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FIRST AUSTRALIAN EMC TEST HOUSE DESIGNATED BY THE EUROPEAN UNION AS A Conformity Assessment Body (CAB)...News Article 1999

THE ROLE OF AN EMC TEST HOUSE AND COMPETENT BODY
an article by EMC Technologies Technical Director

GOVERNMENT APPOINTED COMPETENT BODY

NATA Accredited and Government Appointed

EMC Technologies is pleased to announce that both Melbourne and Sydney facilities have been appointed by the Australian Government Spectrum Management Agency (now the Australian Communications Authority) as a Competent Body under the EMC Framework, Radiocommunications Act 1992.

In addition to providing the most comprehensive NATA accredited EMC testing services in Australia, EMC Technologies can also provide suppliers and manufacturers of electrical and electronic products with the alternate route to establishing compliance by means of the assessment of Technical Construction Files (TCF).

Examples of the use of the TCF route include the following:

Testing against standards is not practical due to the physical size or nature of the device.
There are a large number of product variants that make testing un-economical.
Where modifications have been performed on approved equipment.
Where testing has been performed to other standards.

EMC Technologies is a member of the Australian Competent Body Association (ACBA) and the Electrical Compliance Testing Association (ECTA). The key personnel are also NATA signatories for most of the SMA EMC standards and are well placed to offer independent advice to manufacturers and suppliers on the selection of the best route to compliance with the EMC regulations. This makes EMC Technologies the only Competent Body to date to also provide NATA accredited testing.

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Circumstances where the TCF might be used

This document deals with five scenarios where
use of the TCF might be appropriate.

(This is not intended to be an exclusive list of the potential applications of a TCF and the recommendations given should be modified for other circumstances where necessary.)

For apparatus where there is no applicable harmonised EMC standard. Although the availability of generic standards theoretically means that a standard exists for every product, it is recognised that in practice their use may not be practicable for some products.

For apparatus where harmonised standards exist but the manufacturer applied that standard in part only, e.g. where a manufacturer can justify that a particular type of apparatus complies with the protection requirements of the Directive without performing test to any or all of the phenomena described in the relevant harmonised specification.

For installations where testing to harmonised standards is not practicable due to the physical properties (e.g. size, location) of the installations.

For products where the testing of each individual product to harmonised standards is not practicable due to the large number of similar product variants.

For products having existing certification to EMC standards not recognised by the EC, but which are nevertheless regarded as indicating compliance with the protection requirements of the directive.

Suggested TCF contents

In this section, brief details of the possible format and content of TCFs as briefly outlined in the above 5 scenarios.

1. No applicable harmonised standard

There may well be cases where a specific standard for a given product does not exist, and the generic standard is not considered appropriate, but nevertheless it will be in the manufacturer�s best interests to assemble test data of some sort as the best method of demonstrating compliance with the protection requirements. The emphasis will therefore be on drawing up in collaboration with the Competent body a test program suitable for the type of product being assessed, and on demonstrating the validity of this program, rather than on a detailed analysis of the EMC protection methods used in the apparatus. Part II of the TCF (procedures used to ensure conformity) will reflect this, but Part I will still have to contain sufficient detail to identify the product.

2. Harmonised standards applied in part only

Under the circumstances where harmonised standards have been applied in part only, it is envisaged that the TCF will seek to demonstrate why tests for certain phenomena were not felt to be necessary. It is likely that the emphasis of the TCF will be on the construction of the apparatus; in particular to demonstrate what special properties the apparatus demonstrates which render as unnecessary some or all of the tests described in the relevant harmonised standards. The technical description of the apparatus is therefore likely to be extensive, making easier the theoretical justification for not performing tests in the technical rationale.

3. Installations where testing to harmonised standards is not practicable due to the physical properties of the installation

It is envisaged that there may be occasions where, because of the physical properties of an installation, it is not practicable to perform tests according to harmonised standards. For instance the installation might be too large, or it might operate in such a way that the test could not be conducted using established procedures. Under these circumstances, the role of the TCF is to define a framework within which the creator of the installation can operate and remain confident that the apparatus which makes up the installation complies with the essential requirements of the directive. The description of the apparatus should therefore include details of the physical location of the installation and also any relevant characteristics of the physical location, e.g. the composition of the building in which the installation is housed, and any significant local environmental factors such as close proximity to a recognised source of EM disturbance. Given the difficulty of performing tests on the installation as a whole, Part II will concentrate on tests performed on the apparatus comprising the installation, design steps taken to deal with EMC and adherence to installation and maintenance codes of practice.

