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61/MT23(Convenor) 497A

61/5830/RVC

RESULT OF VOTING ON CDV (RVC)

PROJECT NUMBER:

IEC 60335-1/FRAG2 ED6

DATE OF CIRCULATION:

2019-04-19

REFERENCE NUMBER OF THE CDV:

61/5732/CDV

IEC TC 61 : SAFETY OF HOUSEHOLD AND SIMILAR ELECTRICAL APPLIANCES

SECRETARIAT: SECRETARY: CHAIR:

United States of America Ms Randi Myers Mr Fabio Gargantini

OF INTEREST TO THE FOLLOWING COMMITTEES: HORIZONTAL STANDARD:

SC 61B, SC 61C, SC 61D, SC 61H, SC 61J

FUNCTIONS CONCERNED:

EMC ENVIRONMENT QUALITY ASSURANCE SAFETY

SUBMITTED FOR CENELEC PARALLEL VOTING NOT SUBMITTED FOR CENELEC PARALLEL VOTING

The CDV document was distributed to National Committees with a request that voting take place for circulation as a FDIS or publication as an International Standard.

P-MEMBERS VOTING

MEMBERS VOTING P-MEMBERS IN FAVOUR IN FAVOUR % CRITERIA RESULT

37 34 91.9 ≥66,7 % APPROVED

ALL VOTES

TOTAL VOTES CAST TOTAL AGAINST AGAINST % CRITERIA RESULT

40 3 7.5 ≤25 % APPROVED

The chair (in cooperation with the secretariat and the project leader) has taken the following course of action:

WHEN THE APPROVAL CRITERIA HAVE BEEN MET:

A1 THE COMMITTEE DRAFT FOR VOTE (CDV) WILL BE REGISTERED AS A FDIS BY 2019-07-31

A2 THE COMMITTEE DRAFT FOR VOTE (CDV) WILL BE REGISTERED AS AN IS BY

WHEN THE APPROVAL CRITERIA HAVE NOT BEEN MET:

B A REVISED COMMITTEE DRAFT FOR VOTE (CDV) WILL BE DISTRIBUTED BY

C A REVISED COMMITTEE DRAFT (CD) WILL BE DISTRIBUTED BY

D THE COMMENTS WILL BE DISCUSSED AT THE NEXT MEETING OF ON

A2 When proceeding directly to publication, no changes to the technical content of the enquiry draft shall be made.

In the case of a proposal B or C made by the chair, if two or more P-members disagree within 2 months of the circulation of this compilation, then the draft shall be discussed at a meeting.

TITLE:

Household and similar electrical appliances - Safety - Part 1: General requirements

NOTE FROM TC/SC OFFICERS:

This document will be discussed during the TC 61 Plenary meeting in Bled, Slovenia, 3-7 June 2019. After the meeting, a revised RVC document will be circulated with the confirmed Observations of the Secretariat included.

