I am sure some of you sometimes build electronics and give them away to others (maybe for money, maybe not).
I am also sure that most of you would care about electrical safety of those devices.
But I am even more sure that you don't go all the way and have every single and custom-made electronic device fully certified for safety, just to make sure that there are no (or limited) liabilities in case something goes wrong with the stuff you built (fire, electrical shock, etc.).
To be honest, I don't know how this "certification / liability" thing really works, but I imagine this costs a lot of money and time and is not viable for single and custom-made builds.
Here are a few questions that come to mind with respect to liability and implementing safety regulations in single and custom-made electronics (please add other questions if you think it's useful):
What are your thoughts and approaches to deal with this?
P.S.: here are some links to useful information on how to make your stuff safe (but not much on dealing with authorities, regulations and liabilities):
I am also sure that most of you would care about electrical safety of those devices.
But I am even more sure that you don't go all the way and have every single and custom-made electronic device fully certified for safety, just to make sure that there are no (or limited) liabilities in case something goes wrong with the stuff you built (fire, electrical shock, etc.).
To be honest, I don't know how this "certification / liability" thing really works, but I imagine this costs a lot of money and time and is not viable for single and custom-made builds.
Here are a few questions that come to mind with respect to liability and implementing safety regulations in single and custom-made electronics (please add other questions if you think it's useful):
- What are practical ways to deal with "safety compliance"?
- Does it make a difference if we build stuff for our own use or for someone else?
- Does it make a difference if we just hook up some wires between some pre-built "safety compliant" modules / PCBs or if we build a potent high-voltage tube amp using single parts from scratch?
- Does it make a difference to use a "safety approved" wall wart as an external low-voltage power supply instead of an on-board power supply running from mains AC voltage?
- I've heard of "CE self declaration", but don't understand what this is and how it's useful. How does this work? Does it help to limit any liabilities?
What are your thoughts and approaches to deal with this?
P.S.: here are some links to useful information on how to make your stuff safe (but not much on dealing with authorities, regulations and liabilities):
Most CE is self-declared. This means that you have read and understood all the EU requirements (mostly Low Voltage Directive and EMC Directive for audio equipment) and can confidently state that your equipment meets them. This can be either by design, or your own testing or some combination.
Two alternatives:
1. pay someone else to do it for you
2. just put a CE sticker on the back - everyone knows that CE just means "China Export"
The best way to achieve safety compliance is to ensure that the item is safe under all likely conditions, then write it all down to show that you have done this.
Two alternatives:
1. pay someone else to do it for you
2. just put a CE sticker on the back - everyone knows that CE just means "China Export"
The best way to achieve safety compliance is to ensure that the item is safe under all likely conditions, then write it all down to show that you have done this.
I would look at creepage and clearance and SELV, also regulations regarding fire safety (UL).
EN-60950 etc. look up the various specifications its up to you to make yourself aware of the regulations and requirements, this is part of the design process.
Basically if you build something and it causes an accident or death by any means you are liable.
EMC testing is problematic for home designs how do you test, again though if you break the EMC rules you are again liable. Here the EMC club is a good source of information regarding testing and design.
I spend many a happy hour pondering and discussing safety aspects of designs... Its hard enough in the professional world never mind DIY, so always err on the side of safety.
EN-60950 etc. look up the various specifications its up to you to make yourself aware of the regulations and requirements, this is part of the design process.
Basically if you build something and it causes an accident or death by any means you are liable.
EMC testing is problematic for home designs how do you test, again though if you break the EMC rules you are again liable. Here the EMC club is a good source of information regarding testing and design.
I spend many a happy hour pondering and discussing safety aspects of designs... Its hard enough in the professional world never mind DIY, so always err on the side of safety.
this is what you want to avoid under all cost$, otherwise break out your checkbook and start listing all the organizations in the countries where the device lives as a starting point.
best practice is to make sure all components used in non SELV have their own safety markings esp. if you want easy jump start towards any future safety approval process. Yes using wall warts takes a lot of liability away from DIY. I personally look for connectors switches and transformers designed towards use for Class II (double insulated). I reckon if you apply warning labels on the covers, and make sure the recipients sign a waiver, might be another way to CYA. as always check with a qualified lawyer.
