the what's inside product safety newsletter · product safety newsletter • page 3 importers...

Product Safety Newsletter •

Chairman's Message .................................. 1

Officers of the PSTC's ............................... 2

Letters to the Editor ................................... 3

Area Activities ........................................... 4

Technically Speaking ................................ 5

ECMA Generic Safety Standard Activity . 6

Hi-Pot Leakage Current ............................. 7

Safety Net--News from the Internet .......... 8

Executing Product Safety Functions ......... 9

Institutional Listings ................................ 22

Vol. 9, No. 2 April - June, 1996

Mark your calendars and make plans to

attend the 1996 IEEE EMC Society

International Symposium to be held in

Santa Clara, CA from August 19 to 23.

The theme of the Symposium is “EMC: Silicon to

System”, but product safety is included, too. One of

the midweek sessions features paper presentationshighlighting product safety-related papers. Also, our

technical committee, TC-8 (Product Safety), will be

sponsoring a workshop on European Union CE Mark-ing issues: "EU and You: Direction for the Road to

Compliance.” The focus will be on Telecom, Medi-

cal Device, Machinery and Low Voltage Directives.The workshop is scheduled for Friday morning Au-

gust 23 from 8:30 to 12:00. We will keep you advised

of further Symposium developments including de-tails of the TC-8 Annual Meeting.

1996 International EMC Symposium

TheProductSafetyNewsletter

Continued on page 16

What's Inside

Chairman's Message


The

ProductSafetyNewsletter

The Product Safety Newsletter is published bimonthly by the Product Safety Technical Committee of theIEEE EMC Society. No part of this newsletter may be reproduced without written permission of the authors.All rights to the articles remain with the authors.

Opinions expressed in this newsletter are those of the authors and do not necessarily represent the opinionsof the Technical Committee or its members. Indeed, there may be and often are substantial disagreementswith some of the opinions expressed by the authors.

Subscriptions are free and may be obtained by contacting "Subscriptions", below.

Central CommitteeChairman: Brian Claes (510) 659 6574

(510) 659 6852 (fax)Vice Chair: Richard Pescatore (408) 447 6607 [email protected]./Tres.: John McBain (415) 919 8426 [email protected]

(415) 919 8504 (fax)Symposium: Mark Montrose (408) 247 5715

Local GroupsCHICAGO

Chairman: John Allen (708) 238 0188

COLORADORichard Georgerian (303) 417 7537

SO CAL/ORANGE COUNTYChairman/Sec.: Charlie Bayhi (714) 367 0919

PACIFIC NORTHWEST (PORTLAND)Chairman/Sec-Tres.: Scott Varner (503) 656 8841 [email protected]

NORTHEASTDave Lorusso (508) 435 1000 x7518 [email protected]

SANTA CLARA VALLEYChairman: Murlin Marks (408) 985 2400 X2353 [email protected]

SEATTLEChairman: Walt Hart (206) 356 5177 [email protected]

TEXAS (CENTRAL)Chair Vic Baldwin (512) 990 6145

Newsletter CommitteeEditor Roger Volgstadt (408) 285 2553 (fax) [email protected]

Subscriptions Dave McChesney (408) 296 3256 (fax)

Institutional Listings Ron Baugh (503) 691 7568 (fax) [email protected]

News & Notes John Rolleston (614) 438 4355 (fax) [email protected]

Activities Editor Kevin Ravo (408) 296 3256 (fax) [email protected]

Page Layout Ken Warwick (408) 974 0113 (fax) [email protected]


importers of record of products manufactured else-where can hold a certificate. Other entities, Mexicanor not, cannot hold NOMs.

Finally, although the Mexican electrical code waspublished in October of 1994, it didn’t go into effectuntil July of 1995, and then only partially, for basicconstruction material categories. In general, IT equip-ment shouldn’t be effected by this event.

I know that Erin McLaughlin wrote an article aboutMexican approvals some time back. Maybe it’s timefor another. What are your thoughts? This may be agood chance to remind this distinguished audience ofour presence in Mexico ... At any rate, feel free to passthis info on, and tell them that if anyone has anyquestions, they can certainly give me a call.

Tim CallandUL, Mexico OfficePhone: 52-5-294-7660 �

Mark your calendarsand make plans to at-tend the 1996 IEEEEMC Society Interna-tional Symposium to beheld in Santa Clara, CAfrom August 19 to 23.

(Kevin Ravo, our Chapter Activities Editor, passedthe following letter on to the PSN. It is reproducedhere in part with permission from the author-Ed.)

Dear Kevin,

I noticed an item under “News and Notes” [PSN, Vol.8, No. 5, Nov-Dec, 1995] about Mexican certifica-tion that wasn’t quite right, so I’m forwarding mycomments to you (lucky guy).

The article says that Mexican test labs will accepttesting done at other “approval houses” (this expres-sion always galls me). Any accredited Mexican(SINALP) lab is required under the terms of itsaccreditation to generate its own data (on Mexicansoil) and risks losing its accreditation, or worse, if itrepresents data from another source as its own. Theday foreign data is acceptable in Mexico, we’ll beshouting it from the roof-tops - but that day has yetto arrive.

Second, the article isn’t very clear about who inMexico can hold a certificate. Only the manufacturerof products made in Mexico, or the legal importer or

Letters to the Editor


Gary Kress, Ph.D.457 Hawthorne St.Monterey, CA. 93940voice: 408-375-7200

March: HazOps and System Safety - Charles Hoes,Hoes Engineering.

