Replacing a power cord on a vintage pedal

[PRR]

If your business has Liability Insurance, that policy will probably want your goods tested.

That would be production, not repair. Repair shop insurance can only go by general trends of that business, plus your bad record (leading to rate-hikes or refusal).

> ACKKK! Every country had its own rules and standards, ... I'm not sure exactly how, but in the run up to the EU, they quit doing that...

When lamps and transformers moved from high-tech to mass-market, many nations sought to keep production local (friends of the government) and policy was designed to tilt the playing field. Wars have been disruptive. But primarily such field-tilting policy does not work for long. Either the locals get fat and lazy OR some larger operation can climb the policy-hurdles and sell into the fenced market at a profit. I think most of the "local" electric makers ended up strapped and were "partnered" into one of the multi-national conglomerates. Now the field-tilting policies were just an extra cost they did not need. Everybody was thinking outside national lines and agreed they did not need 23 standards.

US/Can is a little outside that cluster but already our standards are moving to "harmony" with EUR standards. Only so far: yesterday I posted a picture how to hotwire Blue/Brown to Black/White. But a lot of impediments are being smoothed-over.

Small point: for decades the City Of Los Angeles required most electrics sold in LA to be tested by their own lab. Some older guitar amps have the LA sticker. It was a little extra money for the City. However LA Lab often moved much quicker than UL. Today all the major Labs are "Nationally recognized" and a LA Lab approval is about as good as UL. (And if your partners object, LA Lab will try to educate them.)

[Rob Strand]

First, there are no USA federal laws that require all electrical goods pass UL certification. Which makes sense, because UL is a >>private<< organization, started by insurance companies to get some kind of handle on what was wildly unsafe versus having some thought about how to make them safe(r). There are laws requiring certain goods, medical products among them, to be tested for safety. I  believe some of the medical device enforcement from the Food and Drug Administration and it's issued regulations do this. But guitar amps, pedals, toasters, computers, etc., no.

Thanks for setting me straight on this.  I get the picture now.  I didn't realize consumer products didn't *have to* comply to the standards.   Basically there's no equivalent to the FDA policing layer for consumer products.    The other thing I didn't realize is the NEC in the US doesn't fall under Fedral law.   Moreover you get state to state variations.  So the only thing keeping you honest is morality or the threat of legal action.  In the era of conforming to standards and the like I've only had to deal with medical devices. 

I'm not sure exactly how, but in the run up to the EU, they quit doing that model, and adopted a more privatized model. The testing labs were kicked out to fund and run themselves, the various safety agencies got together to form the standards side of the IEC, and the country passed laws saying "you can't sell stuff that harms anyone; if you have not passed the safety standards tests, you are presumed to harm people, and must not sell your goods.". This was great if you wanted to not have to get tested to different standards in every country, because you only had to run one gauntlet.

At least for medical, there very is specific government directives you must comply with.  These are essentially law.   The government directives point to the IEC standards (including the specific version(s) and applicability dates).  So while IEC might be run by a different body the government(s) in Europe have adopted them as law.  There's some technicality where the standard used by the government has an extra page to the basic IEC standard - some sort of legal hole patching.  If you do the wrong thing you can have your product stopped and it is considered breaking the law.  The system in AU virtually identical to EU.

There is a way you can "self declare" compliance.   It is an extremely grey area to what that means.  No regulatory body wants to elaborate on what that means.  I know people that give seminars on compliance don't really know what it means(!).    The only thing I do know it means is companies that don't want to do the testing just try to run the gauntlet.

In Europe I believe you need to have a local representative body to sell a product (at least a medical product).   If you are not doing things above board you might find it hard to find someone to put their hand up for the job.  Nonetheless there's grey areas that still allow products to get through.

