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The over testing trap

Author : Richard Poate is Senior Compliance Manager at TÜV SÜD Product Service

07 November 2016

As well as being fit for purpose and functional, products must be able to meet the applicable regulatory standards in order to be legally brought to market.

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It is therefore vitally important to consider what the compliance requirements will be, in the form of regulations and standards, at the early product design stages. 

If this isn’t done, the testing and certification process may become complex and could lead to significant time-to-market delays. Also, additional costs may be accrued if re-designs are required and subsequently ‘retro-fitted’ in order to achieve compliance. 

However, the design of electrical and electronic products is becoming increasingly complex. What were once simple mechanical devices now often incorporate electronics, wireless capabilities and even robotics. As technological developments evolve rapidly, test standards are failing to keep up with these product innovations. Designers, manufacturers and end users are therefore often confused as to which standard, or multiple standards, should be applied to a product to ensure compliance. 

TÜV SÜD see this situation replicated for all types of product, including the more obvious technologically complex devices such as tablets and smart TVs, as well as the less obvious, such as domestic fridges, cars, medical devices and even street lamps. 

Wireless world

With the increasing end user expectation that products will have wireless capabilities, manufacturers are producing products that are becoming increasingly complex in their design. The rapid development of wireless technology, and the corresponding end-user acceptance of a wireless capability, has created a situation where product designers are now unfamiliar with the regulatory requirements of their target markets. TÜV SÜD is seeing an increase in the number of non-compliant products coming into its laboratories. 

The cost of regulatory compliance very much depends on the type of technology being used and the complexity of the equipment itself. For example, a mobile phone using a combination of 4G, Wi-Fi and Bluetooth technology will cost many thousands of pounds more than a simple device using just Bluetooth technology.

In order to reduce both costs and time to market for new products, many designers integrating wireless systems into their product are therefore relying on the use of wireless modules which already meet some or all of the Radio Equipment Directive (RED) requirements. 

However, once these modules are integrated into another product, this changes the regulatory requirements as it is the entire host product itself, and not just the module, which now falls within the scope of the RED. The assumption that no further action is required because the wireless module is compliant as an independent component is therefore incorrect. Articles 3.1a (safety) and 3.1b (Electromagnetic Compatibility) as defined by the RED apply to all radio equipment and telecommunication equipment. Despite this, it is worth remembering that integrating a pre-approved module will save manufacturers time and money when it comes to testing the whole device. 

Wasting time

Electrical testing

While testing both end products and their components is critical, this can often be duplicated unnecessarily to ‘cover all bases’. This reflects a poor understanding of the intended environment and of the specifications used to determine if testing should be done. Consequently, most will err on the side of caution and often over test their products and systems. 

However, as products become increasingly technologically complex, it is impossible to achieve this. For example, for products that have a wireless component (such as Bluetooth or WLAN), and other features (multi-function equipment) such as battery back-up, you cannot sensibly test for every mode in every configuration that is laid out in the relevant standards. Instead you need to find the worst case or worst cases, which generally require expert knowledge. Failure to do this would take months and cause serious time to market delays, let alone substantial costs for what are largely irrelevant tests.

For example, a large scale industrial printer is traditionally considered a machine due its mechanical moving parts. However, these products have evolved and now incorporate electronics and RFID modules. 

In this case, clearly the RED applies due to the inclusion of RFID technology. Electrical safety is taken care of by article 3.1a of the RED, but the potential hazards caused by the machine itself are not necessarily covered. So, a supplementary assessment to the essential health and safety requirements of the Machinery Directive would be advised and expected by the end use customer. 

Worse case

As equipment is becoming more complex and there are more operating modes, it is proving expensive and time consuming to test. Therefore consider performing testing to establish the “worst case” modes of operation in order to reduce test time and therefore cost.

Take a step back and identify all the possible hazards that could occur when operating the machine, but do not take this approach too literally. Are the hazards mainly mechanical, electrical or EMC/radio emissions? For example, the Machinery Directive defines a machine as “an assembly of linked parts or components, at least one of which moves…” However, a laptop is an assembly of linked parts which move and TÜV SÜD would not consider that as something that required testing under this Directive.

Never before has it been more important to match innovative products design with an innovative approach to testing and compliance. As technology progresses and multiple capabilities are incorporated into a single product, it is vital that compliance requirements and approaches are considered from the initial design stage. 

To expedite the test process, remember that a test laboratory will not be familiar with individual products. Test laboratories see hundreds of product types of all shapes and sizes using multiple technologies, and every manufacturer has their own implementation of test modes. Therefore, prepare user manuals for the test software and operation of test modes, ensuring that instructions are crystal clear, including detail such as screen shots and photographs. Also, where setups are complicated consider attending to assist the laboratory in the early stages.

Otherwise, re-designs further down the line will be significant both in terms of cost and timescales. Pre-compliance work early on in the product design and manufacturing phase should be a key consideration as this will avoid retro-fitting at a later stage, which is more costly and will invariably delay the time to market.


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