An update on CE Marking Electrical Cable

CE Marking Wire and Cable

A picture showing a selection of wire and cable products
Domes­tic and Euro­pean Wire and Cable Prod­ucts

In an ear­li­er post, I wrote about the require­ments for CE Mark­ing wire and cable and dis­cussed the mark. In 2016, the Con­struc­tion Prod­ucts Reg­u­la­tion 305/2011 (CPR) came into effect, replac­ing the Con­struc­tion Prod­ucts Direc­tive 89/106/EEC. The CPR includ­ed pro­vi­sions cov­er­ing any kind of mate­ri­als that could be used in con­struc­tion, and that includes elec­tri­cal cables.

A New Standard under the CPR

A new stan­dard was approved, EN 50575, cov­er­ing the char­ac­ter­is­tics of pow­er, con­trol and com­mu­ni­ca­tion cables used in per­ma­nent instal­la­tions in build­ings. EN 50575 cov­ers the reac­tion of cables to fire. The stan­dard pro­vides require­ments for four char­ac­ter­is­tics: flame spread, smoke gen­er­a­tion, the for­ma­tion of molten droplets and acid con­tent. The result is a new set of mark­ings for cables cov­ered by the stan­dard, includ­ing CE Mark­ing. Also required by the CPR is a Dec­la­ra­tion of Per­for­mance, not a Dec­la­ra­tion of Con­for­mi­ty. The Dec­la­ra­tion of Per­for­mance pro­vides dif­fer­ent infor­ma­tion than that found in a Dec­la­ra­tion of Con­for­mi­ty.

Application of EN 50575

EN 50575 only applies to cables or wiring prod­ucts intend­ed for use in con­struc­tion. It should not be applied to wiring mate­ri­als used for inter­nal wiring of appli­ances and prod­ucts. These prod­ucts are out­side the scope of the CPR and there­fore are also out­side the scope of EN 50575.


  • Cables used for per­ma­nent instal­la­tion in build­ings must be CE Marked start­ing 1-Jul-2017
  • Wire and cable prod­ucts used in machines and appli­ances are not affect­ed by EN 50575, and there­fore should not be CE Marked
  • Cables used to inter­con­nect machin­ery and which are per­ma­nent­ly installed into build­ing infra­struc­ture (e.g., Eth­er­net cables and oth­er inter­con­nect­ing cables run through build­ing struc­tures in per­ma­nent wire­ways or in plenum spaces) require CE Mark­ing as of 1-Jul-17
  • Wire and cable prod­ucts, like line-cord assem­blies, for exam­ple, require a CE Mark because they are com­plete prod­ucts and are cov­ered by a spe­cif­ic EN Stan­dard under the Low Volt­age Direc­tive.

Here’s a good sum­ma­ry of the new require­ments and an expla­na­tion of the new mark­ings in a video by Gen­er­al Cable. Full dis­clo­sure: we have no rela­tion­ship with Gen­er­al Cable or any oth­er wire and cable man­u­fac­tur­er.

Need more help? Get in touch!

ISO 13849–1 Analysis — Part 6: CCF — Common Cause Failures

This entry is part 6 of 9 in the series How to do a 13849–1 analy­sis

What is a Common Cause Failure?

There are two sim­i­lar-sound­ing terms that peo­ple often get con­fused: Com­mon Cause Fail­ure (CCF) and Com­mon Mode Fail­ure. While these two types of fail­ures sound sim­i­lar, they are dif­fer­ent. A Com­mon Cause Fail­ure is a fail­ure in a sys­tem where two or more por­tions of the sys­tem fail at the same time from a sin­gle com­mon cause. An exam­ple could be a light­ning strike that caus­es a con­tac­tor to weld and simul­ta­ne­ous­ly takes out the safe­ty relay proces­sor that con­trols the con­tac­tor. Com­mon cause fail­ures are there­fore two dif­fer­ent man­ners of fail­ure in two dif­fer­ent com­po­nents, but with a sin­gle cause.

Com­mon Mode Fail­ure is where two com­po­nents or por­tions of a sys­tem fail in the same way, at the same time. For exam­ple, two inter­pos­ing relays both fail with weld­ed con­tacts at the same time. The fail­ures could be caused by the same cause or from dif­fer­ent caus­es, but the way the com­po­nents fail is the same.