But I digress. In the USA, our lawmakers promise to solve problems by passing new laws. Nice idea. Promise voters to stop all this carjacking by makiing carjacking illegal. There, we passed the law, problem solved. Only carjackings go on. Well, the police just aren't doing their jobs well enough. Not my problem, I introduced laws to make it illegal, so elect me again and I'll make it even MORE illegal this time.
...
Passing laws in a time of underperforming police and prosecutors and overstuffed prisons does not prevent illegal acts.

Yes, passing laws, policing and prosecuting are quite different things.

[Rixen]

In NZ there are standards, but they are not mandatory (but may be referenced in other regulations as a mandatory means of compliance). However, it is (of course) illegal to hurt someone, or create a hazard that might reasonably foreseeably cause harm.

If something is produced/tested according to the relevant standard it is deemed as having met all practicable steps to make it safe, and a court of law is going to have a hard time getting a prosecution.

If one doesn't do due diligence, one (namely the business owner) can be exposed to fines which can be huge. (Individuals cannot sue, therefore cannot really get rewarded for hurting themselves and bringing a court case)

But here's the thing, although the fines can be huge, *usually* the defendant's financial situation will be taken in to account so as to make it hurt a lot and also push for the company to make changes to improve safety without putting them out of business.

So if I repair a cable, use good practice to do the work etc, test it according to the relevant standard (AS/NZS 3760) which includes things like checking cable clamping, earth continuity test, insulation resistance test, visual inspection etc I will have met all reasonably practicable steps and will have a good defense if something goes wrong.

[Rob Strand]

So if I repair a cable, use good practice to do the work etc, test it according to the relevant standard (AS/NZS 3760) which includes things like checking cable clamping, earth continuity test, insulation resistance test, visual inspection etc I will have met all reasonably practicable steps and will have a good defense if something goes wrong.

Thanks for elaborating on the NZ scenario.  Interesting it's not law in NZ.

At least if you follow a standard it shows good intent and that you are following current practices.

I did have to change a connector once for UL.   It passed the IEC standards but didn't specifically pass the equivalent UL standard.  The intent of the two standards were the same (and most of the tests for the connector) but  I still had to change it.   I got an official ruling and the paperwork won.   Even so I didn't feel I was doing anything dodgy by using that connector.

[Rixen]

..oh, I should add that in NZ electrical work over 32 ac or 100 Vdc must be done by a licensed electrical worker unless it's your own stuff, so that throws a spanner in the works for anyone who wants to fix something and sell it..

[antonis]

At least for medical...

In Europe I believe you need to have a local representative body to sell a product (at least a medical product).   If you are not doing things above board you might find it hard to find someone to put their hand up for the job.  Nonetheless there's grey areas that still allow products to get through.

Getting more "grey", IMHO, with recent 745/2017 & 746/2017 IVDRs validation..
(at least for in vitro diagnostic products..)

[R.G.]

There is a way you can "self declare" compliance.   It is an extremely grey area to what that means.  No regulatory body wants to elaborate on what that means.  I know people that give seminars on compliance don't really know what it means(!).    The only thing I do know it means is companies that don't want to do the testing just try to run the gauntlet.

In my personal view, the self declare rules are a bit of a trap to make it appear to be fair. You can buy copies of the IEC standards- yeah, you have to buy them; the IEC standards are copyrighted works sold by the IEC. A one-time purchase of the single standard was about $300. There are many standards, and they are updated more or less frequently. You can get a full set for some thousands of dollars, but if you plan to stay current for next year's products, better you buy a subscription  which is more expensive.

You can study them, but someone without a practicing knowledge of engineering and electronics doesn't really have a chance of getting them right in practice. Currently practicing and experienced people can hope to get the safety aspects mostly right, but will probably miss a few fine points.

The now-private testing labs can speculatively test products on their own. If they do this, and find a non-conformance, their report to the regulators in the EU will make your product forbidden for sale. They will then offer to the manufacturers to test the product, at price, to see if the manufacturer's changes bring it into compliance. All well and good in theory, but it amounts to the testing labs being in bit of a protection racket. Again, only my personal opinion, which carries no weight at all.