Annexes: Result of voting, Comments received

61(Bled/MT23)36

June 2019

61/5830/RVC 61/MT23(Convenor) 497A

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Voting Result on 61/5732/CDVCirculation Date: 2018-12-28 Closing Date: 2019-03-22IEC 60335-1/FRAG2 ED6: Household and similar electrical appliances - Safety - Part 1: General requirementsCountry Status Vote Comments ReceivedAlbania P -Argentina O -Australia P Y - 2019-03-05Austria P Y - 2019-03-21Belarus O Y - 2019-03-22Belgium P Y - 2019-03-22Brazil O A - 2019-03-22Bulgaria O -Canada P Y - 2019-03-12China P Y - 2019-03-11Czech Republic P Y - 2019-03-15Denmark P Y Y 2019-03-22Egypt P Y - 2019-03-20Finland P Y - 2019-03-21France P Y Y 2019-03-21Germany P Y Y 2019-03-22Greece P Y - 2019-03-21Hungary P Y - 2019-03-22India P Y - 2019-03-19Indonesia P A - 2019-03-19Iran P N Y 2019-03-17Ireland P A - 2019-01-04Israel P A - 2019-03-21Italy P Y Y 2019-03-21Japan P N Y 2019-03-22Korea, Republic of P Y - 2019-03-22Kuwait O -Malaysia P Y - 2019-03-21Mexico P Y - 2019-03-22Netherlands P Y Y 2019-03-18New Zealand P Y - 2019-03-04Norway P Y - 2019-03-07Pakistan P Y - 2019-03-19Philippines, Rep. of the P Y - 2019-03-19Poland P Y - 2019-03-19Portugal P A - 2019-03-22Qatar O Y - 2019-03-19Romania O -Russian Federation O Y - 2019-03-21Saudi Arabia O -Serbia P Y - 2019-03-15Singapore O -Slovakia O -Slovenia P Y - 2019-03-21South Africa P A - 2019-03-22Spain P Y - 2019-03-22Sweden P N Y 2019-03-19Switzerland P Y Y 2019-03-19Thailand P Y - 2019-02-26Turkey P Y - 2019-03-20Ukraine P Y - 2019-03-21United Arab Emirates - - - 2019-03-17United Kingdom P Y - 2019-03-20United States of America P Y Y 2019-03-15Vietnam P Y - 2019-03-14

Approval Criteria ResultP-Members voting: 37P-Members in favour: 34 = 91.9% >=66.7% APPROVEDTotal votes cast: 40 Total against: 3 = 7.5% <=25% APPROVEDFinal Decision: APPROVED

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61/5830/RVC 61/MT23(Convenor) 497ANotes

1. Vote: Does the National Committee agree to the circulation of the draft as a FDIS: Y = In favour; N = Against; A = Abstention.2. Abstentions are not taken into account when totalizing the votes.3. P-members not voting: Albania(1).

*Comments rejected because they were not submitted in the IEC Comment form. **Vote rejected due to lack of justification statement.

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61/5830/RVC 61/MT23(Convenor) 497ADate Document Project Nr.2019-03-22 61/5732/CDV 60335-1/FRAG 2 ED6

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Type of comment Comments Proposed change Observations of the secretariat

Convenor if necessry

1 CH01 ge The CH NC supports this document with the following comments.

NotedMT23 observation:Accepted.

2 CI/ANEC01

ge Consumers International and ANEC support IEC 60335-1/FRAG2 ED6 ‘Household and similar electrical appliances - Safety - Part 1: General requirements’


3 IT01 ge The Italian NC is in favor of proposed document 61/5732/CDV and submits the following comments.


4 ZA01 ge ZA NC accept 61/5732/CDV the no technical comment:


5 DK01 ge Need of clarification: Different expressions are used for referring to the standard; “the standard”, “the entire standard”, “clause 8-32”. Why using different expressions?

Be consistent throughout the proposal Referred to EG1MT23 observation:Accepted.

6 IR02 2 ge Since the IEC60335-1 is a safety standard, it is recommended that IEC GUIDE 104 and ISO/IEC GUIDE 51 be added in references

Add the new references:IEC GUIDE 104:2010, The preparation of safety publications and the use of basic safety publications and group safety publicationsISO/IEC GUIDE 51:2014, Safety aspects -- Guidelines for their inclusion in standards

Not accepted – this has nothing to do with the CDV. It is a new proposal and should be submitted as new DC by the IRNC if necessary.MT23 observation:Accepted.

7 JP01 ge We do not agree to the CDV for the following reasons.- The scope should be limited to remote

communication through public communication line out of home, excluding home WLAN network.

- Criteria for cryptographic techniques are unclear to check compliance.


7 SE01 ge The Swedish NC put a negative vote on the document for the reasons specified below.


9 CH02 16, 22, 27

3.10.2 ed Wrong formatting. Format “public network” in bold. Referred to EG1MT23 observation:Accepted.