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Where / how can I get hold of the relevant directives or regulations (or whatever they're called)?
standards organization charge thru the nose for them - clearly a profit center
its expected that a company dedicating engineering time to reading them won't balk at $k for the docs
but there are review/discussions on the web and books to help that get you most of the info without buying from the standards organizations
its expected that a company dedicating engineering time to reading them won't balk at $k for the docs
but there are review/discussions on the web and books to help that get you most of the info without buying from the standards organizations
This is worth repeating.
The only out I can envisage is if the receiver of those goods acted incredibly negligently (was so taken by that tube amp that they had to have it within arm's reach as they got drunk in the hot tub). But if the slip&fall lawyer can show you had an inkling of knowledge that they might do something stupid like that...
Of course the topic varies place to place.
For true diy I use common sense safety practices and the rest be damned.
WWW.CREEPAGE.COM Welcome!
Put up more details and I will help where I can with some advice, just spent 4 weeks doing another big supply board with SELV areas (12 layers🙂)...
On tip I will give, when you have HV (high voltage) and a SELV area (usually the control electronics) I always ensue there is a visible gap through ALL layers of the PCB, you can then see the low voltage area is isolated and safe, simple and effective...
Add this to your silk screen...
http://www.safetysign.com/products/p2839/high-voltage-iso-label
Do not add any text... more for commercial but the reason this is often seen with no text is that it is almost universally understood, if you add High Voltage in text you have to add it for every country where your product may be sold or used to avoid any misunderstanding... Doing products for a global market can be ... fun
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When marketing into EU, we found audio products are generally regulated by EMC and LV directives (as mentioned previously) and also RoHS, ie, No Lead. This is getting pretty easy to comply with in Europe because you have practically eradicated the stuff. In the US, (lead-based solder is still common.) Compliance consists of carefully checking that EVERYTHING that goes into your product is, in turn, RoHS certified by the vendor.
EMC had us stumped. The essence of the directive is "Your gear can't emit EMF that interferes with anything else's ability to function, and cannot be vulnerable to malfunction in the presence of EMF". But how to test? What are they looking for, exactly? Can I do this at home? Unwilling to buy an expensive Standard, we were stumped until we found this:
EN 55032:2012
This document discloses what the Standard is looking for. My electrical engineer looked it over and said, "Well, we don't have half of these features, and the ones that are present in our product function in a frequency range orders of magnitude outside these limits." On the basis of that statement, I confidently self-certify my products EMC-compliant.
For LV, we found someone else's published compliance report for a product similar to ours. The testing was based on compliance with IEC/IEEE standards. Again, it showed us that our usual design practices and engineering judgement were well within standard practice.
I would not take the CE sticker too lightly. This is a simple and effective chain-of-liability that leads directly to yourself. The person who actually applies the sticker (or directs it to be applied by others) is personally responsible for the compliance fo the product.
The legal options vary widely around the world, but in the US, we organized as a LLC (limited liabiliy corporation). My design firm has few assets, and our liabilities are contained, isolated from personal or other business assets. If I hurt someone and there is a suit, I have nothing to lose but the entire business, which frankly is not much. My home and other businesses are safe.
The gist of CE compliance is that the product must not knowingly present a hazard to the purchaser or anyone else likely to encounter it, including children And Pets! So, for example, if I design an amp with exposed tubes (to serve as romantic lighting?) and put a little "don't touch" label, this will not be considered compliant with LV safety standards, because your babies and cats can still burn themselves: the hot thing has to be protected in a cabinet or chassis or behind a screen.
I found a fantastic article on principles of safety labeling as it applies in the US. If I can find the link, I'll share it.
EMC had us stumped. The essence of the directive is "Your gear can't emit EMF that interferes with anything else's ability to function, and cannot be vulnerable to malfunction in the presence of EMF". But how to test? What are they looking for, exactly? Can I do this at home? Unwilling to buy an expensive Standard, we were stumped until we found this:
EN 55032:2012
This document discloses what the Standard is looking for. My electrical engineer looked it over and said, "Well, we don't have half of these features, and the ones that are present in our product function in a frequency range orders of magnitude outside these limits." On the basis of that statement, I confidently self-certify my products EMC-compliant.
For LV, we found someone else's published compliance report for a product similar to ours. The testing was based on compliance with IEC/IEEE standards. Again, it showed us that our usual design practices and engineering judgement were well within standard practice.
I would not take the CE sticker too lightly. This is a simple and effective chain-of-liability that leads directly to yourself. The person who actually applies the sticker (or directs it to be applied by others) is personally responsible for the compliance fo the product.
