RE: certifying overall products vs. certifying individual constituant chassis
Fascinating indeed the dialogue between Gert and John W. I feel encouraged by Jim's message to add an input to this topic We do our own certification (safety and EMC) for the EU market. Our products include or consist of racks/cabinets containing CE marked equipment. The products we sell can be standard (i.e. sold to more than one customer) or custom. In both cases we certify (including EMC testing) each configuration. For only one customer and final product integrator, we were asked to provide CE DoC's for equipment installed within cabinets. However, when we purchase and integrate installations, we ask our suppliers to certify the whole system, rather than get DoC's for parts. Alexandru Guidea CAE Inc. From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Knighten, Jim L Sent: Friday, October 30, 2009 1:58 PM To: emc-p...@ieee.org Subject: RE: certifying overall products vs. certifying individual constituant chassis Guys, The responses to my question regarding certifying products at the ensemble overall product level vs. certifying at the individual chassis, or subsystem, level have been fascinating and appreciated. I appreciate the robust and knowledgeable input from expert consultants and test labs. I encourage more representatives from manufacturers to chime in to the discussion of this topic. Are you certifying your products (what John Woodgate calls not custom products, i.e., produced for numerous customers and sold and billed as a unit) as a unit, or as constituent subsystems, or chassis? By the term certifying, I include BOTH EMC and safety. Jim __ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 - phone 858-485-3788 - fax (unattended) From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Friday, October 30, 2009 3:23 AM To: emc-p...@ieee.org Subject: Re: certifying overall products vs. certifying individual constituant chassis In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D69@ZEUS.cetest.local, dated Fri, 30 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Custom or not. It's the same. CE marking applies also to single items to its full extend. The word custom is not mentioned in the guide, nor rack. From the Guide to 2004/108/EC : What you have quoted is all about combination products offered for general sale. For those, what you say is correct. But my responses are mostly about **custom** assemblies of compliant products, for which the rules are, as I am sure you know, different. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
Guys, The responses to my question regarding certifying products at the ensemble overall product level vs. certifying at the individual chassis, or subsystem, level have been fascinating and appreciated. I appreciate the robust and knowledgeable input from expert consultants and test labs. I encourage more representatives from manufacturers to chime in to the discussion of this topic. Are you certifying your products (what John Woodgate calls not custom products, i.e., produced for numerous customers and sold and billed as a unit) as a unit, or as constituent subsystems, or chassis? By the term certifying, I include BOTH EMC and safety. Jim __ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 - phone 858-485-3788 - fax (unattended) From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Friday, October 30, 2009 3:23 AM To: emc-p...@ieee.org Subject: Re: certifying overall products vs. certifying individual constituant chassis In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D69@ZEUS.cetest.local, dated Fri, 30 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Custom or not. It's the same. CE marking applies also to single items to its full extend. The word custom is not mentioned in the guide, nor rack. From the Guide to 2004/108/EC : What you have quoted is all about combination products offered for general sale. For those, what you say is correct. But my responses are mostly about **custom** assemblies of compliant products, for which the rules are, as I am sure you know, different. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D69@ZEUS.cetest.local, dated Fri, 30 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Custom or not. It's the same. CE marking applies also to single items to its full extend. The word custom is not mentioned in the guide, nor rack. From the Guide to 2004/108/EC : What you have quoted is all about combination products offered for general sale. For those, what you say is correct. But my responses are mostly about **custom** assemblies of compliant products, for which the rules are, as I am sure you know, different. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D6A@ZEUS.cetest.local, dated Fri, 30 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: I'd prefer not to refer to Guides to withdrawn directives. Not in general, nor in this specific case. The term installation has been removed. The choice now is: Apparatus or Fixed Installation. (Note the word Fixed). In that case, please refer to: 2004/108/EC: Whereas (20) Article 2, 1 (c) Article 13, 1 second paragraph Guide for the EMC Directive 2004/108/EC: Clauses 1.2, 1.3 and 4.4, especially the head clause itself and 4.4.1. Subsequent representations, mostly from the telecoms industry, have resulted in an interpretation of Article 13, 1 paragraph 2: Such apparatus is not restricted to a single instance, as long as for each instance, at the time of putting into service, the requirements of this paragraph, as explained in clause 4.4.1 of the Guide are met. (At the time of putting into service, the specific location and its EM characteristics are known.) Note that 4.4.1 itself inherently assumes, in using the words '...the batch, the serial number...' that more than one such custom assembly may be produced. But they **must** be custom assemblies of compliant products, **not** catalogue items offered for general sale. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
I'd prefer not to refer to Guides to withdrawn directives. Not in general, nor in this specific case. The term installation has been removed. The choice now is: Apparatus or Fixed Installation. (Note the word Fixed). While this text does not appear (shame!) in the Guidelines to the current Directive, there is nothing inconsistent there. Fixed installations are required to meet the Essential Requirements. There is nothing there that says that racks have to be treated differently from any other physical arrangement of the compliant products. If you do not agree with former legislation not being valid anymore, you should address your comments to the EC, not on this list. Regards, Ing. Gert Gremmen g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate Verzonden: Friday, October 30, 2009 9:35 AM Aan: emc-p...@ieee.org Onderwerp: Re: certifying overall products vs. certifying individual constituant chassis In message df8a8fdtaq6kf...@jmwa.demon.co.uk, dated Fri, 30 Oct 2009, John Woodgate j...@jmwa.demon.co.uk writes: My advice refers to **custom assemblies**, NOT single items of commerce, which must be tested for EMC and safety as a whole, as I have said many times. Maybe it would help if you looked at 6.5.2 of the Guidelines to the former EMC Directive 89/336/EEC. A custom assembly of individually compliant finished products is an 'installation'. While this text does not appear (shame!) in the Guidelines to the current Directive, there is nothing inconsistent there. Fixed installations are required to meet the Essential Requirements. There is nothing there that says that racks have to be treated differently from any other physical arrangement of the compliant products. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