10 FR01 19 3.10.2 ed Use the acronym for "Power line communication" as for the other examples

Modify indent as following :"- PLC (power line communication)"

AcceptedMT23 observation:Accepted.

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11 NL01 20 3.10.2 te SRD (short range devices) is applicable to many different types of wireless equipment including various forms as :-Access control-alarms & movement detectors-cordless audio devices-remote control-RFID(source: ETSI)

Therefore SRD will in practice often be restricted to the physical space of the household environment and can thus not be claimed to be a public network

Move line 20 to the next paragraph of the note (lines 22-26).

Referred to MT23

MT23: Not accepted. SRD (short range devices) is useable up to 300 m (public network).

12 NL02 30 3.10.3 te/ed The used word ‘exchange’ implies that remote communication is always two-way (duplex), whereas the term ‘remote communication’ in the meaning of the CDV also covers one-way communication, e.g. an appliance that can be controlled with sound / voice commands or an appliance that uses send-only transmission of data.

Replace the word ‘exchange’ by ‘transmission’ (including in note 1 to entry) and add a note 2:NOTE 2 to entry: Transmission of data can be one-way (simplex) or two way (duplex).

Referred to MT23

MT23: Accepted only for the definition not in sub Clause 22.xx.

13 IT02 32 3.10.3 ed The "," after modulation is not needed, Remove "," after modulation. Referred to EG1MT23 observation:Accepted.

14 NL03 41 3.10.4 ed Note 2 is not directly related to the definition of remote operation but rather to the definition of remote communication.The note aims to clarify that line of sight IR signal is not considered to be a signal that can initiate something out of sight and thus that a line of sight IR signal is not to be considered remote communication.

Move note 2 to 3.10.3. Referred to MT23

MT23: Not accepted.

15 IR01 7.14 Para 7 te For compliance of durability in marking, it is recommended to use of the apparatus shown in figure 8 IEC 60730a-1

Change first sentence of paragraph 7 in sub clause 7.14 with : Compliance is checked by measurement and by rubbing the marking by using apparatus shown in figure 8 IEC60730-1 for 15 s and again for 15 s with petroleum spirit.


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16 IR03 11.2IEC60335-1: CSV

After last paragraph

te The physical characteristic of test corner should be relative with dimensional characteristic of specimen. For example in large specimen like washing machine there are no additional requirements in this standard.

It is recommended that the clause 11.2.1 is added in last paragraph11.2.1. Test corner shall have three sides and ceiling if necessary, the dimensions of test corner should be relative with dimensional characteristic of specimen. Specific requirement are stated in particular requirement of part 2-2 , if necessary.


17 IR04 19.13 After first paragraph

te The specification of poisonous and ignition gas should be specified in this sub clause

It is recommended that this Note1 is added after first paragraph:Note 1: Any gasses produced as a result of abnormal conditions should not have potential toxicity like carcinogenic and skin or eye irritation for user


18 IT03 46 22.XX ed Missing the ":" at the end of the sentence. Add " : " after “to”. Referred to EG1MT23 observation:Accepted.

19 NL04 47 22.xx Item a) ed The words ‘or the exchange of data’ is superfluous as the exchange of data is inherently covered by the remote communication definition:remote communicationexchange of data between the appliance and an entity that can be initiated out of sight of the appliance, using communication means such as radio wave modulation, sound wave modulation, or bus systemsDeleting the words ‘or exchange of data’ will also align item a) with b) where the words ‘or exchange of data’ have not been added.

Delete the words ‘or exchange of data’.

(note: if deletion is not approved, the words ‘or exchange of data’ will need to be added to item b) to align items a) and b) as there should be no difference in approach between a) and b))

Referred to MT23

MT23: Not accepted to delete exchange of data in line 47 because we change data in the hardware of the appliance, but accept the term “or the exchange of data in line 57 after the word “software”.

20 SE02 49 22.xx ed 22.46 is included in clauses 8 to 32 on line 50

Delete line 49 and move contents of line 50 to the end of line 48.