April: Product Safety Hazards and Electromag-netic Fields - Dan Weinberg, Ph. D.

May: Part 6 for Telecom Equipment - Dan Barsotti,UL.

June: CPSC Role and Function - Lee Baxter,CPSC

For additional information contact:Murlin Marksvoice: 408-985-2400fax:: 408-296-3256e-mail: [email protected]

Central Texas ChapterFor information, contact:Vic Baldwinvoice: 512-990-6342fax:: 512-990-6145

Orange County-Southern CaliforniaChapterFebruary Meeting:

by Kevin Ravo voice: 408-985-2400 ext. 32311 fax: 408-296-3256 email: [email protected]

The following is an overview of recent or plannedactivities for the various Local Groups aroundthe USA. If you have any activities’ informa-

tion that may be of interest to readers, please forwardit to the above address and I will try to include it in thenext issue.

Santa Clara Valley ChapterFebruary Meeting:The social was held at El Torito’s followed by themeeting at Applied Materials.

Business items consisted of a discussion of the 1996EMC Symposium, the MJD Award, and PSTC Elec-tions in May.

The main presentation was Ergonomics in the Work-place by Gary Kress, Ph.D, Human/Machine Systems.Gary discussed various topics related to workplaceinjury.

Strains and Sprains account for 40% of lost workdays.Ergonomics is the designing of jobs to fit people andaddressing hazards associated with activities, not equip-ment. The traditional focus has been on hardware ratherthan the operator. In an ergonomic work system, thefocus is on the worker.

For more information or questions, contact:Continued on page 15

Area Activities


Copyright 1996 by Richard NuteInternet: [email protected],com

Consider similar situations where we are carefulto avoid the hazardous situation. Consider theprocess of crossing a street. We avoid crossing infront of a nearby moving car. Consider theChernobyl nuclear power plant disaster. We avoidgetting within 20 miles of that site.

We simply stay away from the hot pot, the boilingwater, the moving car, and the radiation-emittingpower plant. We interpose distance between usand the hazardous situation. In some cases, thatdistance is small as in avoiding a burn from a potof boiling water. In other cases, the distance islarge as in avoiding the radiation from Chernobyl.

And, we avoid putting a finger into an emptyEdison-base light socket.

So, one means of protection against injury ispersonal avoidance. Personal avoidance is usu-ally accomplished by putting distance between usand the hazardous situation.

How much distance?

That depends on the nature of the situation. If weare considering the pot of boiling water, then thedistance need only be a few inches. If we areconsidering glass-making, then the distance fromthe furnace needs to be quite a few feet. In thesetwo cases, the distance can be predicted from thefall-off of heat and temperature with distance.

If we are considering crossing the street, then wedo some mental vector analysis of our velocity and

MODELS FOR PROTECTIONAGAINST INJURY

How does safety work? That is, given ahazardous situation, how do we preventinjury from that situation?

At first, these questions seem far too abstract toeven begin to formulate an answer. So, let’sconsider some real situations, and then form somegeneralizations.

Consider a pot of boiling water on the stove.Clearly, if we were to touch the pot or the water,we would incur a burn. So, we don’t touch the pot,and we don’t put a finger in the water.


Technically Speaking


by Jim Kearns and Gino Lauri

ECMA is a Europe based internationalassociation founded in 1961 and dedicatedto the standardization of information and

communication systems. The work of ECMA hasalways been recognised as far sighted and reflectingtechnological trends at an early stage. As aconsequence many ECMA Standards have becomeinternational and European Standards. To ensureclose co-operation ECMA has established formalliaisons with all European and internationalstandardization bodies. Similar to other standardswriting organizations, the work of ECMA is carriedout by Technical Committees (TC). ECMA TC12has recently undertaken the task of developing auser friendly “generic” safety standard.

It is the opinion of the members of ECMA TC12that with the advent of multimedia products theborderline between different classes of products,like IT equipment, audio-video equipment, com-munication equipment, and the environment withinwhich the equipment is used, has become blurred.This situation has highlighted the fact that exist-ing standards covering single classes of productsare occasionally inconsistent and in conflict.

The philosophy being applied in the developmentof this ECMA standard is to define hazard-basedrequirements, using engineering principles andtaking into account relevant IEC equipment stan-dards, e.g. IEC 65, IEC 950 and IEC pilot docu-ments, e.g. IEC 664 and IEC 1140. Wheretechnical discrepancies between standards emerge,

a conclusion will be based on engineering prin-ciples, and will be presented to the relevant IECtechnical committees for consideration.

The principles of safety and the technical contentof IEC 950 and IEC 65 will be used to assist in thisdevelopment. It is however to be emphasized thatthe ECMA/TC12 activities do not aim to mergeIEC 950 and IEC 65: the goal is to develop ageneric standard for electronic equipment whichmay be used in a domestic and professional envi-ronment, and to offer it as the basis for a new IECstandard.

This new ECMA Standard will be hazard-basedand the associated requirements will be based onthe philosophy of prevention and protection. Thefollowing hazards are being considered as basic:

Electrical shock hazard Electrical shock is due to current passing throughthe human body. Currents of the order of a milli-ampere can cause a reaction in persons in goodhealth and may cause indirect danger due to invol-untary reaction. Higher currents can have moredamaging effects. Voltages up to about 40 V peak,or 60 V d.c., are not generally regarded as danger-ous under dry conditions, but parts which have tobe touched or handled should be at earth potentialor properly insulated.