The big companies will just funnel new products through a big testing lab a few times until the defects are arguably tested out. The products are then arguably immune to the hijacking, as it turns into a small lab arguing that the big lab is both wrong and sloppy.

Self checking in an environment like that is very chancy. If you're selling very limited quantities, you might get missed from notice. But if someone (like your competitor)  tells a testing lab that they think your product might not comply, you're in for some expensive juggling.

And you're still liable in court for any real or imagined damage your product causes.

In many ways, the old European system was cleaner. Sure, you still had to pay the testing lab to test, but the supposition was that if you did these 2,833 things, the product was presumed safe, and they told you what the 2,833 things were. Now, a safety lab will never tell you "this is safe", they will only tell you "we can't find anything that is provably not safe - yet." That still left you as a designer with having to know the matrix of all countries and their safety rules, and design to the worst case set of all the countries you were going to sell in. But still, it had some ending point. Not so now.

[Rob Strand]

In my personal view, the self declare rules are a bit of a trap to make it appear to be fair.

The cost of standards is a bit of an issue.  Some standards vendors undercut others.    It's not too bad but it depends on how many products you make, and what kind they are, as many pull-in a lot of other standards.   

You can study them, but someone without a practicing knowledge of engineering and electronics doesn't really have a chance of getting them right in practice. Currently practicing and experienced people can hope to get the safety aspects mostly right, but will probably miss a few fine points.

Agreed.  The way the standards are phrased aren't enitrely clear or unambiguous and there's many details.  Often test houses have their own interpretations, or they set the bar to a certain level on ambiguous items.    If you haven't experienced all this before it very easy to stuff-up.   Self-declaration can result in a poor interpretation of these finer points.  Some companies choose to interpret the words to suit themselves or to get around what they don't pass.  It is possible to use warning labels and put warnings in the manual but there is a line to be drawn here.  The classic example is to have exposed mains wires and a label saying danger don't touch.   The greyer versions of these type of points are not accepted by a test house.

The now-private testing labs can speculatively test products on their own.

I believe there was always a mechanism where anyone could raise an issue with a product.

Self checking in an environment like that is very chancy. If you're selling very limited quantities, you might get missed from notice. But if someone (like your competitor)  tells a testing lab that they think your product might not comply, you're in for some expensive juggling.

Very true, not mention who is going to police it.

In many ways, the old European system was cleaner. Sure, you still had to pay the testing lab to test, but the supposition was that if you did these 2,833 things, the product was presumed safe, and they told you what the 2,833 things were. Now, a safety lab will never tell you "this is safe", they will only tell you "we can't find anything that is provably not safe - yet."

Yes but it it hasn't been that way since 60601-1 Edition 3, which was rolled out on a very bumpy road in about 2012.   The mandatory risk management aspect means the company has to understand a lot of the standard.   You can't just send it off and get back your certificate.   The test houses can only go so far reviewing the risk management part.  The company uses the test house results to support their cause.   Ultimately the responsibility falls back on the company.    If a company finds a problem, they can't just say "well the test house didn't find it", it is up to the company to fix it.

There are some aspects of the newer regime that is a real pain.  It does require a lot of time and investment for a company to pass.   I've been through this a few times now and I've got the scars to prove it!   Nonetheless I agree with the intent of the new regime.  I just wish they would clean-up the wording, perhaps apply some of the requirements they impose on manufacturers to their own documents.

[Rob Strand]

Getting more "grey", IMHO, with recent 745/2017 & 746/2017 IVDRs validation..
(at least for in vitro diagnostic products..)

More changes, more confusion, more time and money spent by companies.

The thing I do agree with about the new scheme is there is process where a EU body reviews the product and documents before you are allowed to sell the product.   The ability to sell a product without some scrutiny was a big flaw in the old EU scheme.  Dodgy companies could sell stuff without doing proper background work and tests.  Now the model is more like the FDA scheme.  Hopefully it doesn't get out of hand creating an unnecessary burden like the FDA scheme.