Referred to MT23MT23: Not accepted. Essential for the understanding, see also guidance document.

21 DK02 50 22.XX te In our opinion a SW download can impair the requirements also in §7 and therefore §7 should be included in this requirement. E.g. some appliances can vary the accepted input voltage in the software.

Change “clauses 8 to 32” to “clauses 7 to 32”

Referred to MT23MT23: Not accepted.Risks referenced in the comment should be covered by Clause 10 and many aspects of Clause 7 which would not apply, therefore MT23 recommends to submit in change proposal for amendment 1 with more detail proposal.

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22 SE03 50 22.xx te If the none PEC software are corrupt the user will be still protected by the functions in clause 19.Exclude cause 11 due to that it is exclude in clause 22.46 ” These requirements are not applicable to software used for functional purpose or for compliance with Clause 11.”

Change from “clauses 8 to 32“ to “clauses 8 to10 and 12 to 32”

Delete “Note 1” and renumber “Note 2”.

Referred to MT23MT23: strongly not accepted. Would not be in line with the intent of 22.xx which requires “shall not impair compliance with this standard” (all clauses). See also the Guidance document 61/5761/DC (lines 653-665).

23 CH03 53 22.XX ed Typo. Add a blank or space after “8 to”. Referred to EG1MT23 observation:Accepted.

24 DK03 53 22.XX NOTE 2 ed If DK02 is accepted a change is also needed here

Change “clauses 8 to 32” to “clauses 7 to 32”

See comment 21MT23: See comment 21.

25 NL05 53 ed Add space between ‘to’ and ‘32’ is missing. Add space between ‘to’ and ‘32’. Referred to EG1MT23 observation:Accepted.

26 DE01 53-56 22.XX ed Decision 26, NL02 from document IEC 61/5634A/CC was not completely implemented in the CDV. Recommend to modify as agreed.

NOTE 2 should read as follows (changes are underlined):NOTE 2 Examples of means which do not affect clauses 8-32 of this standard are the change of speed setting of a range hood fan, change of operational setting of an air conditioner (i.e. fan speed, heating and cooling temperatures, louver movement), operation of a drive for shutters, blinds, gates etc. to open or close the driven part.

Not accepted.EG1 revised the comment editorially to follow the correct style.8-32 was replaced by 8 to 32(i.e. was replaced by such as.

MT23: The first part “8-32” to “8 to 32” is accepted. Note 2 as proposed by DE shall be implemented in the final version of this CDV, because proposed change is necessary for the better understanding.

27 CH04 54 22.XX ed Typo. Delete the full stop after “such as”. Referred to EG1MT23: See DE01

28 NL06 54 ed Incorrect point after the words ‘such as’. Delete point after the words ‘such as’. Referred to EG1MT23: See DE01

29 CH05 55 22.XX ed Typo. Delete the full stop after “and gates”. Referred to EG1MT23: See DE01

30 DK04 55 22.XX NOTE 2 ed In the examples some products are now missing due to deleting “etc.” from the text of 61/5581/CD

Reinsert “etc.” so the text is like “… shutters, blinds, gates etc. to open …” or include “doors and windows” in instead.

Referred to EG1MT23: See DE01

31 NL07 55 ed Incorrect point after the word ‘gates’. Delete point after the word ‘gate’. Referred to EG1MT23: See DE01

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32 SE04 56 22.xx te Also exclude “audible and visible feedback” that may be needed by from the display or a similar device accordioning to 22.55.

Add this to the end of line 56: Audible and visible feedback that may be needed for the user interface according to 22.55 are also excluded.

Referred to MT23

MT23: not accepted for part 1, may be for special parts 2.

33 IT04 57-60 22.XX te The chapter b) takes in consideration the cases not addressed in chapter a. The compliance criteria for chapter b) is generic and can create misunderstanding.

Replace the sentence with the following:Compliance is checked by inspection of technical documentation and by the requirements and tests in Annex XY.

