01.01.07
The new EMC directive 2004-108-EC
Ken Webb of TÜV Product Service looks at the implications of the new directive for the rail industry
The provisions and requirements of the new EMC directive 2004/108/EC apply from 20th July 2007. Although there will be a two year transition period until July 2009 when, in theory, manufacturers can still apply the requirements of the existing EMC Directive 89/336/EEC, manufacturers would be well advised to understand and prepare for the requirements of the new directive as soon as possible.
The new directive refers to ‘equipment’ and splits this into two categories, “apparatus” and “fixed installations”. It then applies different compliance requirements to each.
Although the essential requirements have not changed, the routes to compliance have. There will now be just one route to compliance, self declaration (internal production control), and the involvement of an independent third party (currently a competent body, but in future a notified body) becomes voluntary even where harmonised standards are not applied in full.
While this relaxed regime may be welcomed by many suppliers to the rail industry, they should be aware that the new directive has some new mandatory requirements, including carrying out an EMC assessment and creating a technical file.
This article describes the main changes affecting suppliers of apparatus and how they apply to the rail industry.
All suppliers of apparatus must comply with new requirements
The railway supply industry is served by both highly specialised industry-specific products and systems and by an increasing number of commercially available products and systems, The latter are primarily intended for other industries (e.g. IT) but they are increasingly finding applications in the rail industry.
Within the rail industry there is a structured approach to overall safety and reliability, and EMC compliance forms a core part of these requirements. Whatever the size of the project, EMC will have an impact on the overall safety case and EMC assurance can be considered as confidence in the totality of EMC performance of a project comprising three key elements:
• functional safety (input to safety case)
EMC forms an important part of the overall safety case which train operating companies and infrastructure controllers are required to prepare in accordance with The Railways (Safety Case) Regulations 2000. The consideration of EMC and functional safety is usually in accordance with Yellow Book 3, Railtrack Engineering Safety Management, Volumes 1 and 2.
• Functional operation (availability & reliability)
Availability and reliability of trains and other assets, (e.g. signalling), is a key customer concern and also the subject of contractual requirements between infrastructure controllers, (e.g. Network Rail) and the TOCs. EMC plays a key role in equipment reliability, unreliability or unavailability of trains due to poor EMC leads to passenger frustration and potentially financial penalties being imposed.
• Legislation and standards (EMC directive and CE marking)
EMC legal requirements are imposed by the EMC directive and the UK implementing regulations SI 2005/281. Demonstration of compliance with the essential requirements of the directive is provided mainly through testing to the EN 50121 series of EMC standards, plus other relevant standards, and the assessment of a technical construction file (TCF) by a government appointed competent body
Therefore the changes brought about by the new directive will have a direct impact on the last of these three elements, and a knock on affect on the other two should there be problems of misinterpretation or misunderstanding.
A clear understanding of the new requirements and responsibilities is therefore essential for all involved with supplying or using electrical/electronic equipment within the rail industry. This includes:
• infrastructure controllers (e.g. Network Rail and LUL)
• train operating companies and infrastructure companies
• rolling stock leasing companies (ROSCOs)
• train builders
• equipment suppliers
New requirements bring new responsibilities
The first of the major new requirements in the directive is a legal requirement to produce technical documentation, (i.e. a technical file), enabling the conformity of the apparatus with the essential requirements to be assessed. Annex IV of the directive specifies the contents as follows:
1. a general description of the apparatus
2. evidence of compliance with the relevant national standards, if any, applied in full or in part;
3. where the manufacturer has not applied harmonised standards, or has applied them only in part, a description and explanation of the steps taken to meet the essential requirements, including a description of the electromagnetic compatibility assessment, results of design calculations made, examinations carried out, test reports, etc;
4. A statement from the notified body, if requested by the manufacturer.
It is important to understand that all suppliers of apparatus must produce this documentation. Many suppliers to the rail industry will be familiar with the TCF route under the current directive 89/336/EEC and the requirement to produce technical documentation. However for many other suppliers who don’t follow the TCF route this represents a new responsibility for them.
Item 3 in the above list highlights the second of the major new requirements, the requirement to perform an EMC assessment when harmonised standards are not applied or applied in part only.
The directive states that correctly applied relevant harmonised standards, or standards which make complete provision in respect of the apparatus, will be equivalent to performing an EMC assessment. However, where the apparatus complies only in part with the relevant harmonised standards or standards, it shall be presumed to comply only with those parts of the essential requirements which correspond to the elements of the relevant harmonised standard or standards with which the apparatus complies. A typical example where harmonised standards are applied in part only is when in-situ testing is performed on large equipment or systems, either at the manufacturer’s premise or the final point of installation. In such cases it may be impossible to apply test methods as per the standard and the new directive requires an EMC assessment to be carried out. The directive does not explain in detail what an EMC assessment should involve but it says that it shall take into account the following as a minimum:
• all intended operating conditions of the apparatus;
• different configurations;
• the relevant phenomena to meet the essential requirements
Help and guidance is available
We’ve briefly described the two main additional requirements for suppliers of apparatus under the new EMC directive. These will affect every supplier of electrical and electronic apparatus to the rail industry and many will be seeking help and guidance to ensure their products remain compliant.
The first bit of good news is that detailed guidance will be available before the directive’s effective date of 20th July 2007. The European Commission has produced a draft guidance document and this has been circulated to industry experts and organisations for comment, and the intention is to have these available as a web based document by spring 2007.
Seek help and guidance
There is no doubt that there will be a period of uncertainty while manufacturers become familiar with the additional requirements of the new directive. During this period they will require help and guidance from experienced professionals and they will be pleased to hear that such help and guidance is readily available.
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