Custom or not. It's the same. CE marking applies also to single items to its full extend. The word custom is not mentioned in the guide, nor rack. From the Guide to 2004/108/EC : 1.2.2 Combination of finished appliances (systems) A combination of several finished appliances which is made commercially available as a single functional unit intended for the end-user is considered to be apparatus. Such a system, within the sense of the EMC Directive, is combined, and/or designed and/or put together by the same person (the “manufacturer”) and is intended to be placed on the market for distribution as a single functional unit for end-use and to be installed and operated together to perform a specific task. All provisions of the EMC Directive, as defined for apparatus, apply to the combination as a whole. It should be noted that combining two or more CE marked finished appliances does not automatically produce a “compliant” system e.g.: a combination of CE marked Programmable Logic Controllers and motor drives may fail to meet the protection requirements. 1.2.6 Products for own use Where an apparatus is manufactured for own use, placing on the market is considered to take place at the moment of putting into service; the obligation to comply with the Directive begins with first use. From 3.2 Where a manufacturer assembles a final apparatus using components from other manufacturers, the manufacturer must retain overall control. The manufacturer is responsible for the compliance of the final apparatus. Regards, Ing. Gert Gremmen g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: John Woodgate [mailto:j...@jmwa.demon.co.uk] Verzonden: Friday, October 30, 2009 9:14 AM Aan: ce-test, qualified testing bv - Gert Gremmen CC: emc-p...@ieee.org Onderwerp: Re: certifying overall products vs. certifying individual constituant chassis In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D67@ZEUS.cetest.local, dated Fri, 30 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Please all, be aware that this is a grey area in regulations in the EC and I must all advice you to be careful when just assemble piles of equipment in a rack, and put that on the EC market. AGAIN THE SAME ERROR My advice refers to **custom assemblies**, NOT single items of commerce, which must be tested for EMC and safety as a whole, as I have said many times. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message df8a8fdtaq6kf...@jmwa.demon.co.uk, dated Fri, 30 Oct 2009, John Woodgate j...@jmwa.demon.co.uk writes: My advice refers to **custom assemblies**, NOT single items of commerce, which must be tested for EMC and safety as a whole, as I have said many times. Maybe it would help if you looked at 6.5.2 of the Guidelines to the former EMC Directive 89/336/EEC. A custom assembly of individually compliant finished products is an 'installation'. While this text does not appear (shame!) in the Guidelines to the current Directive, there is nothing inconsistent there. Fixed installations are required to meet the Essential Requirements. There is nothing there that says that racks have to be treated differently from any other physical arrangement of the compliant products. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D67@ZEUS.cetest.local, dated Fri, 30 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Please all, be aware that this is a grey area in regulations in the EC and I must all advice you to be careful when just assemble piles of equipment in a rack, and put that on the EC market. AGAIN THE SAME ERROR My advice refers to **custom assemblies**, NOT single items of commerce, which must be tested for EMC and safety as a whole, as I have said many times. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
I really think this is beyond sensible. The emission limits have been set, **taking into account that one product is very rarely use in an environment where there is no other product operating and emitting.** ... **taking into account that a single piece of equipment is very rarely used in (large) numbers together.** The leakage current issue is much more relevant than you suggest. A single fault in a rack of equipment (lost ground = defined test) effectively creates a rack (assumed metal) with a touch current equal to the sum of the touch currents of the individual equipments. John, while you are in generally well informed and very to the point, in this issue you advocate points of view, that may put members of this list and their customers in legal and technically risky situations. Please all, be aware that this is a grey area in regulations in the EC and I must all advice you to be careful when just assemble piles of equipment in a rack, and put that on the EC market. Read the essential requirements of the EMCD and LVD, carry out a risk assessment on EMC and Safety and be due diligent A good TCF may very well create sufficient protection without (much) testing. Some simple measures will almost always be necessary. And I know John, if you create a rack of equipment the risks are the same, you are right, but a natural person *has* the right to live riskfully (is that good English?), but a company does *NOT* have the right to expose it's customers to any avoidable risk. Gert Gremmen Ce-test, qualified testing Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate Verzonden: vrijdag 30 oktober 2009 8:01 Aan: emc-p...@ieee.org Onderwerp: Re: certifying overall products vs. certifying individual constituant chassis In message 380-2200910429224138...@earthlink.net, dated Thu, 29 Oct 2009, Cortland Richmond k...@earthlink.net writes: Willful ignorance -- choosing to ignore a fact one knew or should have known -- is far from being a defense when questioned on compliance matters. Would the choice not to test for combined leakage current in a medical device render the a marketer immune who know each part contributed to a level over that permitted? IMO the same logic applies to emissions. No-one is advocating wilful ignorance. I pointed out that the situations with safety and EMC are somewhat different. For safety, it may well be necessary to investigate temperatures, **whoever** puts the products into the rack. With regard to leakage current, the total value of current does not depend on whether the products are in a rack or not. IMO, even if one is not legally required to test, -- as in the sale of components direct -- one might well find himself in violation of implied warranty of serviceability should a customer find himself forbidden because of emissions to use what we sold him. I really think this is beyond sensible. The emission limits have been set, **taking into account that one product is very rarely use in an environment where there is no other product operating and emitting.** The overall level of emissions cannot possibly be affected by whether it was the user or the manufacturer that put a set of compliant products into a rack. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message 380-2200910429224138...@earthlink.net, dated Thu, 29 Oct 2009, Cortland Richmond k...@earthlink.net writes: Willful ignorance -- choosing to ignore a fact one knew or should have known -- is far from being a defense when questioned on compliance matters. Would the choice not to test for combined leakage current in a medical device render the a marketer immune who know each part contributed to a level over that permitted? IMO the same logic applies to emissions. No-one is advocating wilful ignorance. I pointed out that the situations with safety and EMC are somewhat different. For safety, it may well be necessary to investigate temperatures, **whoever** puts the products into the rack. With regard to leakage current, the total value of current does not depend on whether the products are in a rack or not. IMO, even if one is not legally required to test, -- as in the sale of components direct -- one might well find himself in violation of implied warranty of serviceability should a customer find himself forbidden because of emissions to use what we sold him. I really think this is beyond sensible. The emission limits have been set, **taking into account that one product is very rarely use in an environment where there is no other product operating and emitting.** The overall level of emissions cannot possibly be affected by whether it was the user or the manufacturer that put a set of compliant products into a rack. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