4. Products where the testing of each individual product is not practicable due to the large numbers of similar product variants

It is envisaged that certain kinds of products and installations will be made available as large numbers of broadly similar product variants, perhaps to meet particular customer specifications. Examples of this might be local area networks in offices or custom variants of commercial vehicles. Part I might therefore need to include identification of variants (or broad families of variants where listing every individual variant would be excessive), block diagrams showing typical interrelationships between functional areas and a description of the principal components and sub-assemblies and on typical installations. In the case of system variants such as local area networks, details might also be included of any instructions to installers or users indicating appropriate installation and maintenance codes of practice.

5. Products having existing certification to EMC standards not recognised by the EC

It is recognised that compliance with some EMC standards not as yet officially recognised by the European Directive will indicate compliance with the essential requirements of the directive. Such standards might include military standards, national civil EMC standards, or standards generated by industry. In such cases, the TCF could concentrate on the coverage of the standard (i.e. whether additional verification was needed in regard to phenomena not covered by the standard in question, but addressed in the Directive); the performance levels required by the standard, and the test methods employed.

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COMPETENT BODY REPORT

The report from the Competent Body might mirror the content of parts one and two of the TCF, assembled by the manufacturer. Hence , it could:

Refer to the exact build state of the apparatus assessed, cross referencing with part I
Comment on the technical rationale.
State what work was done to verify the contents and authenticity of the design information in the TCF, cross referencing with part II (ii).
Comment where appropriate on the procedures used to control variants, and on environmental, installation and maintenance factors which may be relevant.
Contain an analysis of the test performed either by the manufacturer, an authorised third party, or the competent body itself, and the results obtained, so as to assess whether those test indicate that the apparatus should comply with the essential requirements of the Directive, cross-referencing with part II (iii).
It is envisaged that Parts I and II of the TCF will be written by the manufacturer in co-operation or consultation with the Competent Body. The report from the Competent Body should therefore not need to repeat much of the information contained in Parts I and II.
At the end of the report a detachable certificate will be supplied, this can be used by the manufacturer as an indicator of compliance where it is felt it would be inappropriate to submit the entire report. It is possible that where Parts I and II of the report prepared by the manufacturer largely �speak for themselves�, the Competent Body might prepare a certificate only.
It should be emphasised that the manufacturer is ultimately responsible for the declaration of conformity of products certified via the TCF route. The role of the Competent Body is to assert that the evidence contained within the TCF is consistent with conformity. It is the manufacturer�s responsibility to ensure that the information is correct and that subsequent production units are consistent with it.

Technical rationale

a) A brief exposition of the rationale underpinning the inclusion and balance of evidence in II (ii ) and II (iii).

Test data

A list of the EMC tests performed on the product, and test reports relating to them, including details of test methods, etc.;
an overview of the logical processes used to decide whether the tests performed on the apparatus were adequate to ensure compliance with the directive;
a list of tests performed on critical sub-assemblies, and test reports or certificates relating to them.

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If it's really URGENT

Call any time on: +61 418 566 466

EMC Technologies - Victoria (Head Office)

176 Harrick Road Keilor Park Victoria 3042 Australia
Ph: +61 3 9365 1000 Fax: +61 3 9331 7455

EMC Technologies - New Zealand

47 MacKelvie Street, Grey Lynn, Auckland New Zealand Ph: + 64 93600 862 Fax: + 64 93600 861

EMC Technologies - New South Wales

Unit 3, 87 Station Road, Seven Hills NSW 2147 Australia Ph: + 612 9624 2777 Fax: + 612 9838 4050

EMC Technologies - Queensland

Unit 1 / 15 Success Street, Acacia Ridge 4110 Qld Australia Ph: + 617 3875 2455 Fax: + 617 3875 2466