Com­mon-cause fail­ure includes com­mon mode fail­ure, since a com­mon cause can result in a com­mon man­ner of fail­ure in iden­ti­cal devices used in a sys­tem.

Here are the for­mal def­i­n­i­tions of these terms:

3.1.6 com­mon cause fail­ure CCF

fail­ures of dif­fer­ent items, result­ing from a sin­gle event, where these fail­ures are not con­se­quences of each oth­er

Note 1 to entry: Com­mon cause fail­ures should not be con­fused with com­mon mode fail­ures (see ISO 12100:2010, 3.36). [SOURCE: IEC 60050?191-am1:1999, 04–23.] [1]


3.36 com­mon mode fail­ures

fail­ures of items char­ac­ter­ized by the same fault mode

NOTE Com­mon mode fail­ures should not be con­fused with com­mon cause fail­ures, as the com­mon mode fail­ures can result from dif­fer­ent caus­es. [lEV 191–04-24] [3]

The “com­mon mode” fail­ure def­i­n­i­tion uses the phrase “fault mode”, so let’s look at that as well:

fail­ure mode
DEPRECATED: fault mode
man­ner in which fail­ure occurs

Note 1 to entry: A fail­ure mode may be defined by the func­tion lost or oth­er state tran­si­tion that occurred. [IEV 192–03-17] [17]

As you can see, “fault mode” is no longer used, in favour of the more com­mon “fail­ure mode”, so it is pos­si­ble to re-write the com­mon-mode fail­ure def­i­n­i­tion to read, “fail­ures of items char­ac­terised by the same man­ner of fail­ure.”

Random, Systematic and Common Cause Failures

Why do we need to care about this? There are three man­ners in which fail­ures occur: ran­dom fail­ures, sys­tem­at­ic fail­ures, and com­mon cause fail­ures. When devel­op­ing safe­ty relat­ed con­trols, we need to con­sid­er all three and mit­i­gate them as much as pos­si­ble.

Ran­dom fail­ures do not fol­low any pat­tern, occur­ring ran­dom­ly over time, and are often brought on by over-stress­ing the com­po­nent, or from man­u­fac­tur­ing flaws. Ran­dom fail­ures can increase due to envi­ron­men­tal or process-relat­ed stress­es, like cor­ro­sion, EMI, nor­mal wear-and-tear, or oth­er over-stress­ing of the com­po­nent or sub­sys­tem. Ran­dom fail­ures are often mit­i­gat­ed through selec­tion of high-reli­a­bil­i­ty com­po­nents [18].

Sys­tem­at­ic fail­ures include com­mon-cause fail­ures, and occur because some human behav­iour occurred that was not caught by pro­ce­dur­al means. These fail­ures are due to design, spec­i­fi­ca­tion, oper­at­ing, main­te­nance, and instal­la­tion errors. When we look at sys­tem­at­ic errors, we are look­ing for things like train­ing of the sys­tem design­ers, or qual­i­ty assur­ance pro­ce­dures used to val­i­date the way the sys­tem oper­ates. Sys­tem­at­ic fail­ures are non-ran­dom and com­plex, mak­ing them dif­fi­cult to analyse sta­tis­ti­cal­ly. Sys­tem­at­ic errors are a sig­nif­i­cant source of com­mon-cause fail­ures because they can affect redun­dant devices, and because they are often deter­min­is­tic, occur­ring when­ev­er a set of cir­cum­stances exist.

Sys­tem­at­ic fail­ures include many types of errors, such as:

  • Man­u­fac­tur­ing defects, e.g., soft­ware and hard­ware errors built into the device by the man­u­fac­tur­er.
  • Spec­i­fi­ca­tion mis­takes, e.g. incor­rect design basis and inac­cu­rate soft­ware spec­i­fi­ca­tion.
  • Imple­men­ta­tion errors, e.g., improp­er instal­la­tion, incor­rect pro­gram­ming, inter­face prob­lems, and not fol­low­ing the safe­ty man­u­al for the devices used to realise the safe­ty func­tion.
  • Oper­a­tion and main­te­nance, e.g., poor inspec­tion, incom­plete test­ing and improp­er bypass­ing [18].

Diverse redun­dan­cy is com­mon­ly used to mit­i­gate sys­tem­at­ic fail­ures, since dif­fer­ences in com­po­nent or sub­sys­tem design tend to cre­ate non-over­lap­ping sys­tem­at­ic fail­ures, reduc­ing the like­li­hood of a com­mon error cre­at­ing a com­mon-mode fail­ure. Errors in spec­i­fi­ca­tion, imple­men­ta­tion, oper­a­tion and main­te­nance are not affect­ed by diver­si­ty.

