Safety Regulation Testing

[guitarmike2107]

I just had my bubble burst this morning a bit.. need some help inflating it again.

I want to build some amps to sell to friends and local bands, but I also want to do it the right way, i.e. try to be legally sound in case an amp causes a fire and "burns down the house".. mmm sounds like a song coming on

The primary question is has anybody here used an external testing house for CE type compliance testing.. if so Please recommend.
....
The implications of the safety regs has been skirted around here a few times, from the internet searches I have done I figure any amp build should comply with EN60065 or UL60065 in the states, so I contacted a local testing firm and just about fell off my seat when they quoted £1080 per day to do the tests and provide certification.

From what I gather (meaning I still need to buy the regs and read them) I could self certify to these directives if I put the technical report together as appropriate, but the firm I contacted also said the product has to meet some parts of EMC (Electromagnetic Compatibility) regs EN55103-1 and EN55103-2.

Anybody got any thoughts on the EMC thing? None of the other firms I have contacted have mentioned it.

Cheers

Mike

[guitarmike2107]

Just did some more mind numbing reading

It would appear the compliance to the Low Voltage directive can be self certified, but the testing to EN55103-1 and EN55103-2 has to be done by a third party.

Marshall’s new handbooks state that this has been done on their amps.

Man! it costs allot to manufacture a product to these standards, no wonder manufacturing is dying a slow gruesome death in the UK

[zaphod_phil]

Do a search on posts from nigelb. He's based on Wales, and he got his amplifiers tested for safety compliance, etc. I recall him talking about that in some threads. Maybe stevesuk might have some advice as well, if he sees this thread...

[csbradley]

Well, I do that for a living. I came from the audio world (Shure, RCA, Klipsch) and was in charge of compliance, and I am now working at an EMC test lab. So ask away on any specific EMC or Safety questions.

For all of this, what you really need to place the product on the market is a DoC (Declaration of Conformity). This will state the products compliance, and must be made available to authorities as requested. No third party test reports are really required (for safety or EMC), but the product is required to meet the requirements specified in the harmonized test standards (and you should be able to proove this.) If you know the standard, you can put together your own "technical construction file" to show compliance.

If you were to go to a third party lab, the costs are going to be very high for all of the testing; IEC60065 with UL (USA) and EN (Europe) deviations, EN55103-1 (emissions), and EN55103-2(immunity), so that is not really a viable option unless you are going into business and have $20,000 to drop. Test labs in China are the lowest cost, and sometimes much faster than labs in Europe or US/CAN. (I would recommend TUV in Shanghai.)I've used TUV, CSA, UL, ETL, and various China/Taiwan/Hong Kong labs. None are cheap. The last subwoofer I certified cost about $19,000 for safety and EMC testing, and this was all performed in China.

There will be alot of document chasing on your part. You will need UL/CSA/VDE/TUV type documentation for all transformers, large caps, any "safety critical" components, etc...

Lets not even get into WEEE, RoHS, Packaging Directive, EUP Directive, etc... for Europe. Not really a small business friendly environment.

A good link to start with (www.newapproach.org).

CSB

[Alexo]

Good lord.

At what point does one need to get this level of certification/"conformity?"

Is there any quantity (or territory range) below which the above does not apply?

I can't imagine the above is necessary for custom, one-off amps, but what if you make a run of a dozen amps? Or sell maybe 200 amps per year? Where does one draw the line?

Thanks for chiming in, CS. I always wondered about that Klipsch avatar of yours - btw, I loooove my Heresy II's!

[guitarmike2107]

Good lord.

At what point does one need to get this level of certification/"conformity?"

Is there any quantity (or territory range) below which the above does not apply?

I can't imagine the above is necessary for custom, one-off amps, but what if you make a run of a dozen amps? Or sell maybe 200 amps per year? Where does one draw the line?

I am not sure you really want to be asking those questions.

