Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[Dave Heald]

Thanks, all, for the good discussion on this.  I considered everything here
& think I've got a good path forward.

Best Regards,
-David

On Tue, Jul 21, 2015 at 3:24 AM, John Woodgate  wrote:

> In message <54573abb74734ea78f208b754d51b...@thhste15d1be4.hs20.net>,
> dated Tue, 21 Jul 2015, Charlie Blackham 
> writes:
>
>  That standard it is referencing a standard that is no longer "state of
>> the art" with regard to several sets of limits or frequency ranges. The
>> chair of the ETSI committee is aware of that problem, and proposed I
>> described. The discussion also considered that the purpose of standards is
>> to support Declaration to a Directive, and not certification to the
>> standard itself.
>>
>
> In such a case, where it's the OJ list that is out-of-date, manufacturers
> should indeed consider the latest edition of the referenced standard in the
> EMC assessment, but not put it on the DoC.
>
>>
>> Manufacturers also, of course, have to deal with reality of market
>> surveillance which seems to operate a slightly simplistic "current
>> Harmonised Standard = good / non-current HS = bad" approach.
>>
>
> It's not 'simplistic', it's a legal matter. Your equations do represent
> the *legal* position.
> --
> OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
> When I turn my back on the sun, it's to look for a rainbow
> John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
>
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
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> emc-p...@ieee.org>
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>
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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[John Woodgate]

In message <54573abb74734ea78f208b754d51b...@thhste15d1be4.hs20.net>, 
dated Tue, 21 Jul 2015, Charlie Blackham  
writes:


That standard it is referencing a standard that is no longer "state of 
the art" with regard to several sets of limits or frequency ranges. The 
chair of the ETSI committee is aware of that problem, and proposed I 
described. The discussion also considered that the purpose of standards 
is to support Declaration to a Directive, and not certification to the 
standard itself.


In such a case, where it's the OJ list that is out-of-date, 
manufacturers should indeed consider the latest edition of the 
referenced standard in the EMC assessment, but not put it on the DoC.


Manufacturers also, of course, have to deal with reality of market 
surveillance which seems to operate a slightly simplistic "current 
Harmonised Standard = good / non-current HS = bad" approach.


It's not 'simplistic', it's a legal matter. Your equations do represent 
the *legal* position.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[John Woodgate]

In message , 
dated Tue, 21 Jul 2015, "ce-test, qualified testing bv - Gert Gremmen" 
 writes:


The basic problem is that EN 55022 is a mixed  standard, describing 
test methods and limits in the same text, where most immunity basic 
standards (such as the EN 61000-4-ys series) have been conceived for 
that role only and do not prescribe limits (suggest some only).


EN 55022 is a Product-family emission standard, EN 55024 is the 
companion immunity standard. EN 55022 is indeed referred to in other 
standards as if it were a Basic standard.


A product should therefore never comply to a Basic standard 
(impossible); an error widely spread.


Agreed.

Basic standards are never referenced in the OJ with the EN 55022 as 
exception.


See above; I don't think it's an exception, because it's a 
Product-family standard. The fact that it's also used in a Basic 
standard rôle is irrelevant.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[Charlie Blackham]

That standard it is referencing a standard that is no longer "state of the art" 
with regard to several sets of limits or frequency ranges. The chair of the 
ETSI committee is aware of that problem, and proposed I described. The 
discussion also considered that the purpose of standards is to support 
Declaration to a Directive, and not certification to the standard itself.

Manufacturers also, of course, have to deal with reality of market surveillance 
which seems to operate a slightly simplistic "current Harmonised Standard = 
good / non-current HS = bad" approach.

Regards
Charlie


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 20 July 2015 22:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

In message <85d45e15f71741059f90847883213...@thhste15d1be4.hs20.net>,
dated Mon, 20 Jul 2015, Charlie Blackham 
writes:

>The discussion concluded that whilst final responsibility would always 
>rest with the manufacturer (and Notified Body if used), that using the 
>latest state of the art standard would be perfectly acceptable or 
>perhaps even the better decision.
>
> 
The committee that wrote the referencing standard decided to use dated 
references, and that was voted on and accepted. So how can it be a 'better 
decision' to ignore that?

While the advantages of dated and undated references are pretty evenly 
balanced, the main point in favour of dating is that the user ***is in no doubt 
which edition of the reference standard to apply***. Teaching people to 
disregard that seems extremely perverse.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[ce-test, qualified testing bv - Gert Gremmen]

Some additional info on this topic:
The referenced EN 55022:2006 has not the same role as it would have for
IT equipment.
The role is that of a basic standard, describing test methods , and
exercise methods only.
The limits are in the EN 301489 standard, used as harmonised standard
for your product.
So the fact that EN 55022:2006 is expired in the OJ is not relevant; it
would have been a problem if
the standard was withdrawn, and I have seen that too.
The basic problem is that EN 55022 is a mixed  standard, describing test
methods and limits in the same text,
where most immunity basic standards (such as the EN 61000-4-ys series)
have been conceived for that role
only and do not prescribe limits (suggest some only).
A product should therefore never comply to a Basic standard
(impossible); an error widely spread.
Basic standards are never referenced in the OJ with the EN 55022 as
exception.