Fig 1 below shows the results of a small study done by the UK’s Health and Safe­ty Exec­u­tive in 1994 [19] that sup­ports the idea that sys­tem­at­ic fail­ures are a sig­nif­i­cant con­trib­u­tor to safe­ty sys­tem fail­ures. The study includ­ed only 34 sys­tems (n=34), so the results can­not be con­sid­ered con­clu­sive. How­ev­er, there were some star­tling results. As you can see, errors in the spec­i­fi­ca­tion of the safe­ty func­tions (Safe­ty Require­ment Spec­i­fi­ca­tion) result­ed in about 44% of the sys­tem fail­ures in the study. Based on this small sam­ple, sys­tem­at­ic fail­ures appear to be a sig­ni­fi­cate source of fail­ures.

Pie chart illustrating the proportion of failures in each phase of the life cycle of a machine, based on data taken from HSE Report HSG238.
Fig­ure 1 — HSG 238 Pri­ma­ry Caus­es of Fail­ure by Life Cycle Stage

Handling CCF in ISO 13849–1

Now that we under­stand WHAT Com­mon-Cause Fail­ure is, and WHY it’s impor­tant, we can talk about HOW it is han­dled in ISO 13849–1. Since ISO 13849–1 is intend­ed to be a sim­pli­fied func­tion­al safe­ty stan­dard, CCF analy­sis is lim­it­ed to a check­list in Annex F, Table F.1. Note that Annex F is infor­ma­tive, mean­ing that it is guid­ance mate­r­i­al to help you apply the stan­dard. Since this is the case, you could use any oth­er means suit­able for assess­ing CCF mit­i­ga­tion, like those in IEC 61508, or in oth­er stan­dards.

Table F.1 is set up with a series of mit­i­ga­tion mea­sures which are grouped togeth­er in relat­ed cat­e­gories. Each group is pro­vid­ed with a score that can be claimed if you have imple­ment­ed the mit­i­ga­tions in that group. ALL OF THE MEASURES in each group must be ful­filled in order to claim the points for that cat­e­go­ry. Here’s an exam­ple:

A portion of ISO 13849-1 Table F.1.
ISO 13849–1:2015, Table F.1 Excerpt

In order to claim the 20 points avail­able for the use of sep­a­ra­tion or seg­re­ga­tion in the sys­tem design, there must be a sep­a­ra­tion between the sig­nal paths. Sev­er­al exam­ples of this are giv­en for clar­i­ty.

Table F.1 lists six groups of mit­i­ga­tion mea­sures. In order to claim ade­quate CCF mit­i­ga­tion, a min­i­mum score of 65 points must be achieved. Only Cat­e­go­ry 2, 3 and 4 archi­tec­tures are required to meet the CCF require­ments in order to claim the PL, but with­out meet­ing the CCF require­ment you can­not claim the PL, regard­less of whether the design meets the oth­er cri­te­ria or not.

One final note on CCF: If you are try­ing to review an exist­ing con­trol sys­tem, say in an exist­ing machine, or in a machine designed by a third par­ty where you have no way to deter­mine the expe­ri­ence and train­ing of the design­ers or the capa­bil­i­ty of the company’s change man­age­ment process, then you can­not ade­quate­ly assess CCF [8]. This fact is recog­nised in CSA Z432-16 [20], chap­ter 8. [20] allows the review­er to sim­ply ver­i­fy that the archi­tec­tur­al require­ments, exclu­sive of any prob­a­bilis­tic require­ments, have been met. This is par­tic­u­lar­ly use­ful for engi­neers review­ing machin­ery under Ontario’s Pre-Start Health and Safe­ty require­ments [21], who are fre­quent­ly work­ing with less-than-com­plete design doc­u­men­ta­tion.

In case you missed the first part of the series, you can read it here. In the next arti­cle in this series, I’m going to review the process flow for sys­tem analy­sis as cur­rent­ly out­lined in ISO 13849–1. Watch for it!

Book List

Here are some books that I think you may find help­ful on this jour­ney:

[0]     B. Main, Risk Assess­ment: Basics and Bench­marks, 1st ed. Ann Arbor, MI USA: DSE, 2004.