Accepted

MT23: Not accepted, the compliance criteria is already addressed in line 66 for chapter a) and b)

34 NL08 59 ed The use of the word partitioning is not correct here. The condition under item b) is whether the one software part is separated from another software part.Partitioning may be a solution to provide separation.

Delete the words ‘or partitioning’ in line 59. Referred to MT23

MT23: Not accepted, see Annex R.3.2.2.1 and the Guidance document lines 762 to 776.

35 NL09 59 re The criteria to judge if sw is properly or improperly separated are not given.This will lead to different judgement criteria between different parties using the standard.NLNC assumes that only the use of separate modules for the different software parts is NOT considered to provide proper separation as still a single compiled HEX file is loaded into the programmable device which contains both the SR and NSR modules.

Add the inspection criteria to determine proper separation.

Referred to MT23

MT23: Not accepted, see comment 33.

36 FR02 62, 64 te It shall be clarified that the requirements are not applicable to appliances that meet one of the criteria of lines 62 to 65

Add 'or' at the end of the lines 62 and 64 AcceptedMT23 observation:Accepted.

37 CH06 65 22.XX ed Wrong formatting. Format “message” in bold. Referred to EG1MT23 observation:Accepted.

38 CH07 70, 72 R.2.1 ed Typo. Replace “Replace” with “replace”. Referred to EG1MT23 observation:Accepted.

39 IT05 70 R.2.2.4 Table R.1 ed The fault/error (column 2) in row 6.3 (Timing), the words "wrong sequence" shall be aligned with "logical monitoring".

Move up the words "Wrong sequence" as indicate in Annex to IT05.

Referred to EG1MT23 observation:Accepted.

40 CH08 79, 91, 108

R.2.2, R.3.4

ed Typo. Insert a full stop at the end of sentence. Referred to EG1MT23 observation:Accepted.

41 IT06 90 R.3.4.1 ed The ID can be Numeric or Alphanumeric. Modify the sentence as follow:NOTE: The use of a version ID number (or Alphanumeric), if unique, is one possible solution.

The Note does not preclude using an alphanumeric identifierMT23 observation:Accepted.

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42 IT07 95 R.3.4.2.1 ed The first dash is covered by third dash. Delete the first dash. Accepted

MT23: Not accepted for keeping the first dash.

43 SE05 117 Annex XY ed Make clear that modification in annex XY are to this standard.

Change from “The measures given” to “The following modifications to this standard”

Referred to EG1MT23 observation:For 43, Not accepted, because Annex XY is not a modification of the requirements in the body of standard. But rather in addition for appliances which communicate through the public network.

44 NL10 120-121 Annex XY te/ed It should be added that, besides privacy and data confidentiality, any undesired change in appliance operation is also not covered by annex XY.Appliances may be equipped with features to change operational parameters (e.g. hood speed setting or turn on / off the appliance function) via remote communication through public networks. As for some applications malfunction of such features may affect human wellbeing (e.g. central heating appliances) or even health (e.g. refrigerators, it must be clear that this aspect is not covered by annex XY.

Change the sentence into:However, in general, it does not cover aspects concerning undesired change of appliance operation, confidentiality of data and consumer privacy.

Referred to MT23

MT23: not accepted because undesired operation of appliance is too general. It may or may not affect the compliance of this safety standard of appliance. MT23 recommends not to expand this sentence as explanation for this exclusion is provided in the guidance document..

45 CH09 144, 146

XY.3.106 ed Wrong formatting. Format “message” in bold. Referred to EG1MT23 observation:Accepted.

46 SE06 144 XY.3.106 ed Defined term is used. Change “message” to bold Referred to EG1MT23 observation:Accepted.

47 SE07 146 XY.3.106 ed Defined term is used. Change “message” to bold Referred to EG1MT23 observation:Accepted.

48 NL11 147-159 XY.3.107 ed/te Identification procedure seems to be the same / similar to authentication (XY.3.102). If there are differences between the two then these are not clear from the definitions.Note that the 2 terms are also used combined in the guidance doc 61/5761/DC, lines 777-792.