Gert Gremmen
Ce-test, qualified testing bv


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Tuesday 21 July 2015 03:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards
in EN 301 489-1 v1.9.2

In message
, dated Mon, 20 Jul 2015, "Nyffenegger, Dave" 
 writes:

>At the risk of going off topic,  I don't see anything identified at 
>http://eur-lex.europa.eu/homepage.html  for harmonized standards for 
>the new 2014/30/EU EMC and 2014/35/EU LVD directives that go into force

>April 2016.  Time to start getting prepared.  Am I missing something or

>is it just too soon for them to be published?

You are not missing anything. The reason you haven't seen anything yet
is complicated and largely irrelevant. The lists will not change
significantly due to the changes of Directive alone.
>
>The same line of thinking could apply as to whether or not to start 
>using newer standards sooner than later.  A benefit would be not having

>to go through the cost of additional testing to a newer standard only 
>months later.

You almost never *have* to re-test to a new standard only months later;
there is a transition period which is normally 36 months. You can
*choose* to apply a new edition of a standard as soon as it is notified
in the Official Journal, but you don't have to.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When
I turn my back on the sun, it's to look for a rainbow John Woodgate, J M
Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[Nyffenegger, Dave]

Thanks for reminding me.  I remember now, the published OJ harmonized standards 
lists will have the in force date listed for each standard.
Thanks
-Dave

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Monday, July 20, 2015 9:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

In message
, dated Mon, 20 Jul 2015, "Nyffenegger, Dave" 
 writes:

>At the risk of going off topic,  I don't see anything identified at 
>http://eur-lex.europa.eu/homepage.html  for harmonized standards for 
>the new 2014/30/EU EMC and 2014/35/EU LVD directives that go into force 
>April 2016.  Time to start getting prepared.  Am I missing something or 
>is it just too soon for them to be published?

You are not missing anything. The reason you haven't seen anything yet is 
complicated and largely irrelevant. The lists will not change significantly due 
to the changes of Directive alone.
>
>The same line of thinking could apply as to whether or not to start 
>using newer standards sooner than later.  A benefit would be not having 
>to go through the cost of additional testing to a newer standard only 
>months later.

You almost never *have* to re-test to a new standard only months later; there 
is a transition period which is normally 36 months. You can
*choose* to apply a new edition of a standard as soon as it is notified in the 
Official Journal, but you don't have to.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[John Woodgate]

In message 
utlook.com>, dated Mon, 20 Jul 2015, "Nyffenegger, Dave" 
 writes:


At the risk of going off topic,  I don't see anything identified at 
http://eur-lex.europa.eu/homepage.html  for harmonized standards for 
the new 2014/30/EU EMC and 2014/35/EU LVD directives that go into force 
April 2016.  Time to start getting prepared.  Am I missing something or 
is it just too soon for them to be published?


You are not missing anything. The reason you haven't seen anything yet 
is complicated and largely irrelevant. The lists will not change 
significantly due to the changes of Directive alone.


The same line of thinking could apply as to whether or not to start 
using newer standards sooner than later.  A benefit would be not having 
to go through the cost of additional testing to a newer standard only 
months later.


You almost never *have* to re-test to a new standard only months later; 
there is a transition period which is normally 36 months. You can 
*choose* to apply a new edition of a standard as soon as it is notified 
in the Official Journal, but you don't have to.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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 

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Jim Bacher:  
David Heald: 

Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[Nyffenegger, Dave]

At the risk of going off topic,  I don't see anything identified at 
http://eur-lex.europa.eu/homepage.html  for harmonized standards for the new 
2014/30/EU EMC and 2014/35/EU LVD directives that go into force April 2016.  
Time to start getting prepared.  Am I missing something or is it just too soon 
for them to be published?  

The same line of thinking could apply as to whether or not to start using newer 
standards sooner than later.  A benefit would be not having to go through the 
cost of additional testing to a newer standard only months later.

-Dave

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Monday, July 20, 2015 5:15 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

In message <85d45e15f71741059f90847883213...@thhste15d1be4.hs20.net>,
dated Mon, 20 Jul 2015, Charlie Blackham 
writes:

>The discussion concluded that whilst final responsibility would always 
>rest with the manufacturer (and Notified Body if used), that using the 
>latest state of the art standard would be perfectly acceptable or 
>perhaps even the better decision.
>
> 
The committee that wrote the referencing standard decided to use dated 
references, and that was voted on and accepted. So how can it be a 'better 
decision' to ignore that?