Mechanical hazard Mechanical hazards may result from sharp edges,sharp corners, hazardously rotating or otherwisemoving mechanical parts and from equipment


EMCAGeneric Safety Standard Activity


(The following is in response to a question raised onthe IEEE Product Safety internet discussion group-Ed.)

Hi-Pot leakage current is proportional to measuredleakage current.

If you are doing an ac hi-pot test, then the hi-potcurrent will be proportional to the ac leakage current.If you are doing a dc hi-pot test, then the hi-potcurrent will be proportional to the dc leakage current.

Specifically:

hi-pot test voltsHi pot I = ——————— x leakage current leakage I test volts

You can also calculate the hi-pot current from thecapacitive reactance of all the Y-capacitors in themains circuit. You will need to add some capacitanceto account for the mains-to-ground capacitance of themains circuits and mains transformer.

The hi-pot trip current must be set at some valuegreater than the actual current required for the hi-pottest. The value must account for the component andmanufacturing tolerances contributing to leakagecurrent (the tolerances of the Y capacitors and thevariation in mains-to-ground wiring capacitances).

For example, if the 250-volt leakage current is 2.0

milliamperes, then the hi-pot current for a 1500-volthi-pot test would be:

1500 hi-pot current = ——— x 2.0 250

hi-pot current = 12.0 milliamperes

You would set your hi-pot trip current at, say, 15milliamperes to account for component and manu-facturing tolerances.

The actual value of the trip current is not important.The purpose of the hi-pot test is to find gross manu-facturing errors (which are catastrophic hi-pot fail-ures). I don’t believe it is very useful to attempt to usethe hi-pot test to discriminate against excessive toler-ance buildup in mains-to-ground capacitance.

By the way, there is no published current limit for thehi-pot test, either in standards or certification-houserules. In the “old days,” hi-pot testers had no currenttrip. The only way you could tell a failure (other thanhearing the ZAP!) was that the voltmeter would failto advance to full voltage. Some hi-pot testers alsohad ammeters, in which case you knew you had afailure when the ammeter needle pinned to the highend of the scale.

Richard Nute �

Hi-Pot Leakage Current


by John Quinlan

This is the first installment of a new columnin PSN which will report on safety, EMCand compliance-related discussions and re-

sources which appear on various Internet forums.Ideas for the column content and format are stillevolving and will hopefully be shaped by readers’comments. If you have a comment or suggestionfor future editions, or a specific Internet subjectyou would like to see addressed, please contact meat: [email protected]. For now, the columnwill track some of the compliance-related topicsthat have been recently discussed on the Internet,and then selected parts of the dialog for one or twoof these topics will be published. The topics willbe selected primarily from the emc-pstc list andrelevant newsgroups. The dialog will be editedinto a question and answer format. The editorreserves the right to edit the material based onavailable space and relevance to the subject mat-ter. Although selection of topics is necessarilysubjective, the number of messages that a topicgenerates will certainly be part of the criteria.

Perhaps the best way to start the first column is bybriefly listing some of the principle Internet re-sources for safety, EMC and compliance issues.Most of this information has been extracted froman informal EMC/compliance FAQ, authored byBill Lyons ([email protected]) and peri-odically posted to the sci.physics.electromagnewsgroup.

Continued on Page 10

LISTSERVERSEMC-PSTC: To subscribe, send a message [email protected] with the followingphrase in the message body (brackets omitted):subscribe emc-pstc <your_email_address>

TREG (Telecom Regulatory Electronic Grape-vine): to subscribe, send a message with yourrequest in the message body to scott%[email protected]

NEWSGROUPSsci.physics.electromag (preferred),sci.electronics.design, sci.electronics.misc

note: an RFD for an unmoderated newsgroup de-voted to compliance is circulating, and a CFVshould be forthcoming. Mark Zenier([email protected]) and Bill Lyons are theproponents.

WEB SITES Regulatory Compliance Information Center athttp://uc.com/compliance_engineering/

Compliance Engineering Magazine at http://www.ce-mag.com

The IEEE Electromagnetic Compatibility Societyat http://www.emclab.umr.edu/ieee_emc/

Safety Net--News from the Internet


Continued on Page 17

[We are grateful to the author for providing aseries of condensed installments from his book“Managing Product Safety Activities”. This text isa registered copyright of Paul W. Hill & Associ-ates, Inc., and is reproduced with permission. De-tails about the book may be obtained by calling(407) 368-2538 - Ed.]

The preceding section dealt with the basic activi-ties of a product safety function. This section willdeal with establishing the means to execute thosefunctions.

Product safety activities are multi-disciplinedin nature, acting in conjunction with severaldifferent functions within a company. Such

a span of activity requires some means of keeping

product safety efforts in perspective and chan-neled, such as a recognized operating plan, so as tocontinuously support the product safeness objec-tives of the business.

When undertaking the installation of an ISO 9000management system such a document clearly out-lining the intent, major objectives, procedures,and tracking of results for the activities of productsafety are an absolute necessity.