Merge the two definitions. If differences do really exist then the differences between the two need to be made clear in the definitions.

Referred to MT23

MT23: Not accepted.See also comment 64.

49 CH10 151, 154

XY.3.107 ed Typo. Delete superfluous dashes. Referred to EG1MT23 observation:Accepted.

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50 CH11 151 XY.3.107 ed Wrong formatting. Unbold “and” after “source”. Referred to EG1MT23 observation:Accepted.

51 CH12 157 XY.3.107 ed Typo. Insert “as” before “expected”. Referred to EG1MT23 observation:Accepted.

52 NL12 182-187 XY.22.102 te XY.22.102 requires means to provide data integrity protection in five bullets (lines 183-187), but also requires measures to control faults/errors according Table R.1. Item 6 of Table R.1 also specifies measures for data integrity of external communication.Now it is unclear how the relationship is between item 6 of table R.1 and the data integrity requirements from XY.22.102. Would compliance with R.1 item 6 mean compliance with the data integrity requirements from XY.22.102? And what faults needs to be taken into account for e.g. data corruption from XY.22.102 – data corruption up to hamming distance 3 as indicated in item 6?

The requirements need to be made clear and how the requirements can be fulfilled (compliance with Table R.1 item 6?).

Referred to MT23

MT23: The given requirements in XY.22.102 are sufficient structured.

53 CH13 187 XY.22.102 te Redundant requirement. Replace the full stop after “data transfer” with “, or”.

Referred to MT23

MT23: not accepted. The three dashed items are different aspects and applies each.

54 CH14 188 XY.22.102 te Redundant requirement. Replace “and” with “or”.Explanation/rationale:Using state-of-the-art cryptographic protocols like SSL/TLS ensures authenticity and integrity of remote communication, including protection against disturbed communication. If a fault/error condition like stated in Table R.1 occurs, the remote communication over SSL/TLS will not be successful.Therefore, the requirement to implement measures to control the fault/error conditions specified in Table R.1 is redundant, if cryptographic protocols like SSL/TLS are used. The requirement would restrict the choice of CPUs considerably, as most commonly used CPUs for IoT applications have no support for Annex R libraries.

Referred to MT23

MT23: not accepted.

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55 NL13 192 XY.22.103 ed The current proposed text is prescriptive in the technology (software) to be used to comply with the requirement which should not be the case.The word ‘software’ has no added value for the requirement.

Delete the word ‘Software’. Referred to MT23

MT23: not accepted. The given wording makes it clearer.

56 NL14 193-194 XY.22.103 ed The phrase ‘which is considered to be normal operation’ adds no value to the requirement. Such phrase is not present in any other XY requirements etc.

Keep requirement simple and clear: delete the words ‘which is considered to be normal operation’.

Referred to MT23

MT23: not accepted, but modify the text as follows after the comma:‘which are considered to be normal operating conditions’.

57 CH15 197, 198

XY.22.104 ed Too small font size, missing full stop at the end of sentence.

Correct font size and insert a full stop. Referred to EG1MT23 observation:Accepted.

58 CH16 198 XY.22.104 ed Wrong formatting. Format “cryptographic techniques” in bold. Referred to EG1MT23 observation:Accepted.

59 SE08 198 XY.22.104 ed Defined term is used. Change “cryptographic techniques” “ to bold Referred to EG1MT23 observation:Accepted.

60 NL15 202 XY.22.105 ed The words ‘hardware/software’ have no added value for the requirement.

Delete the words ‘Hardware/software’. Referred to MT23

MT23: Not accepted. The given wording makes it clearer.

61 NL16 202-203 XY.22.105 ed/te The requirement for detection of transmission faults/errors seems to be already fully covered by the data integrity requirements of 22.102.

Change the requirement into:Hardware/software measures shall be taken to prevent unauthorized access and detection of transmission faults/errors in the remote communication.