While the advantages of dated and undated references are pretty evenly 
balanced, the main point in favour of dating is that the user ***is in no doubt 
which edition of the reference standard to apply***. Teaching people to 
disregard that seems extremely perverse.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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 


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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[John Woodgate]

In message <85d45e15f71741059f90847883213...@thhste15d1be4.hs20.net>, 
dated Mon, 20 Jul 2015, Charlie Blackham  
writes:


The discussion concluded that whilst final responsibility would always 
rest with the manufacturer (and Notified Body if used), that using the 
latest state of the art standard would be perfectly acceptable or 
perhaps even the better decision.


 
The committee that wrote the referencing standard decided to use dated 
references, and that was voted on and accepted. So how can it be a 
'better decision' to ignore that?


While the advantages of dated and undated references are pretty evenly 
balanced, the main point in favour of dating is that the user ***is in 
no doubt which edition of the reference standard to apply***. Teaching 
people to disregard that seems extremely perverse.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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 

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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David Heald: 

Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[Charlie Blackham]

David

I’ll offer a slightly different angle.

Newer standards, whilst not referenced in the product standard, do represent 
“state of the art”.

There was a discussion recently in the R&TTE compliance association related to 
the fact that several product type EN 301 489-X standards referenced EN 301 
489-1 version 1.8.1 or even 1.4.1.
The discussion concluded that whilst final responsibility would always rest 
with the manufacturer (and Notified Body if used), that using the latest state 
of the art standard would be perfectly acceptable or perhaps even the better 
decision.

I’m not suggesting that the lab did the correct thing, but the choice of basic 
EMC standard is only a part of demonstrating EMC compliance and a smaller part 
of the whole CE marking compliance jigsaw and if that was the only area that 
wasn’t perfect, then you would be in a pretty good place ☺

Regards
Charlie


From: Dave Heald [mailto:emcp...@gmail.com]
Sent: 20 July 2015 19:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 
301 489-1 v1.9.2

Hi John,
  I agree, and this has been my stance with the lab and with our ODM who 
contracted the lab & had the testing done.

Also, the problem doesn't stop with the 55022 reference - for *EVERY* dated (& 
thus "specific") basic EMC standard that has a newer version, the newer 
standard was used.  For a few, the test method has changed, and this is the 
sticking point - the lab wants us to pay for any delta testing to the old 
standards that they technically should have used in the first place.

If it is generally acceptable or "good enough" to use the newer standards, I 
don't want to stand in the way of product release while we get the testing 
re-done (we know what happens to employees that take stands on technicalities 
that aren't important in the grand scheme of things & it's not good)
However, I also don't want to give in without some input from other experts on 
how important this is to compliance assessment.

Thanks,
-David

On Mon, Jul 20, 2015 at 12:18 PM, John Woodgate 
mailto:j...@jmwa.demon.co.uk>> wrote:
In message 
mailto:ca%2bnn315eg5krv5rgtjbmfqbhkancteqsbuwjkhobpopurog...@mail.gmail.com>>,
 dated Mon, 20 Jul 2015, Dave Heald 
mailto:emcp...@gmail.com>> writes:
Even though the EN 301 489-1 standard's Normative References list specific 
dates (and according to the standard, *only* those versions of the standard 
should be used), is it OK to use the most recent versions of the Reference 
standards to claim compliance?

If a reference is dated, that edition must be used. If it is not dated, the 
latest edition must be used.
--
OOO - Own Opinions Only. With best wishes. See 
www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk>
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK


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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[John Woodgate]

In message 
, 
dated Mon, 20 Jul 2015, Dave Heald  writes:


If it is generally acceptable or "good enough" to use the newer 
standards, I don't want to stand in the way of product release while we 
get the testing re-done (we know what happens to employees that take 
stands on technicalities that aren't important in the grand scheme of 
things & it's not good)
However, I also don't want to give in without some input from other 
experts on how important this is to compliance assessment.


It's impossible to generalize; there are three cases:

1. The new edition is *exactly* the same as the earlier one for every 
cross-reference in the referencing standard;


2. The new edition is *exactly* the same for some cross-references, but 
not others;


3. The new edition is a complete re-write, so that the cross-references 
in the referencing standard are meaningless.


Case 1. is the only one that doesn't spell trouble. *exactly* means 
word-for-word and includes any Notes or examples.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[Dave Heald]

Hi John,
  I agree, and this has been my stance with the lab and with our ODM who
contracted the lab & had the testing done.

Also, the problem doesn't stop with the 55022 reference - for *EVERY* dated
(& thus "specific") basic EMC standard that has a newer version, the newer
standard was used.  For a few, the test method has changed, and this is the
sticking point - the lab wants us to pay for any delta testing to the old
standards that they technically should have used in the first place.

If it is generally acceptable or "good enough" to use the newer standards,
I don't want to stand in the way of product release while we get the
testing re-done (we know what happens to employees that take stands on
technicalities that aren't important in the grand scheme of things & it's
not good)
However, I also don't want to give in without some input from other experts
on how important this is to compliance assessment.