Jim et al, I have been following this with a certain fascination. Willful ignorance -- choosing to ignore a fact one knew or should have known -- is far from being a defense when questioned on compliance matters. Would the choice not to test for combined leakage current in a medical device render the a marketer immune who know each part contributed to a level over that permitted? IMO the same logic applies to emissions. IMO, even if one is not legally required to test, -- as in the sale of components direct -- one might well find himself in violation of implied warranty of serviceability should a customer find himself forbidden because of emissions to use what we sold him. WE know - or should know -- when we have something borderline or worse. Cortland Richmond KA5S - Original Message - From: Knighten, Jim L mailto:jim.knigh...@teradata.com To: emc-p...@ieee.org Cc: Rowson, Stuart mailto:stuart.row...@teradata.com Sent: 10/27/2009 5:20:14 PM Subject: certifying overall products vs. certifying individual constituant chassis I am wondering what the industry experience is regarding basing EMC or Safety product certification on individual chassis (or subsystems/components) that may comprise the product, vs. certification at the product level? In particular, I have some products that are 40U racks containing multiple chassis, each of which is compliant and has its own certification. Currently, product certification is done at the entire product level (i.e., rack) and there is a product regulatory label on the overall product. I know that some companies (names withheld) that appear to be certifying only at the chassis level, rather at the ensemble product level. For EMI, I know the physics teaches us that CE + CE does NOT equal CE (i.e. one compliant chassis combined with another compliant chassis does not assure a compliant combination of the two chassis). I have war stories to corroborate this. For Safety, there are some tests (heating test is an example) that can be are run at the product level. Country approval documentation requirements vary by country, but usually there is requirement for a DoC, CB report, etc. I get increasing pressure internally (economically driven) to declare product certification done if all the constituent chassis are compliant and certified. What is the experience you guys have? Thanks in advance, Jim __ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 – phone 858-485-3788 – fax (unattended) - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message 690230e9cf51aa4ebf639fae9216d5b166e...@mer2-exchrec1.echostar.com, dated Thu, 29 Oct 2009, Grasso, Charles charles.gra...@echostar.com writes: There IS a difference between the two scenarios that you lay out John. On the one hand you (or your company) assembles a number of products into a rack for a specific function and that function is internal. On the other hand you have a manufacturer who decides (with the exact same set of products) to place that solution on the market. If the manufacturer markets that solution (with a Model number or equivalent) then the manufacturer is responsible for the EMC/Safety of said system. How many more times do I have to explain? What you say is correct for a 'marketed' collection of products (offered as a catalogue item, invoiced as one item of commerce). I explained that a ***CUSTOM*** assembly does not need to be tested as an assembly. Please read the messages carefully. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
There IS a difference between the two scenarios that you lay out John. On the one hand you (or your company) assembles a number of products into a rack for a specific function and that function is internal. On the other hand you have a manufacturer who decides (with the exact same set of products) to place that solution on the market. If the manufacturer markets that solution (with a Model number or equivalent) then the manufacturer is responsible for the EMC/Safety of said system. Without testing - how does the manufacturer demonstrate compliance to the EMC or Safety directives? I have had to work rack mount solution issues on other companies and we simply couldn't find a way that the company was not held responsible to the directives. Is there a guideline published anywhere that we can reference? Best Regards Charles Grasso Compliance Engineer Echostar Communications (w) 303-706-5467 (c) 303-204-2974 (t) 3032042...@vtext.com (e) charles.gra...@echostar.com (e2) chasgra...@gmail.com From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John M Woodgate Sent: Thursday, October 29, 2009 4:24 AM To: EMC-PSTC Subject: Re: certifying overall products vs. certifying individual constituant chassis In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D5D@ZEUS.cetest.local, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes If you (John) as a private person will do that, there is no problem, buy a rack or cupboard from Ikea: it's the same. But if you ask a company to assemble such as system (custom made) and sells it to you (independent of the way of invoice), the company has to accept EC liability for the result, and as such needs to assess the EMC properties (maybe test) and take suitable mitigation measures. I understand your point, but I believe that the actual situation is as I have explained it. It simply doesn't make sense that I (my company) can buy a number of products and put them on a shelf, or even install them in a rack, without any EMC issue being raised, but if the manufacturer puts then into a rack for me, he has to spend having the rack tested for EMC, and indeed it may not pass, because the acceptable emissions form the items add up to exceed a limit. -- This is my travelling signature, adding no superfluous mass. John M Woodgate - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message 006401ca58b8$1b179ec0$5146dc40$@com, dated Thu, 29 Oct 2009, Dennis Ward dw...@atcb.com writes: However, if a company has this great little idea of selling the same 5 PCs and 5 cell phones devices connected all together in a 'rack', it is extremely naïve of them to think that just because one PC and one cell phone device 'meet the essential requirements' that all components in the rack operating together would be compliant as well. While they may be able to circumvent the reality of the EMC problem by saying CE+CE=CE, they forget their responsibility that what they sell is to be compliant. Please understand the difference between composite products offered by a manufacturer and custom assemblies made to the purchaser's specification. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
I believe I would have to agree with Gert. Too often some tend to look only at what is 'legal' and forget what is their responsibility. For example, if I were ignorant of EMC and in my own home put 5 identical PCs and 5 identical cell phone devices on a table or in a rack I might 'assume' that everything is OK because after all everything is CE marked. However, if a company has this great little idea of selling the same 5 PCs and 5 cell phones devices connected all together in a 'rack', it is extremely naïve of them to think that just because one PC and one cell phone device 'meet the essential requirements' that all components in the rack operating together would be compliant as well. While they may be able to circumvent the reality of the EMC problem by saying CE+CE=CE, they forget their responsibility that what they sell is to be compliant. Dennis Ward American TCB Certification Resource for the Wireless Industry www.atcb.com 703-847-4700 fax 703-847-6888 direct - 703-880-4841 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of ce-test, qualified testing bv - Gert Gremmen Sent: Thursday, October 29, 2009 1:21 AM To: John Woodgate; EMC-PSTC Subject: RE: certifying overall products