Referred to MT23

MT23: Not accepted. Table XY.1 uses this term (transmission faults/errors)

62 JP02 203 XY.22.105 1 ed The word “transmission faults/errors” may be replaced by disturbed communication, which is defined by clause XY.3.106. The term disturbed communication is used by clause XY.22.102 only once in CDV, so it should be further used as appropriate.

Replace the word as follows.

XY.22.105 Hardware/software measures shall be taken to prevent unauthorized access and detection of transmission faults/errors disturbed communication in the remote communication.

Referred to EG1

MT23 observation:Not accepted. EG1 is not necessary to consider. See comment 61.

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63 NL17 205-207 XY.22.105 Table XY.1 te The table gives examples of treats and measures. As these are only examples it is unclear if all these threats shall be covered or not. This will lead to different approach between parties using the standard.We would suggest to make table XY.1 normative instead of providing examples only, similar to e.g. table R.1.

Modify the last sentence of XY.22.105 as follows:Compliance is checked by evaluation according to XY.22.102 and Table XY.1.

Delete the note in line 205.

In the header of table XY.1 (line 206) delete the words ‘examples of’.

Also XY.22.102 should refer to table XY.1 for the measures for data integrity protection. Therefore modify the last sentence of XY.22.102 as follows:Compliance is checked by the inspections and tests of the software architecture in R.3.2.2 of Annex R and evaluating the software in accordance with R.3.3 of Annex R and Table XY.1.

Referred to MT23

MT23: accept to add table XY.1 to the compliance criteria and to delete NOTE in line 205.

Not accepted to delete the word “Examples” in the title of Table XY.1.

Not accepted to add “Table XY.1” to sub Clause XY.22.102.

64 NL18 205-207 XY.22.105 Table XY.1 ed Some of the measures indicated in the table are explained by a definitions in XY.3 (identification procedure, cryptographic techniques) while others are explained by a footnote in the table.

As the terms ‘identification procedure’ and ‘cryptographic techniques’ are exclusively used in table XY.1, NLNC suggest to delete clauses XY.3.104 and XY.3.107 and transfer the content to new footnotes in table XY.1

Not accepted for XY.3.104 as the term is used more than once. XY.3.107 is only used in the table so its repositioning is accepted.MT23 observation:Accepted, and Note 1 will be moved to the guidance document.

65 NL19 205-207 XY.22.105 Table XY.1 te The terms used for the measured explained by footnotes b to g are explained insufficiently. E.g. more information is needed what is meant with the measures and how they can protect against the threats. E.g.: ‘feedback message’ how this can protect against masquerade?

Extent the footnotes b to g with a better definition / description of the term / measure. Possibly with additional support from the guidance documents (where this info is also lacking currently).

Referred to MT23

MT23: NL-NC is invited to make a proposal if necessary.

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66 CH17 206 Table XY.1 ed Wrong formatting. In the first column format h as superscript;in the second column delete comma after superscript i;delete “the appliances covered by” before “IEC 62280” in first row below the table containing a lot of Xs;in the line of superscript a delete the full stop after “6”;in the line of superscript f format “entity” in bold;in the lines of superscript a, b, c, e, g and h: insert a full stop at the end of each sentence.

Referred to EG1MT23 observation:Accepted.

67 CH18 206 Table XY.1 ed Wrong formatting. Format “message(s)” in bold (twelve times). Referred to EG1MT23 observation:Accepted. See comment 45.

68 CH19 224, 227 to 228

XY.22.108 te Redundant requirement. Replace “- against corruption through communication;” by the following: by means to detect and respond to

disturbed communication; or by data integrity protection; or by means to control the fault/error

conditions specified in Table R.1.Delete “Additionally, the software … fault/error conditions specified in Table R.1.”Explanation/rationale:A state-of-the-art measure to detect corruption through communication is the use of cryptographic techniques, either to provide data integrity protection (see XY.3.105, e.g. code signing), or to provide measures against disturbed communication (see XY.3.106, e.g. cryptographic protocols like SSL/TLS).A secure way to verify compatibility of a software version with the appliance is to consult a mapping of software versions and its compatible appliances on a server through authenticated, secure and reliable remote communication using cryptographic protocols like SSL/TLS.