Thanks,
-David

On Mon, Jul 20, 2015 at 12:18 PM, John Woodgate 
wrote:

> In message <
> ca+nn315eg5krv5rgtjbmfqbhkancteqsbuwjkhobpopurog...@mail.gmail.com>,
> dated Mon, 20 Jul 2015, Dave Heald  writes:
>
>  Even though the EN 301 489-1 standard's Normative References list
>> specific dates (and according to the standard, *only* those versions of the
>> standard should be used), is it OK to use the most recent versions of the
>> Reference standards to claim compliance?
>>
>
> If a reference is dated, that edition must be used. If it is not dated,
> the latest edition must be used.
> --
> OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
> When I turn my back on the sun, it's to look for a rainbow
> John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
>
>
> -
> 
> 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.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website:  http://www.ieee-pses.org/
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>

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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[John Woodgate]

In message 
, 
dated Mon, 20 Jul 2015, Dave Heald  writes:


Even though the EN 301 489-1 standard's Normative References list 
specific dates (and according to the standard, *only* those versions of 
the standard should be used), is it OK to use the most recent versions 
of the Reference standards to claim compliance?  


If a reference is dated, that edition must be used. If it is not dated, 
the latest edition must be used.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 489-1 v1.9.2

[Charlie Blackham]

David

Strictly speaking there’s no conflict as the only relevant standard is EN 301 
489-1. The fact that EN 55022 is also listed in the OJ is coincidental  - the 
applicable standard, EN 301 489-1, is referencing a product standard for 
emissions rather than, say, a basic standard as is the case for immunity.

That said, I don’t think you would have any issue with using the 2010 version 
of EN 55022, but it should be noted somewhere in the report that it is a 
deviation.

Regards
Charlie

From: Dave Heald [mailto:emcp...@gmail.com]
Sent: 20 July 2015 18:30
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE OJ listing vs conflicting Reference Standards in EN 301 
489-1 v1.9.2

I have a technical question on the OJ vs References in standards.

Here is the conflict:  EN 301 489 -1 V1.9.2 is the "current standard" in the 
R&TTE OJ.

However, 301 489-1 V 1.9.2, it lists several "specific" standards in it's 
Normative References chapter... and one of these standards (EN 55022: 2006 + A1 
(2007) expired in the R&TTE OJ in 2013.

Even though the EN 301 489-1 standard's Normative References list specific 
dates (and according to the standard, *only* those versions of the standard 
should be used), is it OK to use the most recent versions of the Reference 
standards to claim compliance?


Any advice on this?


Thanks & Best Regards,
-David Heald
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Re: [PSES] R&TTE Certification Conformity Assessment

[Charlie Blackham]

Amund

Have a look at the R&TTE Compliance Association guidance on this topic 
http://www.rtteca.com/TGN06Rev1.pdf:

.In this sense, there is no "duration of validity" for a notified body 
opinion. It remains valid for so long as the circumstances relevant to its 
issue remain unchanged. If there  is a change, then it is the responsibility of 
the manufacturer to determine the need for  a new or updated opinion

>The reason for the question is that a LVD amendment will be mandatory in the 
>nearest future
It's not "mandatory" - there might be a passing of the "Date of cessation of 
presumption of conformity of superseded standard" (DOCOPOCOSS) - but that it 
all.

Personally I would be more concerned with the Radio Spectrum Harmonised 
Standard being superseded - again that might not be an issue as NBs are not 
required to adhere to Harmonised Standards - but I would make sure that it was 
an "intentional" situation and not one that had come about through a "fire and 
forget" approach to R&TTE Compliance on behalf of the manufacturer.

Regards
Charlie


From: Amund Westin [mailto:am...@westin-emission.no]
Sent: 17 September 2012 17:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE Certification Conformity Assessment


Shall a R&TTE Certificate from a Notified Body, always include a due date?



The reason for the question is that a LVD amendment will be mandatory in the 
nearest future and the manufacturer has not included the amendment in the DoC. 
The RTTE notified body will therefore have a limitation on the certificate with 
due date equal to the amendment "Date of cessation of presumption of conformity 
of superseded standard", in order to ensure that the manufacturer don't use the 
certificate after the day the amendment becomes mandatory.







