EMC & Fixed Installations

For those that install and specify electrical equipment and components for fixed electrical installations, the newly revised Electro Magnetic Compatibility (EMC) Directive is going to have an impact on the way installations are planned and managed within Europe. ASTA BEAB a UK based, electrical certification body with a long involvement in EMC regulations and conformity have examined the new EMC Directive with a view to providing some guidance on the new legislation to the many concerned engineers, specifiers and users in the industry who are wondering 'How does this affect me?'

The Requirements of the new EMC Directive

While the old EMC Directive - 89/336/EEC made no reference to specific EMC regulations for fixed electrical installations, the new version - EMC Directive 2004/108 (published in the Official Journal at the end of December 2004) makes detailed comment on this area.

Detailed in Annex 1 of the Directive, the essential requirements of it are:
"1) Protection Requirements
Equipment shall be so deigned and manufactured, having regard to the state of the art, as to ensure that:
(a) the electromagnetic disturbance generated does not exceed the level above which radio and telecommunications equipment or other equipment cannot operate as intended;
(b) it has a level of immunity to the electromagnetic disturbance to be expected in its intended use which allows it to operate without unacceptable degradation of its intended use.
2) Specific requirements for fixed Installations
Installation and intended use of components
A fixed installation shall be installed applying good engineering practices and respecting the information on the intended use of its components, with a view to meeting the protection requirements set out in point 1. Those good engineering practices shall be documented and the documentation shall be held by the person(s) responsible at the disposal of the relevant national authorities for inspection purposes for as long as the fixed installation is in operation."

A fixed installation is considered to be:
".a particular combination of several types of apparatus, and where applicable, other devices, which are assembled, installed and intended to be used permanently at a pre-defined location" (Article 2.1.c)

What do I have to do to conform with the new legislation?

Obviously, the primary responsibility for the Electromagnetic compatibility of the components that make up a fixed installation lies with the manufacturer. They are obligated to conduct an electromagnetic compatibility assessment of their products on the basis of 'relevant phenomena' with a view to meeting the essential requirements of the Directive. They are also obliged to take into consideration the normal intended operating conditions for the item and all 'the possible configurations identified by the manufacturer as representative of its intended use' (annex ii. 2). Meeting these considerations will enable manufacturers to make and maintain a Declaration of Conformity with the Directive that they can not only use to satisfy the enforcement authorities but also to reassure their supply chain and customers that their products have adequate immunity to and shielding of electromagnetic fields to be included in an installation.

That said the new clause about fixed installations places an additional degree of responsibility for EMC compatibility on those involved with their specification and build. The requirements stress the need for builds to be completed using documented procedures. Therefore those that specify, plan and actually complete the build should consider whether their documentation would be sufficient to satisfy enforcement agency officials. Also are the specifics of hybrid or variant builds sufficiently recorded?

Obviously using established build methods gives a degree of quality assurance to the installation, but can every organisation involved in the build of fixed installations say they have every installation procedure documented? While many providers maintain an ISO 9001 management system that will contain details of installation procedures, some companies will still have to bring their records up to date. While this is only a paperwork exercise, it is an important one to be completed, as the national authorities will request to see them should a complaint be made against the installation.

In summary there are several things that can be done to contribute to your conformity efforts:

· You can follow the guidance notes from the apparatus, and where applicable, other devices, the manufacturer and use documented processes in the build.
· You can maintain documentation detailing your build procedures and information on the measures you have taken to ensure conformity with the EMC Directive
· If generic components are being used to build a fixed installation, you can opt for those that are compliant with the EMC Directive - that have suitable shielding or insulation for their proposed environment
· If in doubt of the conformity of a component or a whole installation, you can get it checked by an EMC expert

Added peace of mind

EMC Certification is used extensively by manufacturers to reassure the distribution chain that a product has undergone testing which has been specified and assessed by an accredited, specialist, and independent third party. Product certification is therefore increasingly required by electrical contractors, project specifiers and purchasers seeking peace of mind, as 'proof-positive' that a product meets with necessary regulations and that their own chances of non-conformity will be reduced by using it. This can be further bolstered by having the whole installation tested in situ, and certified by a qualified body - providing substantial evidence of efforts towards conformity and helping them meet their obligations under the Directive.

Policing
The Directive itself indicates some degree of policing of fixed installations in Article 13
".in particular, where there are complaints about disturbances being generated by the installation, the competent authorities of the Member State concerned may request evidence of conformity of the fixed installation, and, when appropriate, initiate an assessment. Where non-compliance is established, the competent authorities may impose appropriate measures to bring the fixed installation into compliance." (Article 13, 2)

"Member States shall set out the necessary provisions for identifying the person or persons responsible for the establishment of compliance of a fixed installation." (Article 13, 3)

So not only will there have to be a specific (accountable) named point of contact responsible for the conformity of an installation, but they will also have to show evidence of its conformity when challenged to do so. Should an installation be shown to be non-compliant they can also be obliged to make it so.

Although the policing of the revised EMC Directive has not yet commenced, it would be prudent to introduce conformity procedures into installation projects as soon as possible. Not only does this future-proof installations for conformity, but it could also be used as a differentiator in the marketing of your services. In addition, it provides compelling evidence of your commitment to EMC conformity best practice.

Should you require more detailed advice about the new EMC directive and how it affects your fixed installations, contact you local EMC Advisor or Certification Body and they will be happy to assist you.