Importance of a formal planThe ideal product safety mission statement is adocument issued by the senior management of anorganization outlining the basic product safenesspolicy and practices to be followed in the develop-ment, manufacture and distribution of theorganization’s product and services.

Such a statement of intent and purpose is thecharter of the product safety effort.

Also, the product safety mission statement be-comes a critical element should the safeness of aproduct become the issue in a litigation action.Under such circumstances, management must con-vincingly establish that a recognizable processwas in place for handling product safeness mattersin an orderly and reasonable manner.

In the event of a litigation action, it is essential todispel any hint that product safeness factors wereignored or received only casual management con-sideration in the design, manufacture or servicing

Executing Product Safety Functions


International Product Safety News Safety Link athttp://www.safetylink.com/

LANGUAGES REQUIRED BY THE LVDThis issue’s highlighted topic pertains to the lan-guages required by the LVD for product documen-tation and safety markings. The dialog, which wasinitiated by Doug Henderson ([email protected]) on 01/31/96, elicited eight re-sponses. Edited versions of Nick Rouse’s([email protected]), Peter Perkin’s([email protected]) and Volker Gasse’s([email protected]) responses appear below.

Doug Henderson poses the question:With regard to the LVD, is there a list of EUmember languages in which product manuals,safety markings, and other documentation must betranslated? For example, many of us currentlyhave German passages in our manuals because wehave our products licensed by TUV for Germany.What about French, Italian, Greek, and other lan-guages?

Nick Rouse responds:The languages you mention are just the workinglanguages in which all EU documents, even unof-ficial working documents, are issued. There are 11official languages of the EU: Danish, Dutch, En-glish, Finnish, French, German, Greek, Italian,Portuguese, Spanish and Swedish. There is, as faras I know, no official regulation that says thatsafety warnings in all these languages are neces-sary or sufficient to enable free marketing through-out the EU. To market a product in a particularEuropean country you must CE mark it for anymandatory directives requiring that mark, and

meet all additional safety requirements of thatparticular country. In the UK, for example, thereis a requirement to use English for any warningsnecessary for safe operation. There is nothing tostop you from CE marking a product with English-only safety warnings and marketing it only in theUK and Republic of Ireland, if you meet all otherspecific national safety requirements. Nationalgovernments are permitted to add specific na-tional safety requirements under Article 9 of theLVD, provided that these are reported to theCommission and other member states, to givethem the opportunity to object. You may be ableto obtain information about specific national re-quirements from the Commission. I suspect youwill have to produce versions in all 11 languagesif you want sell throughout the EU, and you mayhave to add Norwegian and Icelandic if you wantto sell to the full EEA. Most manufacturers resignthemselves to the fact that the single market isonly a distant ideal, and they or their agents mustmake accommodations for the local markets.

Peter E. Perkins responds:The clearest direction regarding languages re-quired for sales into the EU comes from theMachinery Directive, which states:

“The instructions must be drawn up in one of theCommunity languages by the manufacturer or hisauthorized representative established in the Com-munity. On being put into service, all machinerymust be accompanied by a translation of the in-structions in the language or languages of thecountry in which the machinery is to be used andby the instructions of the original language. Thistranslation must be done either by the manufac-turer or his authorized representative establishedin the Community or by the person introducing themachinery into the language area in question. By

Safety NetContinued From page 8


way of derogation from this requirement, the main-tenance instructions for use by the specializedpersonnel employed by the manufacturer or hisauthorized representative established in the Com-munity may be drawn up in only one of theCommunity languages understood by that person-nel.”

Regarding the hazard markings on the equipment,if the company does not want to provide fullmultilingual markings, an alternative that I havebeen recommending is to not only copy the hazardmarkings labels into the manual, but to also havea description of the marking that repeats the word-ing on the marking. When this is done, the descrip-tion of the marking will be translated with themanual and the local person will have an explana-tion of the markings in his language.

Volker Gasse adds:The requirements described by Peter Perkins arecorrect for the Machinery Directive 89/392/EEC.For Germany, however, when you have a productcomplying to the LVD 73/23/EEC amended by theDirective 93/68/EEC, a national A-Deviation toEN 60950 A3:1995 exists. This deviation requiresthat the maintenance instructions also be trans-lated into the German language (Annex ZC 1.7.14).This is currently in force although it is in contrastto the EU harmonization requirements. Other simi-lar local deviations may exist. �

Update to "Upcoming Clearancesand Creepage Distances for IEC950"by Lal Bhara

The article "Upcoming Clearances and Creep-age Distances for IEC 950", published in theNovember-December, 1995 issue of the Prod-uct Safety Newsletter, was written after theCopenhagen meeting of WG6 in September ,1995. Since then, various comments werereceived on the document 74/435/CD whichwas the result of the WG6 of TC74 atCopenhagen. During the last meeting of WG6in Paris in March, 1996, the national commit-tee comments were reviewed by WG6 and anew document 74/435/CD has been published.For clearances, this document gives twochoices to the designer. The first choice is thepresent clearances as given in the secondedition of the IEC 950 including amend-ments 1, 2, 3 and the forthcoming amend-ment no. 4.

The second choice will be the clearances asgiven in the previous document 74/435/CDwhich will now be contained in the norma-tive annex. The two choices are alternativesto each other and cannot be mixed. Likewise,the present electric strength test in the secondedition of IEC 950 stays as it is when clear-ances in the body of the standard (ie: sub-clause 2.9) are used. The electric strengthtest given in the annex should be appliedwhen clearances in the annex are used.