Best regards

Amund

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Re: [PSES] R&TTE compliance test reports

[Thomas Cokenias]

Hi Scott

What Michael said, yes.

best regards


Tom

On Feb 29, 2012, at 4:26 AM, Michael Derby wrote:

> Hello,
>  
> Not quite Scott, I think what Thomas and Charlie were (correctly) saying, 
> was……
>  
> With harmonized and published standard, we do not need to use accredited 
> laboratory for the test.  
> …..in fact, regardless of whether you use a harmonised standard or not, the 
> lab does not need to be accredited.
>  
> If a laboratory is not accredited, how does a client know if the laboratory 
> is capable of doing the required tests.
> ….that’s a very good question and it explains why so many accredited labs 
> (with their extra overheads) are still in business.   You somehow need to 
> trust your lab.   There’s no certification for the R&TTE or EMC Directives, 
> so all the responsibility is on the person signing the DoC.   Good idea to 
> find a good lab!   That’s why people use an accredited lab or one that they 
> really trust.
>  
> The capability includes equipment and its calibration, knowledge of standard 
> interpretation and skill set of actual testing.
> …Yes.   You could look at the capability of the lab, how they calibrate their 
> equipment, chat to them about the standards and the staff, visit their lab, 
> etc.
>  
>  
> Michael
>  
> Michael Derby
> Regulatory Engineer
> ACB Europe
>  
> From: Scott Xe [mailto:scott...@gmail.com] 
> Sent: 29 February 2012 12:02
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] R&TTE compliance test reports
>  
> Hi Thomas,
> 
> Thanks for your advice.  With harmonized and published standard, we do not 
> need to use accredited laboratory for the test.  If a laboratory is not 
> accredited, how does a client know if the laboratory is capable of doing the 
> required tests.  The capability includes equipment and its calibration, 
> knowledge of standard interpretation and skill set of actual testing.
> 
> Regards,
> 
> Scott
> 
> 
> On 29/2/12 6:45 AM, "Thomas Cokenias"  wrote:
> 
> Hi Scott,
> 
> Not sure if this answers your question,   but you MUST use a Notified Body if 
> you test to a standard that has not been harmonized as evidenced by being 
> published in the Official Journal of the EU.
> 
> If you do  test to a standard that is indeed harmonized and published in the 
> OJ, then you are not required to get a NB expert opinion, and as others have 
> posted, you do not need to use an accredited test lab for your tests either, 
> as long as you use test methods called out by the standards and your 
> equipment and procedures can meet the measurement  uncertainty limits 
> published therein.  This means you can do tests at your location if you 
> already have the equipment.
> 
> best regards
> 
> Tom Cokenias
> T.N. Cokenias Consulting
> P.O. Box 1086
> El Granada CA 94018
> 
> 
> On Feb 28, 2012, at 8:07 AM, Scott Xe wrote:
> 
> R&TTE compliance test reports
> I notice that some compliance reports of R&TTE are reviewed by a notified 
> body while some are issued by an accredited laboratory only.  Can someone 
> advise if they have different purposes or requirements.
> 
> Thanks and regards,
> 
> Scott
> -
> 
> 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 
> 
> All emc-pstc postings are archived and searchable on the web at: 
> http://www.ieee-pses.org/emc-pstc.html
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> formats), large files, etc.
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Re: [PSES] R&TTE compliance test reports

[Michael Derby]

Hello,

 

Not quite Scott, I think what Thomas and Charlie were (correctly) saying,
was..

 

With harmonized and published standard, we do not need to use accredited
laboratory for the test.  

...in fact, regardless of whether you use a harmonised standard or not, the
lab does not need to be accredited.

 

If a laboratory is not accredited, how does a client know if the laboratory
is capable of doing the required tests.

..that's a very good question and it explains why so many accredited labs
(with their extra overheads) are still in business.   You somehow need to
trust your lab.   There's no certification for the R&TTE or EMC Directives,
so all the responsibility is on the person signing the DoC.   Good idea to
find a good lab!   That's why people use an accredited lab or one that they
really trust.

 

The capability includes equipment and its calibration, knowledge of standard
interpretation and skill set of actual testing.

.Yes.   You could look at the capability of the lab, how they calibrate
their equipment, chat to them about the standards and the staff, visit their
lab, etc.

 

 

Michael

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 29 February 2012 12:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] R&TTE compliance test reports

 

Hi Thomas,

Thanks for your advice.  With harmonized and published standard, we do not
need to use accredited laboratory for the test.  If a laboratory is not
accredited, how does a client know if the laboratory is capable of doing the
required tests.  The capability includes equipment and its calibration,
knowledge of standard interpretation and skill set of actual testing.

Regards,

Scott


On 29/2/12 6:45 AM, "Thomas Cokenias"  wrote:

Hi Scott,

Not sure if this answers your question,   but you MUST use a Notified Body
if you test to a standard that has not been harmonized as evidenced by being
published in the Official Journal of the EU.

