Study of the effect on Industry of complying with the Electromagnetic Compatibility Directive.

The DTI recently commissioned a study of the effect that the EMC Directive has had on industry and this study was present to a selected audience at a briefing meeting held at the DTI on 1st October 1997.

The study was carried out between October 1996 and February 1997 by an independent EMC consultant, Brian Jones, on their behalf. It has come up with a list of 39 recommendations to improve the present situation, which to many people is still very confused.

The study was aimed particularly at the small to medium size companies but also took into account the views of larger companies and Trade Associations.

The survey of small businesses of less than 100 people was done from a random selection of 130 companies from the Dun and Bradstreet Trade Directories. 62 companies actually took part of which 44 considered themselves to be covered by the Directive. Interestingly a number of companies appeared not to want to be involved and there is no doubt that some sections of the industry are "keeping their heads below the parapet" particularly when it comes to seeking advice from the local Trading Standards Officers.

The survey of larger businesses was to some extent self-selecting with those having strong views being more vociferous than those who are content with the situation. Larger businesses have been able to cope more readily with the EMC Directive since they have the infrastructures, systems and manpower to carry out the necessary testing and control.

Of the 51 trade associations contacted only a half replied and these usually set up contacts with their own members.

The views of the Trading Standards Officers were sought through a selection of 18 Departments across the country plus an overview from LACOTS their co-ordinating body. This is only one of many Directives that the TSO's have to police and most are doing it on a reactive rather than a pro-active basis. It is also clear that many of the TSO's do not have the required expertise and there is no money or time available to train them. This is being aggravated by the recent changes in the local authority structure.

DTI Need your feedback If you have any constructive comments to make on the following list of recommedations please fax or post to David Southerland at the DTI ensuring they arrive before the 1st December 1997. Send to: David Southerland, Standards & Technical Regulations Directorate, DTI, 151 Buckingham Palace Road, London SW1W 9SS. Fax to: 0171 215 1529

One finding that came through loud and clear is that the standards committees are regarded as being unrepresentative and dominated by vested interests such as test equipment manufacturers, large manufacturers and supply utilities. The other finding that is causing concern is the lack of stability in the standards with new and updated standards having insufficient overlap period to allow for redesign and re-tooling.

The DTI intend to present this study to the EU (Department DGIII) in parallel with the above UK consultation process but will not complete it until the UK process is complete. They will be urging for a simplification of the EMC Directive since it is clearly having some negative impact particularly for small companies who cannot absorb the testing and equipment costs and regard this as just another of their many bureaucratic burdens.

List of Recommendations

The immunity requirements of the Directive

1. No change should be made to the immunity requirements of the Directive. If products are deemed

to be compliant without testing, this should be covered in a product family standard.

2. Exemption of products by other criteria should be clearly stated in Commission Guidelines,

together with the rationale, and the means of defining the envelope of the range of products

exempted.

The repeatability of EMC testing

3. Further studies on the repeatability of EMC testing are required. The United Kingdom

Accreditation Service (UKAS) surveys should be extended to include the effect of cabling, and the

additional uncertainties where the Equipment Under Test (EUT) consists of more than one box.

Consideration should be given of how the repeatability of immunity testing can be assessed.

4. The CISPR "80/80 Rule" is probably too entrenched for consideration of its removal from the

emissions standards, but industry must be made aware of its true purpose. The issue of whether or

not to test more than one sample should be addressed more clearly in the Commission Guidelines.

DTI advice to SMEs on minimising the cost of compliance

5. The "Minimising the cost..." guidance is basically considered to be sound, but should be amended

to include greater emphasis on due diligence and the need to keep records. The types of records to

be kept should be described in general terms.

6. The resulting document should be promulgated more widely than the first edition.

7. Further guidance for those involved in procurement, and for installers, would be helpful.

Use of apparatus in certain environments

8. Create two new generic standards for emission and immunity in the domestic environment, by

splitting these away from the commercial and light industry generic standards.

9. Improve the clarity of the definition of the light industry and industrial environments, and

remove references to the nature of the power supply as a differentiator.

Should all sectors be in the scope?