Generic StandardContinued From page 6

More informationThe publication of the resulting ECMA Standardis expected in August 1997. If you are interestedin participating in this work and your company isalready a member of ECMA then you shouldcontact the ECMA Secretariat. A list of ECMAmember companies can be obtained from the web,see addresses below. If you would like to find outhow to join ECMA or learn more about the orga-nization and its work, you can obtain full detailseither from the ECMA Secretariat or from theECMA home page on the Web.

The addresses are:

ECMA114 Rue du RhoneCH1204 Geneva Switzerland

Fax: +41 22 849.60.01

E-mail:[email protected]: http://www.ecma.chFTP site: FTP.ecma.ch

Jim Kearns is European Product Safety Manager,Apple Computer Limited, Cork, Ireland.Gino Lauri is Senior Technical Officer, ECMA,Geneva, Switzerland. �

instability.

Heat hazardHeat hazards may result from high temperatureson surfaces which are accessible to the user, orfrom short-circuiting of adjacent poles of highcurrent supplies or high capacitance circuits caus-ing arcing or ejection of molten metal resulting inundesirable reactions and/or burns.

Excessive temperatures resulting from overloads,component failure, insulation breakdown, highresistance or loose connections, etc. could causea fire risk. Moreover, fires originating within theequipment should not spread beyond the immedi-ate vicinity of the source of fire, nor cause damageto the surroundings of the equipment.

Radiation hazardRadiation hazards may result from functional pro-visions in the equipment, or from secondary ef-fects resulting from equipment operation. Typesof radiation include sonic, radio frequency, infra-red, high-intensity visible and coherent light, ul-tra-violet, laser and other ionising or non-ionisingradiation, etc.

Chemical hazardChemical hazards may result from contact throughinhalation or other physical contact with sub-stances used in the operational process of theequipment, or from excessive temperature caus-ing vapours or fumes from materials or compo-nents used in the construction of the equipment.


lotion, and the protective clothing are personalsafeguards.

A safeguard is a protective device interposedbetween the hazardous situation and the body. Itis a personal safeguard because it is attached to thebody.

Individually, we make personal safeguards workby interposing them between us and the hazardoussituation.

We have discussed two means of safety, personalavoidance and personal safeguards.

Note the use of the word “personal.” Such safe-guards are effective only if we know when andhow to use them.

In most cases, someone will need to tell us whenone is needed, and sometimes how to use it. Forthe hot-pad, we probably learned from our par-ents. For the sunburn-preventing lotion, the in-structions on the label tell us these things.

Note that for both personal avoidance and per-sonal safeguards, safety is accomplished by inter-posing something, either distance or a device,between the hazardous situation and the body.

We said that a safeguard is a protective deviceinterposed between the hazardous situation andthe body. If we attach that safeguard to theequipment or product, we now have an equipmentsafeguard.

Note that an equipment safeguard works just as apersonal safeguard except that instead of beingattached to the body, it is attached to the equip-ment.

Technically SpeakingContinued From page 5

the moving car velocity. Again, we could predictthe distance through vector analysis.

If we are considering the Chernobyl incident, thenwe can consider high-altitude winds to predict thedirection and distance of wind-born fall-out.

If we consider the Edison-base light socket, thenthe distance can be very small, provided we don’tactually touch the metal conductors.

What does this have to do with product safety?

One way in which safety works is by personalavoidance. Individually, we make personal avoid-ance work by interposing sufficient distance be-tween us and the hazardous situation.

Now, let’s consider that we want to pick up the potof boiling water. To do so, we commonly use a“hot pad” or “mitt” or some thing between ourhand and the pot. This “thing” prevents the potfrom burning our hand.

Consider also that, in the summer, to avoid sun-burn, we anoint our body with a lotion whichprevents the hazardous sun rays from reaching theskin.

Or, at Chernobyl, the workers dress in protectiveclothing that prevents the nuclear energy fromreaching the body.

So, another way in which safety works is bypersonally interposing some device which attenu-ates or deflects the energy before it reaches thebody. For the purposes of this discussion, suchdevices, e.g., the hot pad, the sunburn-preventing


Safety is accomplished by interposing a safeguardbetween the hazardous situation and the body.

An equipment manufacturer cannot control safetyby means of personal avoidance or personal safe-guards. Therefore, his only avenue for makingsafe products is to provide equipment safeguardsfor every hazardous situation.

*****

Your comments on this article are welcome. Pleaseaddress your comments to the Product SafetyNewsletter, Attention Roger Volgstadt, c/o Tan-dem Computers Inc., 10300 N. Tantau Avenue,Location 55-53, Cupertino, California 95014-0708.

If you want to discuss this article with your col-leagues as well as with the author and editor, e-mail your comments to [email protected]. �

.......................................................................

For example, the equipment enclosure commonlyprovides protection against electric shock. It isinterposed between the hazardous situation andthe body. But, it is attached to the equipment.

There is a big difference between personal safe-guards and equipment safeguards.

A personal safeguard is only effective if the indi-vidual chooses to use it, and uses it in accordancewith instructions.

On the other hand, equipment safeguards are inde-pendent of the person using the equipment. Theonly caveat is that the safeguard must be suffi-ciently robust to withstand normal use of theequipment for the lifetime of the equipment.(Sometimes, the safeguard must be sufficientlyrobust to withstand abnormal use.)