[0.1]  D. Smith and K. Simp­son, Safe­ty crit­i­cal sys­tems hand­book. Ams­ter­dam: Else­vier/But­ter­worth-Heine­mann, 2011.

[0.2]  Elec­tro­mag­net­ic Com­pat­i­bil­i­ty for Func­tion­al Safe­ty, 1st ed. Steve­nage, UK: The Insti­tu­tion of Engi­neer­ing and Tech­nol­o­gy, 2008.

[0.3]  Overview of tech­niques and mea­sures relat­ed to EMC for Func­tion­al Safe­ty, 1st ed. Steve­nage, UK: Overview of tech­niques and mea­sures relat­ed to EMC for Func­tion­al Safe­ty, 2013.


Note: This ref­er­ence list starts in Part 1 of the series, so “miss­ing” ref­er­ences may show in oth­er parts of the series. The com­plete ref­er­ence list is includ­ed in the last post of the series.

[1]     Safe­ty of machin­ery — Safe­ty-relat­ed parts of con­trol sys­tems — Part 1: Gen­er­al prin­ci­ples for design. 3rd Edi­tion. ISO Stan­dard 13849–1. 2015.

[2]     Safe­ty of machin­ery — Safe­ty-relat­ed parts of con­trol sys­tems — Part 2: Val­i­da­tion. 2nd Edi­tion. ISO Stan­dard 13849–2. 2012.

[3]      Safe­ty of machin­ery — Gen­er­al prin­ci­ples for design — Risk assess­ment and risk reduc­tion. ISO Stan­dard 12100. 2010.

[8]     S. Joce­lyn, J. Bau­doin, Y. Chin­ni­ah, and P. Char­p­en­tier, “Fea­si­bil­i­ty study and uncer­tain­ties in the val­i­da­tion of an exist­ing safe­ty-relat­ed con­trol cir­cuit with the ISO 13849–1:2006 design stan­dard,” Reliab. Eng. Syst. Saf., vol. 121, pp. 104–112, Jan. 2014.

[17]      “fail­ure mode”, 192–03-17, Inter­na­tion­al Elec­trotech­ni­cal Vocab­u­lary. IEC Inter­na­tion­al Elec­trotech­ni­cal Com­mis­sion, Gene­va, 2015.

[18]      M. Gen­tile and A. E. Sum­mers, “Com­mon Cause Fail­ure: How Do You Man­age Them?,” Process Saf. Prog., vol. 25, no. 4, pp. 331–338, 2006.

[19]     Out of Control—Why con­trol sys­tems go wrong and how to pre­vent fail­ure, 2nd ed. Rich­mond, Sur­rey, UK: HSE Health and Safe­ty Exec­u­tive, 2003.

[20]     Safe­guard­ing of Machin­ery. 3rd Edi­tion. CSA Stan­dard Z432. 2016.

[21]     O. Reg. 851, INDUSTRIAL ESTABLISHMENTS. Ontario, Cana­da, 1990.

Five things you need to know about CE Marked Wire and Cable

Wire is sim­ple right? Maybe not! Here are the top five things to know when select­ing wire and cable prod­ucts for use in designs that will be CE Marked:

  1. Wire and cable prod­ucts sold in the EU must be CE Marked under the Low Volt­age Direc­tive, and MAY bear BOTH the CE Mark and the HAR mark. The HAR mark may only be applied by man­u­fac­tur­ers that have met the require­ments for the use of the HAR mark. More infor­ma­tion on the HAR mark. 

    Picture of the HAR Mark.
    The HAR Mark
  2. The HD 21.X and HD 22.X Har­mo­niza­tion Doc­u­ments pre­vi­ous­ly used for deter­min­ing com­pli­ance and apply­ing the CE Mark are being replaced by the EN 50525.X fam­i­ly of stan­dards start­ing on 2014-01-17. See the list.
  3. Wire and Cable prod­ucts with Dec­la­ra­tions of Con­for­mi­ty that refer to old­er ver­sions of the Low Volt­age Direc­tive, or that refer to HD doc­u­ments that have been super­seded are NO LONGER COMPLIANT.
  4. Wire and Cable prod­ucts used in “large-scale” machine tools and fixed instal­la­tions do not need to meet WEEE require­ments.
  5. Design­ers are not required to use CE Marked wire and cable prod­ucts in CE Marked Prod­ucts.

Need to know more? Check out this arti­cle!