vs. certifying individual constituant chassis It doesn't matter if I agree, as it's technically not true. The EMC behavior will NOT be the same and in case of 4 identical equipments, having an emission spectrum close to the limit, the result will exceed the limits. If you (John) as a private person will do that, there is no problem, buy a rack or cupboard from Ikea: it's the same. But if you ask a company to assemble such as system (custom made) and sells it to you (independent of the way of invoice), the company has to accept EC liability for the result, and as such needs to assess the EMC properties (maybe test) and take suitable mitigation measures. With reference to the Guide, in such a case, one will maybe not be pursued under criminal law, but the result may not comply with the essential requirements of the EMVCD and the system may be obliged to be taken off the market. (this will happen in case of complaints only , I hope) Well this is all very theoretically, but it is important to distinguish between dumb law and technical aspects and find a balance between the two to be due diligent. One of my relations is currently building a test rack with RF amplifiers and generators, for a total RF power of much more than 1 kW. Each of the items has a ce-mark. What do you think will be the resulting interference potential without special mitigation measures taken ? What happens to your body/head if you decide to operate 25 cell phones at the same time ? (some weird type of conference call ;)) Each of the phones is safe, but the sum is a substantial risk. Regards, Ing. Gert Gremmen g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate Verzonden: Wednesday, October 28, 2009 8:01 PM Aan: EMC-PSTC Onderwerp: Re: certifying overall products vs. certifying individual constituant chassis In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D5C@ZEUS.cetest.local, dated Wed, 28 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Not true for identical equipment. Please cite the standard or regulation that supports that opinion. If it were valid for a rack of equipment, then that configuration would have been part of the test standard. Just as all operating modes, all cable lay-out and all orientations. If multiple equipment in a rack are not tested it is not to be considered as true. I'm sorry to persist, but this is a very important point. I suppose you agree that I can buy, say, four identical pieces of equipment, with CE mark, DoC and EMC assessment, all in order, put them on a table (even stacked one above another) and operate them without fear of violating anything. If you do agree, what changes when, instead of putting them on a table, I put them into a rack? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim
RE: certifying overall products vs. certifying individual constituant chassis
I think that protection objective is the right keyword here. If you (re)sell equipment consisting of individual modules put together in one product, you (the company) has to prove that the protection objective was reached by performing a couple of measurements and tests with the product (plus quality control system etc.). If you (individual or company) put together a system/rack consisting of different compliant components and do not resell it, you are still liable when the ensemble is the source of interference. For the first case you go through a series of tests and you have to fulfill the requirements. For the second case you better follow the installation instructions/recommendations of the individual manufacturers/suppliers. In the case of interference with equipment installed according to the instructions, the manufacturer will also become involved in providing a solution (please correct me if I'm wrong). If the installation was done differently, the individual/company installing the equipment is entirely responsible. My (personal) view... Best regards, Michael Michael Nagel HW Qualification Test Engineer Embedded Computing Emerson Network Power T +49-89-9608-0 F +49-89-9608-2376 michael.na...@emerson.com www.emersonnetworkpower.com/embeddedcomputing Emerson Network Power - Embedded Computing GmbH, Lilienthalstr. 15, D-85579 Neubiberg/Landkreis München, Deutschland / Germany. Geschäftsführer Josef Wenzl, Amtsgericht München HRB 171431, VAT/USt.-ID: DE 127472241 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John M Woodgate Sent: Donnerstag, 29. Oktober 2009 11:24 To: EMC-PSTC Subject: Re: certifying overall products vs. certifying individual constituant chassis In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D5D@ZEUS.cetest.local, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes If you (John) as a private person will do that, there is no problem, buy a rack or cupboard from Ikea: it's the same. But if you ask a company to assemble such as system (custom made) and sells it to you (independent of the way of invoice), the company has to accept EC liability for the result, and as such needs to assess the EMC properties (maybe test) and take suitable mitigation measures. I understand your point, but I believe that the actual situation is as I have explained it. It simply doesn't make sense that I (my company) can buy a number of products and put them on a shelf, or even install them in a rack, without any EMC issue being raised, but if the manufacturer puts then into a rack for me, he has to spend having the rack tested for EMC, and indeed it may not pass, because the acceptable emissions form the items add up to exceed a limit. -- This is my travelling signature, adding no superfluous mass. John M Woodgate - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D5D@ZEUS.cetest.local, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes If you (John) as a private person will do that, there is no problem, buy a rack or cupboard from Ikea: it's the same. But if you ask a company to assemble such as system (custom made) and sells it to you (independent of the way of invoice), the company has to accept EC liability for the result, and as such needs to assess the EMC properties (maybe test) and take suitable mitigation measures. I understand your point, but I believe that the actual situation is as I have explained it. It simply doesn't make sense that I (my company) can buy a number of products and put them on a shelf, or even install them in a rack, without any EMC issue being raised, but if the manufacturer puts then into a rack for me, he has to spend having the rack tested for EMC, and indeed it may not pass, because the acceptable emissions form the items add up to exceed a limit. -- This is my travelling signature, adding no superfluous mass. John M Woodgate - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
Hi John Would it make any difference if the units were not identical? Is there any Euro document that I can quote that explains this. Regards Andy From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 28 October 2009 20:28 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: certifying overall products vs. certifying individual constituant chassis In message 690230e9cf51aa4ebf639fae9216d5b166e...@mer2-exchrec1.echostar.com, dated Wed, 28 Oct 2009, Grasso, Charles charles.gra...