nute, In regards to your suggestions below, would it not be wise to take into consideration the future plans of the LVD? My understanding is that the LVD will soon be called the EPSD. Part of this change will encompass what is referred as No Risk / Low Risk equipment. Would it be safe to say that the current definition of equipment designed for use with a voltage rating of 50-1000 V ac will change to equipment for use with a voltage rating of 0-1000V ac? the opinions of this group are always appreciated, David Cereceres Safety Engineer Pelco -Original Message- From: Rich Nute [mailto:ri...@sdd.hp.com] Sent: Friday, June 27, 2003 9:00 AM To: david.gelf...@memotec.com Cc: emc-p...@majordomo.ieee.org Subject:Re: CE without LVD? Hi David: It is being suggested that this product does not need safety testing and does not need to include the reference to EN 60950 and the LVD in the CE DoC, since it is SELV circuits only. The LVD applies to products with voltage ratings between 50 and 1000 V ac and between 75 and 1500 V dc. SELV does not exceed 30 V ac and 60 V dc. Therefore, the LVD does not apply to a product that operates from a SELV source of supply. (We may be able to say that the LVD does not apply to a Class III product.) However, it is appropriate to indicate in the DoC that the LVD does not apply to the product because the product voltage is below the lower limits of the LVD. HOWEVER... EN 60950 applies to products powered from a SELV source of supply. The electric shock requirements do not apply to such products, but the other EN 60950 requirements do apply to such products. These other requirements include the so-called energy hazard requirements, mechanical requirements, and fire requirements. So, the product does indeed require safety testing, but not with respect to the LVD. The DoC should indicate compliance with EN 60950. Pragmatically, since you must test for compliance to EN 60950 for these other requirements, it is just as easy to indicate compliance to the LVD via EN 60950 and thereby avoid any future argument whether the LVD applies or not. Most of our inkjet printer products are powered by an external SELV source of supply. We test to EN 60950 and declare compliance with the LVD. Best regards, Rich This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: CE without LVD?
Hello David, Your issue is not new. I have been in a similar situation where the same argument was made for a product powered by SELV. However, EN 60950 addresses other safety issues with products other than electrically caused fire and electrical shock. One needs to also address the mechanical and electro-mechanical safety issues as well. A good example is an SELV powered printer. Best regards, Ron Wellman At 10:19 AM 6/27/2003 -0400, David Gelfand wrote: Hello Group, A ITE product (not ours!) is powered by an CE marked external ac-dc power supply and has only SELV ports. I believe this product must be tested to EN 60950, and that in the CE Declaration of Conformity it must declare conformity to the LVD via EN 60590. It is being suggested that this product does not need safety testing and does not need to include the reference to EN 60950 and the LVD in the CE DoC, since it is SELV circuits only. Can you provide me with references to back my point of view? Thanks, David. David Gelfand Approvals/Design Engineer Memotec Inc. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: CE without LVD?
I read in !emc-pstc that David Gelfand david.gelf...@memotec.com wrote (in db3b83f22a576e41983ea8bfa15af2f30577d...@mtlex01.nexxlink.int) about 'CE without LVD?' on Fri, 27 Jun 2003: A ITE product (not ours!) is powered by an CE marked external ac-dc power supply and has only SELV ports. I believe this product must be tested to EN 60950, and that in the CE Declaration of Conformity it must declare conformity to the LVD via EN 60590. It is being suggested that this product does not need safety testing and does not need to include the reference to EN 60950 and the LVD in the CE DoC, since it is SELV circuits only. Can you provide me with references to back my point of view? Not really. If the *product* is SELV, can you find any tests in 60950 that are applicable? I suspect not, unless it contains a battery of sufficient beef that a short-circuit could create a fire hazard. In that case, even though the LVD does not apply, the manufacturer should control his product liability under the GPSD by applying the standard as far as it is relevant. The same applies if there is a high voltage generated internally in a product supplied at SELV, FELV or PELV (or any other xLV that may have been invented). HOWEVER, if the product and the external power supply are marketed together, the that is a 'system' under the EMC Directive. While there is no such concept under the Low Voltage Directive, the DOC needs to apply to both parts of the 'system', so indeed it should declare conformity to EN 60950. There is also a need to put the CE mark on the product, for the EMC Directive. The comments about the GPSD are correct, but they don't actually indicate what the manufacturer needs to do physically in order to comply with all the rules. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: CE without LVD?
Precisely my understanding as well, and that of the UK DTi if I am not very much mistaken. Regards Nick. At 11:44 -0400 27/6/03, richwo...@tycoint.com wrote: There are two possible situations. 1) An ITE device is sold without a power supply, and the input voltage of the product is rated in the SELV range (e.g., 9V DC). In this case, the product is not subject to the LVD since the input voltage falls below the minimum level specified in the LVD. However, if it is a consumer product, it is subject to the General Product Safety Directive which basically says the product must be safe. EN 60950 can be used to demonstrate safety. If it is not a consumer product, the Liability for Defective Products Directive takes over. Again, EN 60950 can be used to demonstrate safety. CE marking is not required for either of the later two Directives nor do they need to be listed on the DoC. 2) The same ITE device is sold with a power supply. In this case, the input voltage to the complete product is the main voltage and the complete product is subject to the LVD. Richard Woods Sensormatic Electronics Tyco International -Original Message- From: David Gelfand [mailto:david.gelf...@memotec.com] Sent: Friday, June 27, 2003 10:20 AM To: EMC List Subject: CE without LVD? Hello Group, A ITE product (not ours!) is powered by an CE marked external ac-dc power supply and has only SELV ports. I believe this product must be tested to EN 60950, and that in the CE Declaration of Conformity it must declare conformity to the LVD via EN 60590. It is being suggested that this product does not need safety testing and does not need to include the reference to EN 60950 and the LVD in the CE DoC, since it is SELV circuits only. Can you provide me with references to back my point of view? Thanks, David. David Gelfand Approvals/Design Engineer Memotec Inc. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: CE without LVD?
Hi David: It is being suggested that this product does not need safety testing and does not need to include the reference to EN 60950 and the LVD in the CE DoC, since it is SELV circuits only. The LVD applies to products with voltage ratings between 50 and 1000 V ac and between 75 and 1500 V dc. SELV does not exceed 30 V ac and 60 V dc. Therefore, the LVD does not apply to a product that operates from a SELV source of supply. (We may be able to say that the LVD does not apply to a Class III product.) However, it is appropriate to indicate in the DoC that the LVD does not apply to the product because the product voltage is below the lower limits of the LVD. HOWEVER... EN 60950 applies to products powered from a SELV source of supply. The electric shock requirements do not apply to such products, but the other EN 60950 requirements do apply to such products. These other requirements include the so-called energy hazard requirements, mechanical requirements, and fire requirements. So, the product does indeed require safety testing, but not with respect to the LVD. The DoC should indicate compliance with EN 60950. Pragmatically, since you must test for compliance to EN 60950 for these other requirements, it is just as easy to indicate compliance to the LVD via EN 60950 and thereby avoid any future argument whether the LVD applies or not. Most of our inkjet printer products are powered by an external SELV source of supply. We test to EN 60950 and declare compliance with the LVD. Best regards, Rich This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