If you do  test to a standard that is indeed harmonized and published in the
OJ, then you are not required to get a NB expert opinion, and as others have
posted, you do not need to use an accredited test lab for your tests either,
as long as you use test methods called out by the standards and your
equipment and procedures can meet the measurement  uncertainty limits
published therein.  This means you can do tests at your location if you
already have the equipment.

best regards

Tom Cokenias
T.N. Cokenias Consulting
P.O. Box 1086
El Granada CA 94018


On Feb 28, 2012, at 8:07 AM, Scott Xe wrote:

R&TTE compliance test reports 

I notice that some compliance reports of R&TTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

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Re: [PSES] R&TTE compliance test reports

[Scott Xe]

Hi Thomas,

Thanks for your advice.  With harmonized and published standard, we do not
need to use accredited laboratory for the test.  If a laboratory is not
accredited, how does a client know if the laboratory is capable of doing the
required tests.  The capability includes equipment and its calibration,
knowledge of standard interpretation and skill set of actual testing.

Regards,

Scott


On 29/2/12 6:45 AM, "Thomas Cokenias"  wrote:

> Hi Scott,
> 
> Not sure if this answers your question,   but you MUST use a Notified Body if
> you test to a standard that has not been harmonized as evidenced by being
> published in the Official Journal of the EU.
> 
> If you do  test to a standard that is indeed harmonized and published in the
> OJ, then you are not required to get a NB expert opinion, and as others have
> posted, you do not need to use an accredited test lab for your tests either,
> as long as you use test methods called out by the standards and your equipment
> and procedures can meet the measurement  uncertainty limits published therein.
> This means you can do tests at your location if you already have the
> equipment.
> 
> best regards
> 
> Tom Cokenias
> T.N. Cokenias Consulting
> P.O. Box 1086
> El Granada CA 94018
> 
> 
> On Feb 28, 2012, at 8:07 AM, Scott Xe wrote:
> 
>> R&TTE compliance test reports
>>> I notice that some compliance reports of R&TTE are reviewed by a notified
>>> body while some are issued by an accredited laboratory only.  Can someone
>>> advise if they have different purposes or requirements.
>>> 
>>> Thanks and regards,
>>> 
>>> Scott
>> -
>> 
>> 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
>> 
>> All emc-pstc postings are archived and searchable on the web at:
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>> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used
>> formats), large files, etc.
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>> Mike Cantwell 
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>> David Heald 
> 
> 


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Re: [PSES] R&TTE compliance test reports

[Thomas Cokenias]

Hi Scott,

Not sure if this answers your question,   but you MUST use a Notified Body if 
you test to a standard that has not been harmonized as evidenced by being 
published in the Official Journal of the EU.

If you do  test to a standard that is indeed harmonized and published in the 
OJ, then you are not required to get a NB expert opinion, and as others have 
posted, you do not need to use an accredited test lab for your tests either, as 
long as you use test methods called out by the standards and your equipment and 
procedures can meet the measurement  uncertainty limits published therein.  
This means you can do tests at your location if you already have the equipment.

best regards

Tom Cokenias
T.N. Cokenias Consulting
P.O. Box 1086
El Granada CA 94018


On Feb 28, 2012, at 8:07 AM, Scott Xe wrote:

>> I notice that some compliance reports of R&TTE are reviewed by a notified 
>> body while some are issued by an accredited laboratory only.  Can someone 
>> advise if they have different purposes or requirements.
>> 
>> Thanks and regards,
>> 
>> Scott
> -
> 
> 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 
> 
> All emc-pstc postings are archived and searchable on the web at: 
> http://www.ieee-pses.org/emc-pstc.html
> Attachments are not permitted but the IEEE PSES Online Communities site at 
> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
> formats), large files, etc.
> Website: http://www.ieee-pses.org/
> Instructions: http://listserv.ieee.org/request/user-guide.html
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> For help, send mail to the list administrators:
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> Mike Cantwell 
> For policy questions, send mail to:
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Re: [PSES] R&TTE compliance test reports

[Nick Williams]

On 28 Feb 2012, at 17:11, Amund Westin wrote:

> My input on this issue:
>  
> · Notified Body = Appointed by authorities for testing / 
> certification according to an EU directive
> · Accredited laboratory = Fulfil ISO/IEC 17025 Laboratory 
> Accreditation (criteria for laboratories to demonstrate the technical 
> competence to carry out specific test methods)

Correct. 


>  
> I assume that a Notified body must also be an Accredited laboratory, but not 
> visa versa.

Not necessarily. The requirement for appointment as a Notified Body is to have 
the appropriate competence to make judgements about whether or not a product 
complies with a particular Directive's essential requirements (as well as 
certain other administrative requirements such as independence from the 
manufacturer of the products they are auditing, and appropriate indemnity 
insurance). There is no specific requirement for an NB to be accredited as a 
test lab, although they frequently are. 

Nick. 



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Re: [PSES] R&TTE compliance test reports

[Michael Derby]

Hello Amund.

 

No, there's no requirement for a Notified Body to be associated with a test
laboratory.

 

Presently, there's no requirement for a Notified Body to be accredited under
the R&TTE Directive.. Although each nation typically does have an
accreditation requirement before submitting Notified Body applications to
the European Commission.   I hope that makes sense.