The products I work with in my day job have to conform to the machinery directive, we supply “custom” heavy lifting machines and each new design has to be “type” tested to ensure it conforms to relevant standards. For the mass produced stuff we have to test to ensure continued conformity too.

From what I have read the Low Voltage directive is no different, i.e. it does not differentiate between custom 1 off’s or mass produced, at the end of the day the manufacturer is liable for safe design and negligence is not an excuse.. it’s a crime.

So I would say if you are building amps for sale they should have a Declaration of Conformity with them. But I am not sure if this is the same for the States, I suspect it is.

The question whether building an amp for friend bobby down the road should be CE/UL tested … I don’t know, but I suspect that if the amp caused bobby’s house to be burnt down and it caused his neighbours house to burn down and in the process killed the pet gold fish you could end up with a lawsuit on your hands at which point you would need to prove the amp was designed and built to acceptable standards.

You could brush this all aside and say that we are building amp based on a well proven design etc etc .. but Marshall had to fit the cage, if you sold a new amp with out a cage and bobby’s dog accidentally sniffed a hot tube and burnt his nose.. Again you could be held responsible.

It’s a crazy world we live in … and I do love pets btw

[WesKuhnley]

PFFT!

Don't bother testing with a third party. Build bullet-proof products, and if you're small enough, do cash-only sales. Don't put your personal name on the amp and voila! you're good to go. Legally untraceable. Eventually, if everything goes well, you'll have to go legit and bite the bullet, but jump through the extra hoops now?

I am debating even doing business in the EU, or even internationally, due to the INSANE regulations for products like these. The US is bad enough without having to build in a EU dealer discount to offset some shipping cost and keep the product competitive.

Sooner or later, after China, India, and the rest of SE Asia are FINALLY industrialized and unionized, manufacturing will come back to the US and western Europe. It CAN'T be cheaper to build in Asia if labor costs the same.

Manufacturing groups and unions should be supporting a movement in China, if they want to keep their jobs here.

Sorry, got a little sidetracked...manufacturing is such a hot button topic for me.

[csbradley]

The simple summary (for the LVD and EMC directive in Europe) is:

LVD) The product must be safe.
EMC) The product cannot interfere with other products, and other products cannot interfere with it.

That's it.

Now it gets to how can you prove it is safe and interference with other products is not an issue. That is where you apply the harmonized standards (EN60065 and EN55103-1/2). If you apply the harmonized standards it gives you the "presumption of conformity" to the Low Voltage and EMC Directive. You are still liable for anything you place on the market.

Since Europe does not require "certification" or registration of these products (it only requires compliance), there is no minimum quantity that enacts these requirements. All products must comply.

[EDIT] Oh Yea, and Europe also wants someone, with residence in Europe, to sign the DOC's. This way, if there is an issue, they have someone under their jurisdiction that they can hold responsible.


CSB

[katopan]

Same bad news in Australia. Audio electronic gear isn't on the prescribed list and so doesn't have to be tested by the regulating authority. But EVERY piece of anything has to comply to minimum safety and EMC standards. Big leap between hobby for yourself and selling to others, even as a one off. I'd possibly have taken the step to be self employed with a very different day job some time ago except for how with every product idea I've had along the way it's come back to this - if it plugs into the mains instead of using batteries, and anything happens to hurt person, animal or property, you better have all your paperwork and insurance for the law suit even if your product isn't at fault. As soon as it gets the blame you will have costs even if it's to prove your product didn't cause the damage. And if it did cause the damage because the owner got his mate to dangerously modify it, and neither are admitting it, then you'll need to prove the changes made compared to your original design (photos of internals before shipping) by referring to the molten mass of internals that the fire dept investigators have as evidence.
An extreme situation that is very unlikely, but what if..... Like many others I've now made an amp for a friend. Being confident with my construction, pretty sure he won't do anything stupid with it, he'll generally be around while it's on, and will never modify it himself allows me to sleep at night. But there's still a risk and with someone I didn't know I wouldn't have all that.