The legal options vary widely around the world, but in the US, we organized as a LLC (limited liabiliy corporation). My design firm has few assets, and our liabilities are contained, isolated from personal or other business assets. If I hurt someone and there is a suit, I have nothing to lose but the entire business, which frankly is not much. My home and other businesses are safe.
The gist of CE compliance is that the product must not knowingly present a hazard to the purchaser or anyone else likely to encounter it, including children And Pets! So, for example, if I design an amp with exposed tubes (to serve as romantic lighting?) and put a little "don't touch" label, this will not be considered compliant with LV safety standards, because your babies and cats can still burn themselves: the hot thing has to be protected in a cabinet or chassis or behind a screen.
I found a fantastic article on principles of safety labeling as it applies in the US. If I can find the link, I'll share it.
Basically,
You have to make the device idiot proof!
If little fred or suzi circumvent you protection and IP rating your liable.
Here is one for you..I know of an example where a child put a kettle lead in their mouth with the other end plugged in and powered up..where do you draw the line?
Any access to internals must be with the use of a tool.
I cant really see how you can have any exposed tubes, any components must be ROHS compliant and fire resistant under fault conditions. The equipment must be self protecting with automatic disconnection of supply and always fail in a safe manor. (Where no exposed metalwork or anything connected to the device must not become live or create a dangerous difference in potential).
That's without getting into different countries regulations.
Its a mares nest..
You don't have to think far to include liability of repairing old kit. If it becomes usable what regulations apply?
Saying you know this is a bit dangerous because it doesn't have a mains transformer or its got no bottom plate is not a get out!
Regards
M. Gregg
You have to make the device idiot proof!
If little fred or suzi circumvent you protection and IP rating your liable.
Here is one for you..I know of an example where a child put a kettle lead in their mouth with the other end plugged in and powered up..where do you draw the line?
Any access to internals must be with the use of a tool.
I cant really see how you can have any exposed tubes, any components must be ROHS compliant and fire resistant under fault conditions. The equipment must be self protecting with automatic disconnection of supply and always fail in a safe manor. (Where no exposed metalwork or anything connected to the device must not become live or create a dangerous difference in potential).
That's without getting into different countries regulations.
Its a mares nest..
You don't have to think far to include liability of repairing old kit. If it becomes usable what regulations apply?
Saying you know this is a bit dangerous because it doesn't have a mains transformer or its got no bottom plate is not a get out!
Regards
M. Gregg
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Short answer is that:
1) you must do your best to comply with regulations, it's common sense anyway.
2) you can not certify yourself, not a friendly Engineer, no matter what his Lab is equipped with, unless he's officially certified to do so.
That reduces competition immensely, so they basically can charge what they want ... and they do.
It is real *expensive* , I have been asked U$3000 for a single model/product (in this case Fahey 100W Bass amplifier model 4409) or what I preferred, U$6000 for a so called "class" certification, which covers variations on roughly the same product (such as Guitar/Bass/Keyboards/PA/Power Amp Fahey 100W ) which all share the same power supply and basic chassis.
Piece of cake for a large manufacturer (think Fender/Marshall/Sony/Yamaha) but a huge block for small manufacturers, I'd say impassable for Boutique builders.
In general (what I finally did) it's best to deal with an established local Importer in the Country where you want to sell (or within the EU) and let him handle certifications, they will already have staff and contacts to do so smoothly.
Of course, in a way you are tied to them so if you are not happy and want to terminate the deal but not shoot yourself in the foot, you have to find another suitable Importer/Distributor first.
As a side note: that's why a lot of stuff which could come with an internal supply , say answering phones, printers and even some Guitar Amps (think Orange MicroTerror and similar) , come with an external power brick instead.
Reason is that the product itself need not be certified every time, but can take any generic certified power pack , which avoids the main problem.
This is about Electrical Safety certification, but the problem is very similar for Lead Free certification, I guess somebody must inspect and approve the finished product.
1) you must do your best to comply with regulations, it's common sense anyway.
2) you can not certify yourself, not a friendly Engineer, no matter what his Lab is equipped with, unless he's officially certified to do so.
That reduces competition immensely, so they basically can charge what they want ... and they do.