@echostar.com writes: What changes is if the four identical pieces are sold as a system and now - as a system - need to comply with the EU standards. The EU - for quite a while - has had the opinion that CE+CE does NOT = CE (necessarily). This is a very perplexing question! No, it isn't. The principles were established LONG ago: they just haven't penetrated, a situation not helped by Brussels not agreeing to spell things out in plain language. I'm going to bend the rules and re-post what I wrote before, in the hope that reading it again will make things clear. QUOTE In Europe, the position is, or ought to be, fairly clear. If these are custom racks, with products put in as the **customer** requires, and the individual products and racking are billed itemized (to prove the custom aspect), then the individual product DoCs and EMC assessment are valid for EMC, but you would be wise to look at temperature effects for safety. If the racks are batch or stream produced, not custom (although you could make, say, ten identical custom racks *for one customer, to his specification*, without that being a 'batch'), and are billed as a single item, then for EMC and safety they must be tested as a single item of commerce, even if the individual products have DoCs and assessments. ENDQUOTE The 'system' concept was in the previous EMC Directive, but is not very evident in the current one. But it is the key, and the statements below are based on the Guidelines to the former EMC Directive: If a manufacturer or assembler sells a number of individually-compliant products (identical or different) in a rack or in any other form, as a catalogue item (not custom) and for an inclusive price, that is a 'system' and must have its own DoC and safety and EMC assessments. After all, as a catalogue item, the cost of testing can be spread over a significant number of such 'systems'. If a manufacturer or an assembler puts together in a rack or other form a number of compliant products, as specified by a customer on a custom basis, and invoices them at individual prices (to demonstrate that it is a custom assembly), that is not a system and does not need its own DoC and assessments, because, at least for EMC, it is no different from the products being placed on a table or shelf. After all, the cost of testing such a custom assembly would be wholly out of proportion to any benefit gained. And the customer could, in any case, buy the products and rack or other mounting separately and put it all together himself, and then there is no question of any DoC and assessment. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com Confidentiality: This e-mail and its attachments are intended for the addressees only (or people authorised to receive them on their behalf) and may be confidential or privileged. If they have come to you in error you must take no action based on them, nor must you copy or show them to anyone; please delete them from your system and reply to this e mail highlighting the error. Security: Please note that this e-mail has been created in the knowledge that internet e-mail is not 100% secure. Anyone who communicates with us by e-mail is taken to accept this. Viruses: We have taken steps to ensure that this e-mail and attachments are virus free, but we advise that in keeping with good computing practice you should ensure that they are actually virus free. DeltaRail Group Limited registered office Hudson House, 2 Hudson Way, Pride Park, Derby, DE24 8HS. Registered in England and Wales, number 5839985. Please refer to www.deltarail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion
RE: certifying overall products vs. certifying individual constituant chassis
Addendum to my earlier post. This grouping of equipment topic is the kind of grey area that is difficult to fit into regulations. That is exactly why the EC opted for the system of essential requirements and not for the Technical Standards = Law system. In any of such strict regulations there is space for doubt and grey areas. In each of such cases one should refer to the essential requirements and use a technical file method to obtain presumption of compliance. THIS is the difference between the EC (New Approach) and the (for example) FCC approach. The FCC parts grow bigger and bigger in an everlasting attempt to cover new(er) technologies and always lags real world. New technologies in the EC are immediately covered by the Essential requirements and the associated technical standards are left to the market (CENELEC CEN ETSI) to be created. That these latter institutions do a lousy job, is a topic for another discussion. Regards, Ing. Gert Gremmen g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate Verzonden: Thursday, October 29, 2009 7:04 AM Aan: emc-p...@ieee.org Onderwerp: Re: certifying overall products vs. certifying individual constituant chassis In message hutyiahslk6kf...@jmwa.demon.co.uk, dated Wed, 28 Oct 2009, John Woodgate j...@jmwa.demon.co.uk writes: The EU - for quite a while - has had the opinion that CE+CE does NOT = CE (necessarily). This is a very perplexing question! No, it isn't. The principles were established LONG ago: they just haven't penetrated, a situation not helped by Brussels not agreeing to spell things out in plain language. My attention has been drawn to a question of interpretation of Jim's original message. He wrote: I am wondering what the industry experience is regarding basing EMC or Safety product certification on individual chassis (or subsystems/components) that may comprise the product, vs. certification at the product level? In particular, I have some products that are 40U racks containing multiple chassis, each of which is compliant and has its own certification. The expression 'chassis (or subsystems/components)' is perhaps ambiguous, but the following sentence indicates to me that these 'chassis' are finished products which are individually certified compliant for EMC and safety, and my responses use that interpretation. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
It doesn't matter if I agree, as it's technically not true. The EMC behavior will NOT be the same and in case of 4 identical equipments, having an emission spectrum close to the limit, the result will exceed the limits. If you (John) as a private person will do that, there is no problem, buy a rack or cupboard from Ikea: it's the same. But if you ask a company to assemble such as system (custom made) and sells it to you (independent of the way of invoice), the company has to accept EC liability for the result, and as such needs to assess the EMC properties (maybe test) and take suitable mitigation measures. With reference to the Guide, in such a case, one will maybe not be pursued under criminal law, but the result may not comply with the essential requirements of the EMVCD and the system may be obliged to be taken off the market. (this will happen in case of complaints only , I hope) Well this is all very theoretically, but it is important to distinguish between dumb law and technical aspects and find a balance between the two to be due diligent. One of my relations is currently building a test rack with RF amplifiers and generators, for a total RF power of much more than 1 kW. Each of the items has a ce-mark. What do you think will be the resulting interference potential without special mitigation measures taken ? What happens to your body/head if you decide to operate 25 cell phones at the same time ? (some weird type of conference call ;)) Each of the phones is safe, but the sum is a substantial risk. Regards, Ing. Gert Gremmen g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate Verzonden: Wednesday, October 28, 2009 8:01 PM Aan: EMC-PSTC Onderwerp: Re: certifying overall products vs. certifying individual constituant chassis In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D5C@ZEUS.cetest.local, dated Wed, 28 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Not true for identical equipment. Please cite the standard or regulation that supports that opinion. If it were valid for a rack of equipment, then that configuration would have been part of the test standard. Just as all operating modes, all cable lay-out and all orientations. If multiple equipment in a rack are not tested it is not to be considered as true. I'm sorry to persist, but this is a very important point. I suppose you agree that I can buy, say, four identical pieces of equipment, with CE mark, DoC and EMC assessment, all in order, put them on a table (even stacked one above another) and operate them without fear of violating anything. If you do agree, what changes when, instead of putting them on a table, I put them into a rack? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message hutyiahslk6kf...@jmwa.demon.co.uk, dated Wed, 28 Oct 2009, John Woodgate j...