[Alexo]

In the past, I drew up a brief agreement, outlining the dangers of tube amps, safety precautions, etc., and included a couple paragraphs stating that the buyer of the amp assumes responsibility, not just for any damages caused to any people or property as a result of the amp, but that he agrees to pass on this document and said responsibilities to anyone he may sell or give it to. I made two copies per amp, one for the customer and one for me to keep, signed by the customer, just in case.

Would this sort of approach do any good, should the unthinkable happen?

[CurtissRobin]

Sadly, if you were to wind up in court over one of your amps, that paper could be useful in the bathroom. Any meaning it might have to ordinary schlubs like us would be shredded by a trial lawyer.

KennyO

[Shrapnel]

Sadly indeed.

The "ambulance chasers" would find any and all excuses to invalidate such "warranties" as excuses to produce inferior products with serious safety hazards. With such tactics, it could even make it worse if that lawyer sells the right spin to a jury. It is too bad this world has gotten so sue happy... Criminals have more rights than victoms... idiots win suits that shouldn't even have gotten into court... etc.

WK,
Sounds like a winner to me, because as long as they can hire a dozen or more cheap laborers for the same wage as a local, they'll continue to outsource labor, IT, and product support. Now, to "educate the masses" in the other countries... that could definately level the playing field. It would be a good thing for the image of a union, IMHO, do that education instead of looking to be the bad guy in this economy and being seemingly unadvantagious to its own members.


Overall it sounds like we should attempt to meet all standards where feasable, but absolutely make sure we comply with safety standards for all electrical circuits we touch. Interference should't be much of a problem to meet anyway as we don't like extra noise in our amps, other than what we put in (oh wait, what we put in isn't noise, but it is AF ideally) and a good amp shouldn't emit any RFI or EMI anyway.

Also sounds like it may be a good idea to issue a DoC with the sale/transfer of ownership, and keep one on record. Sounds like we should ask for the equivelant to MSDS sheets for what we do use. (Certs on the components, and those who deal with the EU market, Certs for the RoHS stuff.) MSDS sheets, come to think of it, prob would be a good idea for any chems used in the "shop" anyway.

Documentation... documentation... documentation.... sheesh.... a one man operation just became two just to handle all the paperwork, excluding lawyers on retainers, etc. Still not cheap to get involved... but at least the DoC way gives a small outfit a better chance of success without filing for bankrupcy before any product hits the sales floor.

Perhaps a FAQ may be in order for all the known safety rules such as earth grounds, etc??? May be good for a n00b to see for their own safety too. ( I know, we all see a safety warning just about every place we start a new search or join when it comes to tube/valve amps, but this isn't the "If you be stoopid or lazy, you dead" warning.)

[guitarmike2107]

Well I am glad I am not the only one thinking about this stuff.. Didn’t want to be the one ruining everybody’s fun.

LVD) The product must be safe.
EMC) The product cannot interfere with other products, and other products cannot interfere with it.

This sums it up well, I would surmise that since the amps we are building are very similar one could easily create a generic design checklist for the safety requirements. And probably the same about the EMC though I am not to up on that.

[guitarmike2107]

I meant to add that I don't think selling an amp kit would mean you could bypass all this, I think the build instructions would have to be clear and ensure that the finished product meets the requirmeents too... any thoughts?

[conger]

Perhaps one approach would be to build an amp as a "non operational" reproduction of a '60's amp. Then fit anti tamper screws on the rear panel, put a warning plate on the back of the amp stating "DO NOT CONNECT TO MAINS VOLTAGE, DO NOT OPEN etc" and cut off the mains plug when you sell it. In some ways this approach is not too dissimilar to the reproduction gun market.

[zaphod_phil]

I meant to add that I don't think selling an amp kit would mean you could bypass all this, I think the build instructions would have to be clear and ensure that the finished product meets the requirments too... any thoughts?