10. The boundaries between the EMC Directive and specific vertical directives, in particular the

Medical Devices Directive, should be defined clearly, possibly in an addendum to the Commission

Guidelines.

11. There should be no more vertical directives containing EMC within their scope.

EMC Standards

12. It is necessary to have checks at various stages in the standards process, from agreement for new

standardisation work, through to production and authorisation, to ensure that the standard is

necessary, and meets the protection objectives of the EMC Directive.

13. The Commission should review CENELEC's standardisation mandate to include checks and balances as

to whether standards are needed. A process for cost/benefit analysis should be developed.

14. A formal route for identifying standards which are too onerous should be created, to balance the

process for identifying shortcomings laid down in the Directive.

15. A way should be found to increase the representation of small manufacturers, and users, on

standards committees, particularly at international level.

16. A feed back mechanism should be created to enable some analysis of the number and type of EMC

problems to be recorded, and trends observed.

17. International standards working groups should be disbanded once their specific work has been

completed. This would prevent such groups looking for other work to prolong their existence.

18. The adoption of parallel voting for international (voluntary) and European Norm (regulatory)

standards can cause problems. The standards should define only technical requirements for testing.

Statements of an administrative nature should be removed from the European versions.

19. BSI should make Committee Drafts available for information to the public on the same commercial

basis as drafts for public comment.

20. A list of standards and amendments published in the Official Journal of the European Communities,

should be available from an official source, without the need to subscribe to OJEC.

Status of the latest guidance form the Commission

21. The EMC Directive should be revised by an amending directive to bring it into line with the

Commission's latest thinking, as described in the new Guidelines. The UK Regulations should then be

amended to align.

22. The existence and content of the Guidelines should be promulgated widely.

23. The Think Tank should be made more representative of the stakeholders. It is important that is

seen to be representative, objective, knowledgeable, and impartial.

Prototypes and one-offs

24. For one-offs, consider the product as being taken into service, so that no assessment or CE Mark

or Declaration of Conformity is required, but unlike the situation where supply has not taken place,

the responsibility for complying with the protection objectives would remain with the manufacturer.

25. Modular computers should not be considered as one-offs but as a number of product variants where

a worse case is identified, and this is used as the apparatus for assessment. The Declaration of

Conformity would cover this and sub-equipped variants.

Building cabling

26. Clearer guidance on system integrators' responsibilities, from an official source, is required.

CE Marking of products which are not relevant apparatus

27. There should be a clear decision, promulgated throughout the EEA, that products outside the scope

of any directive requiring a CE Mark should not carry it. A suitable way for this to be done is by

amendment to the CE Marking Directive.

28. Customers should be encouraged to seek CE Marks only when relevant, and to demand supporting

evidence in the form of a Declaration of Conformity and test reports.

Test methods for modules and components performing a direct function.

29. The approach taken by the FCC in the USA should be considered for guidance within the EEA.

Routes to compliance

30. Some additional guidance on requirements for TCFs should be produced. This should include the

possible use of information available on products already in service without problems.

Enforcement

31. Clarity on the responsibilities of Trading Standards and Health & Safety Executive on the

enforcement of EMC issues in the workplace is required.

32. The definition of "supply" should be examined in the UK Regulations, since it may prohibit

Trading Standards Officers from suspending supply in the UK of a product first placed on the market

in another EEA Member State.

33. The DTI should involve the enforcement bodies in the negotiations of any changes to the Directive

or the UK Regulations, and in the Administrative Co-operation meetings.

34. Trading Standards representatives should be invited to participate in the BSI EMC Committees.

35. Clarification of the roles of the CAA, the Radiocommunications Agency, and Trading Standards

should be made in respect of EMC requirements on commercial aircraft of all types.

36. The roles of Trading Standards and the Health & Safety Executive in respect of industrial

products should be clarified.

37. The position with respect to direct imports should be clarified.

38. Trading Standards Officers should be provided with additional training on the technical aspects

of EMC, and a way should be found to reduce the burden of the costs of enforcement. Block booking of

laboratory time by several authorities could result in savings.

39. Trading Standards Authorities should be provided with copies of the Commission Guidelines when

they are published.