A manufacturer controls equipment safeguards.He cannot control personal safeguards or evenpersonal avoidance.

However, every manufacturer at various timesdoes attempt to invoke personal avoidance andpersonal safeguards through the use of warnings.A warning is an instruction to either avoid asituation, or to employ a personal safeguard.Therefore, a manufacturer should understand thatuse of a warning is a poor substitute for an equip-ment safeguard.

CONCLUSION

I have described three models for protection againstinjury, personal avoidance, personal safeguard,and equipment safeguard.

Each is used every day by each one of us.

EmploymentWanted

Jeff Collins408 635 9161Hollister, CA


Northeast Area ChapterMarch: Meeting at EMC Corp., technical presenta-tions on telecom by Detecon and design of switchingpower supplies with pfc.April: Annual NPSS dinner, technical presentation

by CPSC.May: Meeting at EMC Corp., technical presenta-

tions by TUV Essen, TUV Product Servicesand TUV Reinland.

June: Meeting at EMC Corp., technical presenta-tion on PTC’s and risk assessment byWeinstein Associates.

For additional information contact:Dave Lorusso or Cliff StarkEMC Corp.171 South StreetHopkinton, MA 01748voice: 508-435-1000 x 7518fax:: 508-435-5067email: [email protected]

Pacific Northwest Area ChapterStill no activity in this area. Anyone interested isencouraged to contact:Scott Varnervoice: 360-817-5500 (ext. 55613)fax:: 360-817-6000e-mail: [email protected]

That is it for this month.

Best Regards,Kevin Ravo �

Area ActivitiesContinued From page 4

Thanks to Mr. Ewald Reichert of TUV ReinlandFEMAC for his excellent presentation on the newrequirements in Japan as they relate to the S-Mark

For additional information contact:Ewald ReichertTUV Rheinland FEMACvoice: 619-792-2770

March: Same location as usual. Additional programspeakers are needed for the rest of the year.

For information or comments, please contact:Charlie Bayhivoice: 714-367-0919

Chicago Area ChapterNo activity yet. Any one interested is encouraged tocontact: John Allenvoice: 708-238-0188

Colorado Area ChapterMarch: Possible Coors Field tourApril: No meeting/activityMay: Tour of Tesla in Colorado SpringsJune: No meeting/activity

For information, please contact:Richard Georgerianphone: 303-417-7537fax:: 303-417-7829e-mail: [email protected]


Chairman's MessageContinued From page 1

members represent professional societies, academia

and professional certification boards. The major

focus of this council is reincorporating core ESHprinciples in formal engineering curricula. In keep-

ing with this goal, a major Joint Council project

nearing completion is the publishing of formal guide-lines for engineering curricula. If successfully imple-

mented, the guidelines could significantly improve

the safety capabilities of engineers graduating in thebasic engineering disciplines.

Previous approaches to effective safety educationand integration have not been as effective as they

could have been. The most expedient solution to this

is coordination with other interested groups whichbring other perspectives and experience to the collec-

tive table. TC-8 and the Product Safety Working

Group, with our emphasis on safety in design amongother practices, has a lot to offer to these efforts and

we can greatly benefit from the perspectives and

experience of others.

We are investigating involvement with these organi-

zations, and I believe they offer great potential foradvancing both product and non-product EHS prac-

tice. I will keep you posted of progress in future

Newsletter editions. In the meantime, I would like tohear from you on the issues of improved engineering

education and partnering with other organizations.

Please contact me as indicated below.

Brian Claes

Chairman, TC-8

email: [email protected]

phone: (510)572-6574fax: (510)572-8260 �

Product Safety Coordination in EngineeringEducationOne of the most common generalizations I have

heard about product and system safety practice is thatengineers are provided little, if any, education on the

topic in either their undergraduate or graduate work.

The emphasis of the engineering curriculum is onbasic functionality. It is left up to resident safety

experts of their future employers to bring engineers

up to speed in safety, reliability, etc. Experiencesuggests this is both expensive and very wasteful.

There are several ways to address this situation. Onepath is to provide an improved focus for product

safety information for practicing engineers. This is

one of our aims in becoming a Product Safety Tech-nical Council. We will provide a function common to

all technical councils, transfer of information through

technical publications and symposia.

Another path is through alliances with other organi-

zations, both within and outside IEEE. One suchopportunity is our formal relationship with the IEEE

Environmental Health and Safety Committee, an

IEEE Technical Activities Board-level committee.We are helping EHS assess interest in a joint partner-

ship with the National Safety Council and its recently

formedInstitute for Safety Through Design (ISTD). The

ISTD focuses on improved occupational safety

through better design of workplace processes andequipment. One of its key initiatives is engineering

education. To further this, it is part of another

organization, the Joint Council for the Health, Safetyand Environmental Education of Professionals, whose


accessories and remanufactured product.

7. A formal product recall plan is prepared,tested and ready to implement if necessary.

The more mature product safety organizationsmight also include internal safety standards tosupplement industry standards. Many would par-ticipate directly, or sponsor individuals, in safetystandards development such as UL’s Industry Ad-visory Groups or IEC Technical Committees andWorking Groups. Some would have professionaldevelopment training in product safeness for prod-uct developers, quality assurance and safety engi-neers. Those with products having contractualobligations to comply with ISO 9000, will becomeinvolved in its installation and registration pro-cesses.