For example, a company in the USA wishing to act as a Notified Body would
have to apply through NIST, who would then assess their ability to do it
through accreditation etc., even though the Directive does not mandate it.

 

Under the NLF re-cast, this will change and I suspect the accreditation for
a Notified Body would be to something like Guide 65.

 

The R&TTE Directive is due to be included in the NLF changes but it's not
being grouped in the 'omnibus re-cast list' of Directives because the R&TTE
Directive is also actually being re-written for technical changes.

 

Directives like the EMC Directive are just being 're-cast' for the NLF and
should therefore not include any technical changes; whereas the R&TTE
Directive is actually being re-written and will certainly contain some
technical and administrative changes.

 

I'm sure I'll get corrected on some of my political terminology details here
but I hope the general idea makes sense.

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 28 February 2012 17:11
To: Michael Derby; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] R&TTE compliance test reports

 

My input on this issue:

 

. Notified Body = Appointed by authorities for testing /
certification according to an EU directive

. Accredited laboratory = Fulfil ISO/IEC 17025 Laboratory
Accreditation (criteria for laboratories to demonstrate the technical
competence to carry out specific test methods)

 

I assume that a Notified body must also be an Accredited laboratory, but not
visa versa.

 

Best regards

Amund

 

 

Fra: Michael Derby [mailto:micha...@acbcert.com] 
Sendt: 28. februar 2012 17:27
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] R&TTE compliance test reports

 

If the tests are all done to a harmonised standard (standard fully applied,
and passes), then there's no need to go to a Notified Body.

(You can, if you wish to, but there's no need to)

 

If you can't or don't fully apply a harmonised standard, then you must go to
a Notified Body for their opinion.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE compliance test reports

 

I notice that some compliance reports of R&TTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

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Re: [PSES] R&TTE compliance test reports

[Brian Oconnell]

The original 2010 proposals were to include the R&TTE in the NLF as a
re-cast directive. I cannot find any recent activity on this. Any
information if NLF will affect acceptance of these self-generated reports?

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Charlie
Blackham
Sent: Tuesday, February 28, 2012 8:51 AM
To: Scott Xe; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: R&TTE compliance test reports

Scott

Also - as a manufacturer, there is nothing to stop you performing your own
tests - there is no mandatory requirement to use an accredited lab.

If you're not using an accredited Lab and need a Notified Body opinion -
talk to them first about how you will demonstrate suitable competence and
traceability.

Regards
Charlie

From: Scott Xe [mailto:scott...@gmail.com]
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE compliance test reports

I notice that some compliance reports of R&TTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

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Re: [PSES] R&TTE compliance test reports

[Charlie Blackham]

Scott

Also - as a manufacturer, there is nothing to stop you performing your own 
tests - there is no mandatory requirement to use an accredited lab.

If you're not using an accredited Lab and need a Notified Body opinion - talk 
to them first about how you will demonstrate suitable competence and 
traceability.

Regards
Charlie

From: Scott Xe [mailto:scott...@gmail.com]
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE compliance test reports

I notice that some compliance reports of R&TTE are reviewed by a notified body 
while some are issued by an accredited laboratory only.  Can someone advise if 
they have different purposes or requirements.

Thanks and regards,

Scott
-


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Re: [PSES] R&TTE compliance test reports

[Michael Derby]

If the tests are all done to a harmonised standard (standard fully applied,
and passes), then there's no need to go to a Notified Body.

(You can, if you wish to, but there's no need to)

 

If you can't or don't fully apply a harmonised standard, then you must go to
a Notified Body for their opinion.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE compliance test reports

 

I notice that some compliance reports of R&TTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

-


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RE: [PSES] R&TTE and IEC 60950

[emc-p...@ieee.org]

R&TTE Article 3.1(a) states "the protection of the health and the safety of
the user and any other person, including the objectives with respect to
safety requirements contained in Directive 73/23/EEC, but with no voltage
limit applying;"

EN60950 would be an appropriate Harmonised Standard for you to "apply".
I don't suppose there will be a lot of "testing", but you do have issues
such as the safe charging and discharging of the battery to consider.

If you don't fully "apply" 60950 in your Technical File, you need a NB
opinion of your assesssment.

Regards
Charlie


-Original Message-
From: Gartman, Richard [mailto:rgart...@ti.com] 
Sent: 23 August 2010 20:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE and IEC 60950

I am looking for view points on wither or not IEC60950 is necessary for a
WiFi product, and if so why. The WiFi client product is a battery operated
802.11 b/g device with < 0.1W output. The battery in the WiFi client device
is recharged by a class 2 EPS that has both UL/CAS and GS mark.