@jmwa.demon.co.uk writes: The EU - for quite a while - has had the opinion that CE+CE does NOT = CE (necessarily). This is a very perplexing question! No, it isn't. The principles were established LONG ago: they just haven't penetrated, a situation not helped by Brussels not agreeing to spell things out in plain language. My attention has been drawn to a question of interpretation of Jim's original message. He wrote: I am wondering what the industry experience is regarding basing EMC or Safety product certification on individual chassis (or subsystems/components) that may comprise the product, vs. certification at the product level? In particular, I have some products that are 40U racks containing multiple chassis, each of which is compliant and has its own certification. The expression 'chassis (or subsystems/components)' is perhaps ambiguous, but the following sentence indicates to me that these 'chassis' are finished products which are individually certified compliant for EMC and safety, and my responses use that interpretation. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message 690230e9cf51aa4ebf639fae9216d5b166e...@mer2-exchrec1.echostar.com, dated Wed, 28 Oct 2009, Grasso, Charles charles.gra...@echostar.com writes: What changes is if the four identical pieces are sold as a system and now - as a system - need to comply with the EU standards. The EU - for quite a while - has had the opinion that CE+CE does NOT = CE (necessarily). This is a very perplexing question! No, it isn't. The principles were established LONG ago: they just haven't penetrated, a situation not helped by Brussels not agreeing to spell things out in plain language. I'm going to bend the rules and re-post what I wrote before, in the hope that reading it again will make things clear. QUOTE In Europe, the position is, or ought to be, fairly clear. If these are custom racks, with products put in as the **customer** requires, and the individual products and racking are billed itemized (to prove the custom aspect), then the individual product DoCs and EMC assessment are valid for EMC, but you would be wise to look at temperature effects for safety. If the racks are batch or stream produced, not custom (although you could make, say, ten identical custom racks *for one customer, to his specification*, without that being a 'batch'), and are billed as a single item, then for EMC and safety they must be tested as a single item of commerce, even if the individual products have DoCs and assessments. ENDQUOTE The 'system' concept was in the previous EMC Directive, but is not very evident in the current one. But it is the key, and the statements below are based on the Guidelines to the former EMC Directive: If a manufacturer or assembler sells a number of individually-compliant products (identical or different) in a rack or in any other form, as a catalogue item (not custom) and for an inclusive price, that is a 'system' and must have its own DoC and safety and EMC assessments. After all, as a catalogue item, the cost of testing can be spread over a significant number of such 'systems'. If a manufacturer or an assembler puts together in a rack or other form a number of compliant products, as specified by a customer on a custom basis, and invoices them at individual prices (to demonstrate that it is a custom assembly), that is not a system and does not need its own DoC and assessments, because, at least for EMC, it is no different from the products being placed on a table or shelf. After all, the cost of testing such a custom assembly would be wholly out of proportion to any benefit gained. And the customer could, in any case, buy the products and rack or other mounting separately and put it all together himself, and then there is no question of any DoC and assessment. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
What changes is if the four identical pieces are sold as a system and now - as a system - need to comply with the EU standards. The EU - for quite a while - has had the opinion that CE+CE does NOT = CE (necessarily). This is a very perplexing question! Best Regards Charles Grasso Compliance Engineer Echostar Communications (w) 303-706-5467 (c) 303-204-2974 (t) 3032042...@vtext.com (e) charles.gra...@echostar.com (e2) chasgra...@gmail.com From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Wednesday, October 28, 2009 1:01 PM To: EMC-PSTC Subject: Re: certifying overall products vs. certifying individual constituant chassis In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D5C@ZEUS.cetest.local, dated Wed, 28 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Not true for identical equipment. Please cite the standard or regulation that supports that opinion. If it were valid for a rack of equipment, then that configuration would have been part of the test standard. Just as all operating modes, all cable lay-out and all orientations. If multiple equipment in a rack are not tested it is not to be considered as true. I'm sorry to persist, but this is a very important point. I suppose you agree that I can buy, say, four identical pieces of equipment, with CE mark, DoC and EMC assessment, all in order, put them on a table (even stacked one above another) and operate them without fear of violating anything. If you do agree, what changes when, instead of putting them on a table, I put them into a rack? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D5C@ZEUS.cetest.local, dated Wed, 28 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Not true for identical equipment. Please cite the standard or regulation that supports that opinion. If it were valid for a rack of equipment, then that configuration would have been part of the test standard. Just as all operating modes, all cable lay-out and all orientations. If multiple equipment in a rack are not tested it is not to be considered as true. I'm sorry to persist, but this is a very important point. I suppose you agree that I can buy, say, four identical pieces of equipment, with CE mark, DoC and EMC assessment, all in order, put them on a table (even stacked one above another) and operate them without fear of violating anything. If you do agree, what changes when, instead of putting them on a table, I put them into a rack? -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
Not true for identical equipment. Please cite the standard or regulation that supports that opinion. If it were valid for a rack of equipment, then that configuration would have been part of the test standard. Just as all operating modes, all cable lay-out and all orientations. If multiple equipment in a rack are not tested it is not to be considered as true. Gert Van: John Woodgate [mailto:j...@jmwa.demon.co.uk] Verzonden: woensdag 28 oktober 2009 8:31 Aan: ce-test, qualified testing bv - Gert Gremmen CC: emc-p...@ieee.org Onderwerp: Re: certifying overall products vs. certifying individual constituant chassis In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D58@ZEUS.cetest.local, dated Wed, 28 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Not true for identical equipment. Please cite the standard or regulation that supports that opinion. Any single product was tested as a single equipment and interaction in the close field between single units is not part of the tests. The current EMC regulations do *NOT* consider combining multiple pieces at all. Radiation may (will) add up even if the signals are not in phase. Same for harmonics and conducted emissions. Agreed. EMC regulation was not made with the idea that a consumer may combine multiple identical boxes in a rack. Please cite the standard or regulation that supports that opinion. When buying a rack of equipment, the client may expect similar protection as when buying a single piece of equipment, and the Manufacturer is expected to have evaluated the consequences. If it's bought as a single item of commerce, yes. As a custom assembly, the individual DoCs and assessments are valid for EMC by additional safety tests may be required, usually for temperature effects only. This does however, not address the combination of multiple different Items in a rack. Technically more or less like to buying a IKEA rack and setting up a audio/video combination. In practice most equipment integrators make a mixture of different and identical types of products, and in that case CE+CE CE at all. Please cite the standard or regulation that supports that opinion. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message FCA549BE3ECF9D4CB8CB8576837EA4890A6D58@ZEUS.cetest.local, dated Wed, 28 Oct 2009, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: Not true for identical equipment. Please cite the standard or regulation that supports that opinion. Any single product was tested as a single equipment and interaction in the close field between single units is not part of the tests. The current EMC regulations do *NOT* consider combining multiple pieces at all. Radiation may (will) add up even if the signals are not in phase. Same for harmonics and conducted emissions. Agreed. EMC regulation was not made with the idea that a consumer may combine multiple identical boxes in a rack. Please cite the standard or regulation that supports that opinion. When buying a rack of equipment, the client may expect similar protection as when buying a single piece of equipment, and the Manufacturer is expected to have evaluated the consequences. If it's bought as a single item of commerce, yes. As a custom assembly, the individual DoCs and assessments are valid for EMC by additional safety tests may be required, usually for temperature effects only. This does however, not address the combination of multiple different Items in a rack. Technically more or less like to buying a IKEA rack and setting up a audio/video combination. In practice most equipment integrators make a mixture of different and identical types of products, and in that case CE+CE CE at all. Please cite the standard or regulation that supports that opinion. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: certifying overall products vs. certifying individual constituant chassis
If I have four products resting on a shelf, and then I decide to put them in a rack instead, there is no change in the EMC situation, so no additional testing is required. Not true for identical equipment. Any single product was tested as a single equipment and interaction in the close field between single units is not part of the tests. The current EMC regulations do *NOT* consider combining multiple pieces at all. Radiation may (will) add up even if the signals are not in phase. Same for harmonics and conducted emissions. EMC regulation was not made with the idea that a consumer may combine multiple identical boxes in a rack. When buying a rack of equipment, the client may expect similar protection as when buying a single piece of equipment, and the Manufacturer is expected to have evaluated the consequences. This does however, not address the combination of multiple different Items in a rack. Technically more or less like to buying a IKEA rack and setting up a audio/video combination. In practice most equipment integrators make a mixture of different and identical types of products, and in that case CE+CE CE at all. Gert Gremmen Ce-test, qualified testing bv Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate Verzonden: woensdag 28 oktober 2009 7:15 Aan: emc-p...@ieee.org Onderwerp: Re: certifying overall products vs. certifying individual constituant chassis In message 463247.69084...@web112009.mail.gq1.yahoo.com, dated Tue, 27 Oct 2009, peter merguerian pmerguerian2...@yahoo.com writes: For EMI, I know the physics tto ebeaches us that CE + CE does NOT equal CE (i.e. one compliant chassis combined with another compliant chassis does not assure a compliant combination of the two chassis). I have war stories to corroborate this. Peter: You are 100% correct and I know a few people in this forum whom I worked with in the past who can attest to this. True, but you have to apply that with insight. If I have four products resting on a shelf, and then I decide to put them in a rack instead, there is no change in the EMC situation, so no additional testing is required. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message 463247.69084...@web112009.mail.gq1.yahoo.com, dated Tue, 27 Oct 2009, peter merguerian pmerguerian2...@yahoo.com writes: For EMI, I know the physics tto ebeaches us that CE + CE does NOT equal CE (i.e. one compliant chassis combined with another compliant chassis does not assure a compliant combination of the two chassis). I have war stories to corroborate this. Peter: You are 100% correct and I know a few people in this forum whom I worked with in the past who can attest to this. True, but you have to apply that with insight. If I have four products resting on a shelf, and then I decide to put them in a rack instead, there is no change in the EMC situation, so no additional testing is required. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
Regarding the product safety issue, I have found there are five concerns: 1. Enclosure - rarely the rack has been relied on for enclosure of (recognized) products. 2. Stability - predictable with measurement data but its easier to directly test 3. Temperature - a difficult problem to predict. Components may not have been certified for elevated internal ambients. Testing of a maximum configuration can often be done. 4. Input current - when using power controls or strips, can generally be assumed to be the sum of the components. 5. Leakage current - also can generally be assumed to be the sum of the components. Certification of the system is not generally needed although we have had to do field certifications of systems ending up in Los Angeles. You should have data that shows, for example by testing worst case configurations or documenting the rationale for deciding, that what you ship is safe. Bob Johnson ITE Safety Knighten, Jim L wrote: I am wondering what the industry experience is regarding basing EMC or Safety product certification on individual chassis (or subsystems/components) that may comprise the product, vs. certification at the product level? In particular, I have some products that are 40U racks containing multiple chassis, each of which is compliant and has its own certification. Currently, product certification is done at the entire product level (i.e., rack) and there is a product regulatory label on the overall product. I know that some companies (names withheld) that appear to be certifying only at the chassis level, rather at the ensemble product level. For EMI, I know the physics teaches us that CE + CE does NOT equal CE (i.e. one compliant chassis combined with another compliant chassis does not assure a compliant combination of the two chassis). I have war stories to corroborate this. For Safety, there are some tests (heating test is an example) that can be are run at the product level. Country approval documentation requirements vary by country, but usually there is requirement for a DoC, CB report, etc. I get increasing pressure internally (economically driven) to declare product certification done if all the constituent chassis are compliant and certified. What is the experience you guys have? Thanks in advance, Jim __ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 – phone 858-485-3788 – fax (unattended) - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