Establishing product safety objectivesProduct safety objectives should define the safetyattributes of a product. They should not be am-biguous, lengthily or legalistic, but simply andclearly state the level of safeness managementexpects to be reflected in the organization’s prod-ucts.

These objectives might be stated as follows:PRODUCT SAFETY POLICY AND OBJEC-TIVES

“All products shall be designed and manufacturedto comply with the following safeness attributes:

1. Products shall be safe for their intended use andforeseeable misuse associated with the manufac-ture, operation, servicing and end of life disposalof the product.

Execution of Safety FunctionsContinued From page 9

of the product.

Product safety check listBefore a mission statement for a product safetyfunction can be developed it is necessary to listactivities in which one would expect the functionto be engaged. The mission statement can thenincorporate those activities that are deemed nec-essary to produce reasonably safe products.

If an audit were made of a well structured productsafety organization, the auditor should readilyrecognize the following activities regardless ofthe organization’s size or structure.

1. Minimum levels of safeness are formally de-fined and incorporated into product designobjectives.

2. Products are fault tested for identification ofpossible latent safeness faults.

3. Products are certified to comply with recog-nized industry safety standards.

4. The safeness status of a product is reviewedby senior management prior to release intocommerce.

5. There is a mechanism to review engineeringchanges and supplier modifications to safetysensitive parts and materials.

6. Safety certification is maintained validthroughout the production life of the product,including all field upgrades, new features or


2. Examples of the product, representative of unitsto be marketed, shall be fault tested to detect latenthazards. Observed hazards will be corrected bydesign, component and material changes or provi-sion be made for appropriate warnings.

3. Products shall be certified to recognized indus-try safety standards. Evidence of compliance willbe authorization from a test and certification agencyto display its monogram or logo on the product”.

Some elaboration might be in order such as includ-ing the company, division or organization name inthe title. In item 3 it may be necessary to includeinternal company safety requirements if they alsomust be considered.

One might wish to include in the term “products”those units intended for internal use only such asdemonstration and training units. Also in thisgrouping are trade show units, marketing test unitsand those “not for sale” units consigned to dis-tributors or other situations in which the equip-ment may not always remain within themanufacturer’s strict control.

Translating objectives into require-ments.Once the overall objectives for the safeness of aproduct have been established it is necessary totransform the objectives into specific design re-quirements.

This task might be defined as follows:The Product Safety Manager (or individual re-sponsible for product safety matters) will identifythe industry safety standards appropriate to theproduct. Safety standards shall be identified for

each intended marketing area. Product design ob-jectives shall provide for compliance to the re-quirements of these standards”.

The standards referred to would almost certainlyinclude one or more from the following standardsgenerating groups:

a) Underwriters Laboratories (UL), componentand equipment standards.

b) Canadian Standards Association (CSA), com-ponent and equipment standards.

c) International Electrotechnical Commission(IEC), component and equipment standards.

d) Internal company standards and product safetydirectives.

e) Regional requirements in marketing areas withspecial safety requirements such as Japan,Nordic Countries, and others with “nationaldeviations” to safety standards.

f) American National Standards Institute (ANSI)for testing procedures referenced in UL stan-dards.

Additional elements might include internal com-pany safety standards or special situations of enduse. Another special requirement is ergonomics ifthe product is considered to be office work placeor work station equipment. Ergonomic standardsmay be required, particularly for European mar-kets and for ISO 9000 management systems. Awidely used ergonomic standard covering officeand computing equipment is the German standardZH 1/618, “Ergonomic Guidelines for Worksta-tions”. Various regional standards for video dis-


b) Costly redesign to obtain compliance can bereduced. In many cases, indications of safetydeficiencies or non-compliance can be foundearly enough in the product developmentcycle to be easily corrected.

c) Test agencies do not check each and everyitem in a standard during certification tests.This can result in a certification oversightthat surfaces later as a safety issue in thefield.

d) Valuable design feedback information is lost.Certification test reports contain little safe-ness correction information if test results arerecorded simply as pass or fail.

For these reasons it is essential to exercise theproduct to all certification requirements. Theonly exceptions being those items which are welldocumented from suppliers as certified, recog-nized or approved by agencies such as flammabil-ity ratings of materials or component approvals.

Designating required evaluation and testing ac-tivities for a product safety operating plan mightbe stated as follows:

Product representative of units to be marketedshall be evaluated to determine the safeness levelof the product and its ability to be certified by asafety testing or regulatory agency. These evalu-ations shall include:1. Intended use and foreseeable misuse or abuse.2. All operator functions, including replenish-

ment of consumables.3. All service and maintenance functions.4. Adequacy of instructions, warnings and manu-

als shipped with the product.5. Potential hazards and latent safety faults not

play devices may also apply.

Product evaluation and testing.The product safety function must have some meansof testing and evaluating products for safenessattributes and the ability to comply with certifica-tion requirements. It is not advisable to rely onengineering tests or worst case testing of a productfor this information. Engineering evaluations arealmost always performance oriented and do notadequately assess safeness attributes of a product.