Referred to MT23

MT23: Not accepted, because these measures are not alternatives.

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69 JP03 225 XY.22.108 1 ed The word “software version” may be replaced by software version identifier, which is defined by clause XY.3.108. The term software version identifier is used by clause XY.7.12.101 only once in CDV, so it should be further used as appropriate.

Replace the word as follows.

– that the software version software version identifier is compatible with the appliance for which the software version was designed.

Not accepted. It is the software version that must be compatible not its identifier.MT23 observation:Accepted..

70 SE09 231 XY.22.109 te The term “person responsible” is unclear.Shall there be a password to avoid non-appliance responsible person to update the software. Even if the user isn’t using remote communication?

Change from “person responsible for the appliance. “to “ user.”

Not accepted – the user could be a hotel guestMT23 observation:Accepted the secretariat comment.

71 FR03 231-232 te 'XY.22.109 Permission for each installation of software in the appliance shall be given by the person responsible for the appliance'

As for compliance to this clause it is not possible to identify who will act to give the permission, the requirement should be limited at the means implemented in order to deliver the function of permission.Nevertheless, the change ‘user’ by ‘person responsible’ is not in line with the requirement of XY.7.12.101 where instruction for software update shall be given to the user.

Proposal:

'XY.22.109 Means shall be provided in order to allow permission for each installation of software by the responsible of the appliance. Instal lat ion shall not occur before the permission is given. '

Referred to MT23

MT23: Not accepted, it is discussed a lot of times in MT 23.Keep the text as in CDV.

72 IT08 231-232 XY.22.109 te The customer shall decide if the permission should be given at either every installation or just the first time, when the remote communication has been performed.Also, for the commercial appliance (in particular in public area), the permission for each installation can affect negatively the performance of the appliance preventing the functionality of SW download.

Modify the sentence as follow:Permission for installation of software in the appliance shall be given by the person responsible for the appliance at the first remote communication or each installation in according to manufacturer instruction of clause XY.7.12.101.

Not accepted. This doesn’t take into account a possible change to the person responsible for the appliance.MT23 observation:Accepted the decision.

73 US01 231-232 XY.22.109 te It is common to allow for permissions to be granted during the initial setup of the appliance for all future updates. This allows the user to waive the need to give permission for each update. This is preferable with updates to address safety concerns.

Add the following to the beginning of line 231:

Unless permission is given for all installations during the initial appliance setup for remote communication,

See comment 72

MT23 observation:Accepted the decision.

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74 SE10 232 XY.22.109 te It shall be possible to set the appliance in automatically update mode if the user wants that.

Add to the end of line 323. But its allowed to have the possibility to turn on automatically software updates.

Not accepted, See comment 70MT23 observation:Accepted the decision.

75 US02 237 XY.22.110 te What is “relevant testing?” Without any definition around what testing needs to be done to verify the software download has not affected safety, it may range from a operational test to repeating all required tests.

Replace “relevant testing” with “testing to determine compliance with clauses 8 to 32, as needed”

Referred to MT23

MT23: Not accepted. The relevant testing depends on the kind of installation. In general, it is a test which verifies that the new software is installed correctly considering if the installation takes place in parallel to the operation of the appliance or in a non-operational mode.But add in between ‘of’ and ‘software’ the word ‘the’.

76 DK05 627 61/5761/DC

Guide ed Here is stated the “entire” standard in reference to clauses 8-32. If DK01 is accepted a change is also needed here.

Change “clauses 8 to 32” to “clauses 7 to 32”.Also need to be changed in line 654 and 666

See comment 21MT23 observation:Accepted.

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Annex to IT05

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