Chris,
Thank you for a very helpful reasoning tool and example.
I would also like to point out that electric pencil sharpeners, erasers,
paper shredders and other such electrical office equipment is covered under
the scope of IEC950/EN60950, 1.1.1.
Tania Grant, Octel Communications Corporation
[email protected]
______________________________ Reply Separator _________________________________
Subject: RE: ITE or Machine?
Author: Chris Dupres <[email protected]> at P_Internet_Mail
List-Post: [email protected]
Date: 4/26/97 2:41 AM
Hi Richard.
You wrote:
<Since there are moving parts, this product is obviously a machine. It
must be determined if the product is subject to the Low Voltage
Directive. Failing that, it must be subject to the Machinery Directive.
One can argue that the product is mains powered and therefore subject to
the Low Voltage Directive. It can also be argued that the transformer is
subject to the Low Voltage Directive, but the table top unit with the
moving parts is powered by a voltage level that is outside the scope of
the Low Voltage Directive and is therefore subject to the Machinery
Directive. Which argument is correct?
>
My approach is to simply identify whether the risk to people, domestic
animals and property is primarily Electrical, or Mechanical. Using a
formal risk analysis procedure helps the paperwork. Consider two
electrically powered machines which use blades...
A food processor has flailing blades that could do serious damage to those
categories, but you could still get a shock if there was a fault. In this
case the biggest risk is mechanical, so I would use the Machinery
Directive.
An electric pencil sharpener is unlikely to do much damage to people or
things, unless you have very small fingers. The biggest risk here is
probably that of electric shock, so I would use the Low Voltage Directive.
In your technical file, you place your analysis and make a formal statement
that you have built to the xxxxx standard. That should satisfy the
regulatory authorities, and the Judge, that you have complied with
protection requirements.
Chris Dupres
Surrey, UK.