Hello Jim, See below --- On Tue, 10/27/09, Knighten, Jim L jim.knigh...@teradata.com wrote: From: Knighten, Jim L jim.knigh...@teradata.com Subject: certifying overall products vs. certifying individual constituant chassis To: emc-p...@ieee.org Cc: Rowson, Stuart stuart.row...@teradata.com Date: Tuesday, October 27, 2009, 2:19 PM I am wondering what the industry experience is regarding basing EMC or Safety product certification on individual chassis (or subsystems/components) that may comprise the product, vs. certification at the product level? Peter: Most manufacturers of rackable systems do tests and certification at the system level. In particular, I have some products that are 40U racks containing multiple chassis, each of which is compliant and has its own certification. Currently, product certification is done at the entire product level (i.e., rack) and there is a product regulatory label on the overall product. I know that some companies (names withheld) that appear to be certifying only at the chassis level, rather at the ensemble product level. Peter: I also have come across some manufacturers that have not certified at the system level. Some of these manufacturers have been negligent about safety/emc regulations - others have done their due diligence and have additionally tested the racks at the system level (even though they have not submitted the rack system for certification by a third party). The latter may have tested system level tests for emc (quiet an experience as you mention below), but also have conducted internal safety tests such as Input Test (to ensure the overall system ratings are not exceeded), monitored internal ambient temperature to ensure the internal chassis manufacturer's specified ambient levels are not exceeded, Leakage Current Test to ensure the cord connected earthed limit of 3.5 mA is not exceeded (exceptions if product is marked with a High Leakage Current Marking and provided with a specialized plug) and for rack systems that are not fixed to the floor, a Stability Test is conducted. From the safety standpoint, in the US and other parts of the world, a local inspector or certification body may not have problems with a rack system that has internal components that are Listed/Certified having their own power cords or interconnected by means of a PDU. As such some manufacturers opt for certification at the subassemly level. As the long as the subassemly is Listed/Certified, no further action is required. Such manufacturers are putting themselves at risk if they have not taken precautionary measues to ensure the system is compliant with all of the applicable safety requirements. Same goes with emc. For EMI, I know the physics tto ebeaches us that CE + CE does NOT equal CE (i.e. one compliant chassis combined with another compliant chassis does not assure a compliant combination of the two chassis). I have war stories to corroborate this. Peter: You are 100% correct and I know a few people in this forum whom I worked with in the past who can attest to this. For Safety, there are some tests (heating test is an example) that can be are run at the product level. Peter: That is correct, but the manufacturer's specified maximimum ambient levels must be followed. In other words, if you purchase an ethernet switch which has been tested to a 25 deg C ambient (you can review the manufacturer's safety test reports), you cannot use it in your rack system which may be rated for a 50 deg C ambient. Country approval documentation requirements vary by country, but usually there is requirement for a DoC, CB report, etc. Peter: This is an area where you need to spend time and define the countries where certification or a type approval is a must, the exceptions and what documentation (CB, NRTL Listing, FCC, EU EMC) will be required to meet the country's mandatory certification requirements for safety and/or emc. A system CB and/or emc report as applicable will go a long way in complying with the country's mandatory requirements. I get increasing pressure internally (economically driven) to declare product certification done if all the constituent chassis are compliant and certified. Peter: This could be a great solution for a country that has no specific regulations for safety and/or emc. For countries suc as the US where product liability laws are strict, proof of compliance at the system level is the way to go What is the experience you guys have? Thanks in advance, Jim
RE: certifying overall products vs. certifying individual constituant chassis
I have not done systems that are as physically big or as yours, but this is how we have danced at the 'component vs systems' party. If you have data that indicates each combination of boxen has unique performance, then you must certify at system, so you ignore the following. 1. Provide, to marketing, a summary of regulatory requirements for system-level vs box-level. 2. Request sales dept to perform marketing study to determine if the end-user will bear the cost/effort of system-level certification. Emphasize the resultant box-level conditions of acceptability and user document requirements. And perhaps the sales dweebs may actually want to provide some boxen as individual products. 3. Present regulatory requirements + marketing study to engineering and sales managers. 4. Live with their decision. Finally, if this is for aviation, military, or police/fire - this approach is not good. The tests must be done at the system level or they have no meaning. FWIW, I sitting in front of a halt chamber REPEATING about 35 hours of tests because sales said enough - we have tests and reports for all components too soon... Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Knighten, Jim L Sent: Tuesday, October 27, 2009 1:19 PM To: emc-p...@ieee.org Cc: Rowson, Stuart Subject: certifying overall products vs. certifying individual constituant chassis I am wondering what the industry experience is regarding basing EMC or Safety product certification on individual chassis (or subsystems/components) that may comprise the product, vs. certification at the product level? In particular, I have some products that are 40U racks containing multiple chassis, each of which is compliant and has its own certification. Currently, product certification is done at the entire product level (i.e., rack) and there is a product regulatory label on the overall product. I know that some companies (names withheld) that appear to be certifying only at the chassis level, rather at the ensemble product level. For EMI, I know the physics teaches us that CE + CE does NOT equal CE (i.e. one compliant chassis combined with another compliant chassis does not assure a compliant combination of the two chassis). I have war stories to corroborate this. For Safety, there are some tests (heating test is an example) that can be are run at the product level. Country approval documentation requirements vary by country, but usually there is requirement for a DoC, CB report, etc. I get increasing pressure internally (economically driven) to declare product certification done if all the constituent chassis are compliant and certified. What is the experience you guys have? Thanks in advance, Jim __ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 - phone 858-485-3788 - fax (unattended) - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: certifying overall products vs. certifying individual constituant chassis
In message e4c83436df3d724a8d70992643ee9d62060f7...@susday7659.td.teradata.com, dated Tue, 27 Oct 2009, Knighten, Jim L jim.knigh...@teradata.com writes: I get increasing pressure internally (economically driven) to declare product certification done if all the constituent chassis are compliant and certified. In Europe, the position is, or ought to be, fairly clear. If these are custom racks, with products put in as the **customer** requires, and the individual products and racking are billed itemized (to prove the custom aspect), then the individual product DoCs and EMC assessment are valid for EMC, but you would be wise to look at temperature effects for safety. If the racks are batch or stream produced, not custom (although you could make, say, ten identical custom racks *for one customer, to his specification*, without that being a 'batch'), and are billed as a single item, then for EMC and safety they must be tested as a single item of commerce, even if the individual products have DoCs and assessments. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