Thanks
W. Richard Gartman, MS, CSP
Product Stewardship Manager
Texas Instruments, Education Technology
7800 Banner Drive, Dallas, Tx 75251
Office: 972-917-1636Email: rgart...@ti.com 
Fax: 972-917-0668 URL: www.education.ti.com  
  www.education.ti.com/us/productstewardship 
  

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RE: [PSES] R&TTE and IEC 60950

[emc-p...@ieee.org]

R&TTE Article 3.1(a) states "the protection of the health and the safety of
the user and any other person, including the objectives with respect to
safety requirements contained in Directive 73/23/EEC, but with no voltage
limit applying;"

EN60950 would be an appropriate Harmonised Standard for you to "apply".
I don't suppose there will be a lot of "testing", but you do have issues
such as the safe charging and discharging of the battery to consider.

If you don't fully "apply" 60950 in your Technical File, you need a NB
opinion of your assesssment.

Regards
Charlie



From: Gartman, Richard [mailto:rgart...@ti.com] 
Sent: 23 August 2010 20:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE and IEC 60950

I am looking for view points on wither or not IEC60950 is necessary for a
WiFi product, and if so why. The WiFi client product is a battery operated
802.11 b/g device with < 0.1W output. The battery in the WiFi client device
is recharged by a class 2 EPS that has both UL/CAS and GS mark.

Thanks
W. Richard Gartman, MS, CSP
Product Stewardship Manager
Texas Instruments, Education Technology
7800 Banner Drive, Dallas, Tx 75251
Office: 972-917-1636Email: rgart...@ti.com 
Fax: 972-917-0668 URL: www.education.ti.com  
  www.education.ti.com/us/productstewardship 
  

-

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RE: [PSES] R&TTE and IEC 60950

[emc-p...@ieee.org]

If you are interested in the European requirements, it is my understanding
that the minimum voltage limits for applicability of EN 60950 are removed
when applying the CE mark under the R&TTE directive. There is some
discussion here in legalese:
http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm#h2-1.-ambiguity-in-annex-iii-of-the-directive


Best Regards

 

 

Hans T Mellberg
CTO,
Bay Area Compliance Laboratories
www.baclcorp.com
1274 Anvilwood Avenue
Sunnyvale, CA 94089, USA
(408)732 9162 x 3601
fax: (408) 732 9164

-Original Message-
From: Gartman, Richard [mailto:rgart...@ti.com] 
Sent: Monday, August 23, 2010 12:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE and IEC 60950

I am looking for view points on wither or not IEC60950 is necessary for a
WiFi product, and if so why. The WiFi client product is a battery operated
802.11 b/g device with < 0.1W output. The battery in the WiFi client device
is recharged by a class 2 EPS that has both UL/CAS and GS mark.

Thanks
W. Richard Gartman, MS, CSP
Product Stewardship Manager
Texas Instruments, Education Technology
7800 Banner Drive, Dallas, Tx 75251
Office: 972-917-1636Email: rgart...@ti.com 
Fax: 972-917-0668 URL: www.education.ti.com  
  www.education.ti.com/us/productstewardship 
  

-

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RE: [PSES] R&TTE and IEC 60950

[emc-p...@ieee.org]

If you are interested in the European requirements, it is my understanding
that the minimum voltage limits for applicability of EN 60950 are removed
when applying the CE mark under the R&TTE directive. There is some
discussion here in legalese:
http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm#h2-1.-ambiguity-in-annex-iii-of-the-directive


Best Regards

 

 

Hans T Mellberg
CTO,
Bay Area Compliance Laboratories
www.baclcorp.com
1274 Anvilwood Avenue
Sunnyvale, CA 94089, USA
(408)732 9162 x 3601
fax: (408) 732 9164


From: Gartman, Richard [mailto:rgart...@ti.com] 
Sent: Monday, August 23, 2010 12:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE and IEC 60950

I am looking for view points on wither or not IEC60950 is necessary for a
WiFi product, and if so why. The WiFi client product is a battery operated
802.11 b/g device with < 0.1W output. The battery in the WiFi client device
is recharged by a class 2 EPS that has both UL/CAS and GS mark.

Thanks
W. Richard Gartman, MS, CSP
Product Stewardship Manager
Texas Instruments, Education Technology
7800 Banner Drive, Dallas, Tx 75251
Office: 972-917-1636Email: rgart...@ti.com 
Fax: 972-917-0668 URL: www.education.ti.com  
  www.education.ti.com/us/productstewardship 
  

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RE: [PSES] R+TTE product - keypad design

[emc-p...@ieee.org]

Nick

Have a look at:

ITU E.161 (http://www.itu.int/rec/T-REC-E.161-200102-I/en )

ETSI ES 202 130 and referenced documents

regards
Charlie


From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: 07 April 2010 10:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R+TTE product - keypad design

I'm looking at a product which is within the scope of the R+TTE 
Directive and has a numerical keypad.

Can anyone tell me if there is a standard for the layout of numerical 
keypads on telecoms type equipment, and, in particular, if that 
standard required the presence of an identifying 'pip' on the 5 key.

Thanks

Nick.

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