Friends,
I couldn't resist sharing with you this emanation from the fertile brain
of our good friend Gregg Kervill:
An Irrational Guide to Electrical Safety and the LVD.
Release date April 1st.
The Low Voltage Directive
We will start by taking a top-level look at the Low Voltage
Directive (LVD) and some of its implications:
Considerations
The LVD has been about since 1973: therefore after more than 24
years we know all there is about it and can therefore safety ignore
it. Alternatively we may consider that there are already a
significant number of people killed by electrocution and that if our
product kills only a few more that it wouldn't make much difference
- statistically speaking - that is.
The CE Mark
Products within the scope of the LVD must be marked with the CE Mark.
The committed Europhile will have included the additional very tiny
letters "a-v-e-a-t" and "m-p-t-o-r" amongst the letters C and E to
produce that universal warning to all of his customers. (Viz.
"Caveat Emptor" = Let him beware.) The advantage of using a "dead"
language for warnings is that will be universally unrecognised by
the very people that they are intended to help - but will favour the
elite and educated and hence protect our own "Kith and Kin".
The Responsible Person
Always appoint the least technically competent employee for the task
of Responsible Person.
It is equally important to ensure that they can be easily
intimidated; will help suppress concerns that a potential
non-compliant product has been in production for the last 15 years;
and that they will continue to sign Declarations of Conformity
despite a series of memos and reports for the quality department and
other conscientious employees.
The "Data File"
The "data file", legally required by the LVD is no problem to the
seriously minded.
True the requirements to hold information that clearly (and
publicly) identifies non-compliances against European Harmonised
standards could be seen as a 'bit negative' (in marketing terms)
but a careful review of the many hundred of harmonised standards
should yield a few to which we can claim compliance - even if they
relate to the pulp content of our user manuals and not to the
product itself.
It is well known that there is no need to review, test or consider
any safety features of products outside the scope of the LVD - as it
is perfectly reasonable to place potentially dangerous products on
the market: provided that they are not CE Marked.
Being Sued
Only the 'wimps' worry that they may be sued by people injured by
their products. The "real-men" take confidence in their design
capabilities. If the product is not compromised to pander to the
requirements of product safety - life is beautifully simple: there
will be no survivors and therefore no-one to sue. Hence there is no
problem. Quod Erat Demonstrandum! Furthermore the lack of
customers is nothing to do with engineering and the blame can be
placed squarely at the door of the marketing and sales departments.
A Look in Detail
Next we will take a look at some of the more detailed requirements
contained in some of the widely used Harmonised Standards - the
Eight Principles relating to Hazards.
Knowledge:
Avoid training and employ only junior staff - this will ensure that
product safety is NOT consider early in the design and therefore
will save huge amounts of money. Having spent the entire budget we
can then bully the Responsible Person (see above) into signing the
release documentation.
Electric Shock
Committing the purchasing department to buying critical components
(e.g. power supplies) that carry an agency approval is restrictive.
The purchasing department must be given total freedom to buy from
the cheapest - third-world sources. We all know that the final
selling price is the MOST important thing to achieve.
Energy Hazards
It has been scientifically proven that subjecting the Operator to
circuits delivering more than 8 Amps, 240 VA, 60 Volts or 20 Joules
keeps them more vigilant and they work harder. True there may be a
few deaths or injuries caused by these energies but these are
usually restricted to the old, ill or infirm. It's nothing to do
with us or with our product.
If we are really clever and have a 48 Volt supply from 200 kg of
lead acid batteries we may be able to get our customer to create the
hazard. All we do is to over-emphasise the fact that the operator
outputs are Safety Extra Low Voltage (SELV). Most of our clients
will be unaware that only Safety Extra Low Voltage Energy Limited
(SELVEL) may be contacted by the operator: and it shouldn't be long
before someone discovers that the fault current in these external
circuits could be more than 2,000 Amps.
Fire
Use the thinnest section of plastic that it is possible to mould.
Make sure that the purchasing department specify only the colour of
the plastic - this will usually guarantee that the cheapest - most
flammable materials are sourced. Avoid metal at all costs - it is
heavy, expensive stuff and takes away from the designer the
opportunity to inflict his individuality upon an unsuspecting world.
As Parkinson so eloquently put it "What can go wrong will go wrong."
So if we start from this premise then the occasional fire will
happen. This could be good; as it will burn up some of the surplus
rubbish and make a positive contribution to society.
Mechanical Hazards
The equipment should fall over if tilted to 8 degrees from the
vertical; pushed, leaned or stepped on; sneezed at; or whenever any
of its doors are opened.
All edges should be razor sharp to dissuade operators and other
unwelcome rascals from touching and spoiling our creation and work
of art.
Under no circumstances should we include handling processes in the
installation instructions - this would take all the fun away from
the commissioning and service engineers.
Heat Hazards
The true artist will ensure that by placing a single sheet of paper
over any of the air vents will raise the internal temperature above
the maximum operating temperature of all the critical components and
(what is more important) of the internal wiring.
A little attention to detail here will ensure that the insulation
between hazardous (e.g. mains) voltage and 'operator contactable'
Safety Extra Low Voltage (Energy Limited) will fail and that every
output will be at mains potential.
Radiation Hazards
Radiation is good for you - remember the X-ray machines in the shoe
shops; I used to like watching the bones in my toes wriggling. Why
ever did they take them out of the shops?
Chemical Hazards
Never use harmless materials when we can use a known carcinogen
instead. The best ones are fine powders (like toners) and if we are
careful with our design we can make it impossible to refill or
replace the toner cartridge without spilling some each time. Here
comes the best bit - we don't make it clear that by using a
conventional vacuum cleaner to clear up the mess the carcinogen will
pass through the vacuum cleaner bag and directly into the atmosphere
where dozens of workers can be affected - perhaps even permanently.
In Conclusion
I apologise unreservedly to anyone who is offended by the above
deliberation - it is not intended to antagonise, berate or demean.
My only wish would be to report that the stories I have related were
fictitious: unfortunately they only a representative sample of
non-compliances that I have come across - some on a weekly basis -
and a couple that I myself committed - long, long ago: before I knew
better.
Gregg Kervill
G.K. Consultants Ltd. - Specialists in Product Safety and CE Marking.
P.O. Box 678, Southampton, Hants. SO16 7RJ. England
Personal: [email protected] Mobile +44 (0) 802 466266
Business: [email protected]
--
Bill Lyons - [email protected] / [email protected]