The safety function need not have elaborate testfacilities. Some product safety testing can becombined with or utilize existing product devel-opment or component and materials engineeringevaluation equipment. However, some safenesstesting equipment is unique or specialized andwill be necessary for determining the ability of aproduct to comply with the requirements of safetystandards. Dielectric strength, fault current carry-ing capacity of earth ground circuits, ground cur-rent leakage testers, accessibility probes, creep-age and clearance measurement capabilities areexamples of evaluation tools and equipment notgenerally found in product development facilities.

It is not desirable to submit products to certifica-tion agencies without prior evaluation to compli-ance requirements. There are several reasons forthis:

a) Self certification programs offered by someagencies require extensive test documenta-tion. Without the ability to exercise a productto all the requirements of a safety standardthis very desirable means of product certifi-cation can not be utilized.


offs appear acceptable to the individuals makingthem. However, collectively they represent abody of product safeness uncertainties to seniormanagement and those with a more comprehen-sive view of safeness risks the business can or cannot accept. It is clear that there must be a formalprocess for determining the acceptability of re-sidual safety risks. The most efficient procedure isa review of the safeness level of the product by areview team, chaired by a member of senior man-agement. The chairperson of the team must reportto a level of management having the authority torequire corrective actions or to accept the safenessrisks on behalf of the business.

The process of reviewing the safeness level of aproduct before initial release into commerce mightbe defined in the Product Safety Policy and Objec-tives statement such as:

Prior to manufacture or distribution of a product areview of its safeness level shall be conducted bya product safeness review group to determine theacceptability of residual risks associated with:1. Deviations from original design objectives.2. Results of fault testing.3. Certification status, particularly marginal lev-

els of compliance.4. Adequacy of warnings and instructions for the

installation, operation and servicing of theproduct.

5. Adequacy of plans for certification mainte-nance throughout the production life of theproduct.

6. Adequacy of procedures for handling safetyrelated field incidents and product recall.

Other issues might also be included such as com-pliance to internal safety standards or safety direc-tives and manufacturing safety requirements is-

likely to be detected by routine manufacturingtests or quality assurance activities”.

Additional elements might include designation ofthe organization responsible for making the evalu-ations. In items 2, 3 and 4 it might be well to listall instructions and manuals supplied with theproduct, including installation instructions, set-up and powering-on, permissible adjustments byoperators, and the general care and housekeepingchores associated with the equipment.

Product safeness reviews.In almost every product development effort thereis some short fall of the design objectives. Someresult from design trade-offs as various engineer-ing problems surface. Others occur due to revi-sions of performance specifications, revised oper-ating characteristics, or as materials and compo-nent changes are introduced during the productdevelopment cycle.

Similarly, there can be short falls in the safenessobjectives for a product. Revision of designobjectives and design trade-offs during the prod-uct development cycle often change the safenesslevel of the final product. It often occurs that faulttesting uncovers hazards not considered in theinitial design objectives or detected during designand development activities.

In addition, product safety certification may bemarginal with one or more parameters barelysatisfying the requirements. Such marginal safetyparameters can swing the product in an out ofcertification compliance due to normal manufac-turing variability and fluctuations in materials andcomponents from suppliers.

Taken one at a time, these compromises and trade-


in one brief, clear, unambiguous document. Amodel of such a document is shown in AppendixA. It may well be all that is necessary to define therole of product safety in an enterprise regardless ofsize, structure or product marketing regions.

Portions of this section on a Policy and PracticesStatement used here and in Appendix A are fromthe seminar material “Managing Product Safety”,by P.W. Hill, 1987 as developed for EMACO, Inc.and is used here with permission.

The next section considers organizing the productsafety effort. �

sued by OSHA and EPA. Under item 6, a specificplan or process for satisfying the safety incidentreporting requirements of the Consumer ProductSafety Commission (CPSC) is advisable, whichwill be discussed later. For the impact OSHA, EPAand the CPSC may have on product safety matterssee the section, "Regulatory Agencies Which Influ-ence Product Design".

Assigning product safety responsibilities.It is essential that one individual member of man-agement be given responsibility for the safeness ofproducts. To regulatory agencies, litigating partiesor consumer groups it must not appear that there isan apparent diffusion of product safeness responsi-bility. Nor should there be the appearance that onearea such as marketing, engineering or manufactur-ing dominates product safeness considerations.

Good management practice would dictate that re-sponsibility for product safeness not be lower in theorganization than the point at which all productsafeness influencing inputs come together. Fromthis position in the organization an integrated andbalanced picture of the safeness of a product can bemade independently from single contributors whoseinterests may be parochial in nature.

The policy and practices statement might assignresponsibility and authority as follows:AUTHORITY AND RESPONSIBILITYAuthority to establish product safety requirements,determine the acceptability of residual risks, over-seeing the implementation of this Policy and Prac-tices Statement, and the delegation of responsibili-ties for various aspects of product safeness is as-signed to (list senior management name and title)”.

Model Policy and Practices Statement.All of the items in this section can be summarized

In the Jan-Mar edition of the Product

Safe ty Newsle t ter , we c i ted TUV

Rheinland World News as our source forthe summaries "Update on the CE mark-

ing and Electrical Components" (page

17) and "What is an SIC Code..." (page18).

The publisher of this newsletter requestedthat we note that TUV Rheinland World

News is a publication of TUV Rheinland

of North America, Inc. For informationabout copies of this publication or about

TUV Rheinland of North America, please

contact Valierie Mosher at 203-426-0888, ext. 123.

The Editor apologizes for any misunder-standing.


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