It is real *expensive* , I have been asked U$3000 for a single model/product (in this case Fahey 100W Bass amplifier model 4409) or what I preferred, U$6000 for a so called "class" certification, which covers variations on roughly the same product (such as Guitar/Bass/Keyboards/PA/Power Amp Fahey 100W ) which all share the same power supply and basic chassis.
Piece of cake for a large manufacturer (think Fender/Marshall/Sony/Yamaha) but a huge block for small manufacturers, I'd say impassable for Boutique builders.
In general (what I finally did) it's best to deal with an established local Importer in the Country where you want to sell (or within the EU) and let him handle certifications, they will already have staff and contacts to do so smoothly.
Of course, in a way you are tied to them so if you are not happy and want to terminate the deal but not shoot yourself in the foot, you have to find another suitable Importer/Distributor first.
As a side note: that's why a lot of stuff which could come with an internal supply , say answering phones, printers and even some Guitar Amps (think Orange MicroTerror and similar) , come with an external power brick instead.
Reason is that the product itself need not be certified every time, but can take any generic certified power pack , which avoids the main problem.
This is about Electrical Safety certification, but the problem is very similar for Lead Free certification, I guess somebody must inspect and approve the finished product.
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The thing to remember with all this is,
even the big players get it wrong and end up with huge law suites.
So certification doesn't mean your safe! it just means you can sell in markets that comply.
When something goes wrong..its down to the designer, they have to prove any component failure was due to a manufacturers error and everything was used within its capability. If its a design fault your liable. The only get out is the appliance was misused or abused which caused the protection to fail.
Regards
M. Gregg
even the big players get it wrong and end up with huge law suites.
So certification doesn't mean your safe! it just means you can sell in markets that comply.
When something goes wrong..its down to the designer, they have to prove any component failure was due to a manufacturers error and everything was used within its capability. If its a design fault your liable. The only get out is the appliance was misused or abused which caused the protection to fail.
Regards
M. Gregg
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The next thing is,
If you modify the product does it still comply?
Or do you need to re-certify?
How do you stand if you use non certified or cheap parts?
Regards
M. Gregg
If you modify the product does it still comply?
Or do you need to re-certify?
How do you stand if you use non certified or cheap parts?
Regards
M. Gregg
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Exactly this is the most falsified issue of CE. The "China Export" CE sticker is a fraud and differs very little from the original CE label which does have another meaning.
Please check differences here:
https://en.wikipedia.org/wiki/CE_marking
BTW "Everyone knows this"
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😕 Ref..BTW everyone already knows this..
Interesting..
Warning, don’t get confused between the CE Mark and the China Export Mark - News Archive : Icom UK - two way radio transceivers, receivers and navigation products
Regards
M. Gregg
Interesting..
Warning, don’t get confused between the CE Mark and the China Export Mark - News Archive : Icom UK - two way radio transceivers, receivers and navigation products
Regards
M. Gregg
If the CE mark is accompanied by the 4 digit identification number of the notified body this indicates that the product was actually tested to the relevant standards, this is particularly true for medical devices having just been through that process recently.
If self certified (safe bet if no ID #) you are relying on good ethics on the part of the designer and maker of the product which is not always a safe bet. Such devices if complaints are received may be subject to testing and if they fail to meet the requirements problems may ensue.
(FWIW I have had a cheap eBay CE marked wall wart actually melt so caveat emptor)
If self certified (safe bet if no ID #) you are relying on good ethics on the part of the designer and maker of the product which is not always a safe bet. Such devices if complaints are received may be subject to testing and if they fail to meet the requirements problems may ensue.
(FWIW I have had a cheap eBay CE marked wall wart actually melt so caveat emptor)
I question,
mains transformer compliance. I find it hard to believe some temperatures these are "Supposed to work at" even from the design specs.
Ie its that hot you can hardly touch it but is within design spec..
Regards
M. Gregg
mains transformer compliance. I find it hard to believe some temperatures these are "Supposed to work at" even from the design specs.
Ie its that hot you can hardly touch it but is within design spec..
Regards
M. Gregg
CE is Euro and is based on a pile of obtusely written IEC standards from some institution based in Geneva last time I checked. 😉 Well it is a bit more complicated, as all notified bodies like BSA and VDE can publish their own documents closely aligned to the IEC standards - some however don't and just reference the IEC standard.
The CE mark is not accepted here, we have UL or CSA either are acceptable here in the US.
It is a minefield for the unwary, OTOH we no longer deliberately use things like death caps and live chassis so some progress appears to have been made.
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