Because of liability issues in the USA, a number of US kit vendors no longer sell kits with instruction, but just a bag of assorted parts. It's then up to the purchaser what they do with those parts, and they have to go on to various web sites such as this one to find schematics and layouts to use. Our fellow 18watt.com member s2, went out of the kit business completely, when someone tried to sue over having got an electric shock off a kit he'd built, or something along those lines IIRC. Anyway, he went on to start up Category 5 Amps, so it turned out well in the end.

[stevesuk]

In the UK there is a legal requirement for ALL electrical equipment used in the work place etc. to be electrically tested annually.
It is covered by the 'Code of Practice for Inspection and Testing of Electrical Equipment '.

It is known by most people (incorrectly) by the name PAT Testing.
(Portable Appliance Testing).
Equipment used for instance in a public place, like a gig should carry a current sticker stating who tested it and when and when it is due to be retested.
It should be carried out by a 'competent' person. The definition of 'competent' could be covered by qualifications or experience.
I was one of the examiners and moderators for the City and Guilds qualification when I was a wage slave, I wrote most of the exam questions. I am also a qualified Electrical Engineer, so, I would be classed as 'competent'.
There is a difference between a periodic test and testing new equipment.
The basic difference is that new equipment has a once only 2kV 'flash test'. Some 'incompetent' caretakers etc. ruin equipment by pressing this button repeatedly particularly on computer equipment.
There are portable testers available that just plug in to the equipment and carry out the test automatically. Colloquially (and incorrectly) called a 'PAT tester'.

Before equipmenmt is used even from new, it should be tested in the place of work and a retest sticker placed on it. Some over enthusiatic pub landlords insisted on band gear having the stickers when the legislation first came out. Big venues still do.

With band equipment such as amplifiers which tends to get abused, it is something that should be carried out regularly.

Sorry about the long post but you can tell I can bore for England on this topic (and used to get paid for it).

Steve UK

www.valvepower.co.uk

[CurtissRobin]

I meant to add that I don't think selling an amp kit would mean you could bypass all this, I think the build instructions would have to be clear and ensure that the finished product meets the requirmeents too... any thoughts?

Many kit sellers don't provide instructions simply because of what lawyers can do with them.

Perhaps one approach would be to build an amp as a "non operational" reproduction of a '60's amp. Then fit anti tamper screws on the rear panel, put a warning plate on the back of the amp stating "DO NOT CONNECT TO MAINS VOLTAGE, DO NOT OPEN etc" and cut off the mains plug when you sell it. In some ways this approach is not too dissimilar to the reproduction gun market.

That's a ruse we see occasionally and it presumes that judges and other court officers are as easily fooled as young dogs. Truly, I've not encountered any lawyers or judges who are that stupid, although a few do give it the old college try.

[Cynicism]If lawyers keep getting their way we'll soon be wearing safety harnesses and lanyards on stage because there's a risk of falling off the stage.

KennyO
Who rarely turns off the cynicism.

[guitarmike2107]

PAT testing is another thing to consider, though the responsibility for this lies with the employer/self employed Individual, we just need to make sure that the amps would comply?

For those who are interested here are links to the Low Voltage Directive and EMC directive, they are deliberately quite general, the harmonised standards would be more specific .. and cost silly money. This is obviously for Europe only

http://eur-lex.europa.eu/LexUriServ/sit ... 100019.pdf

http://ec.europa.eu/enterprise/electr_e ... 04_108.htm

The downfall of manufacturing in the west. Lawyers and health and safety.. The only think left to rant about it the thieving bankers!
That’s another two of our major customers gone into administration today

[rexracer]

How common is an amp fire? Anyone ever had one? Cause? I would think a small child burning themselves on an exposed tube would be more likely. Aren't you liable even with the stickers? If your amp starts a white snake incident I think they would want to talk to you.