Hi Richard
My response to this type of question is generally along the lines of:
a) If the product falls under the R&TTE Directive, then the LVD route - and
thus 60950/60825 - is mandated anyway.
b) If the product does not fall under the R&TTE Directive but some other
New Approach or other Directive, then the latter applies and may affect the
standards to be applied.
c) If the product does not fall under any specific Directive, then it is
still subject to the Product Liability Directive and - more importantly -
the General Product Safety Directive (92/59/EEC), of which Article 3 places
the following general responsibilities on suppliers:
- only place safe products on the market,
- provide users with appropriate safety instructions and warnings,
- be fully aware of the types of risks posed by their products and apply
appropriate precautions in the design, manufacture, labelling and
safety-issues-monitoring thereof
- be able to perform product safety alerts and/or recalls as necessary.
Article 4, sub-Articles 1 and 2, then gives several options to ensure
compliance, thus (as I read the text):
4.1 Where no specific EC regulations (etc.) exist then compliance with the
legal requirements in each Member State in which the product is marketed or
used;
4.2 Where, in addition to lack of EC regulations (etc.), there are no
national legal requirements in Member States, then compliance with
voluntary EC standards, or with national standards and/or codes of good
practice, of the countries in which the products are marketed or sold.
Thus application of "due-diligence", risk-assessment, and compliance with
appropriate national legislation and voluntary standards are the main
routes to compliance with this directive.
To me all the above read as:
- "Do exactly the same for the 24V (etc.) product as you would do for the
230V product."
The shock hazard may not exist - but the secondary circuits of both
products could be identical, thus the fire and laser issues are identical,
and thus so are the solutions in order to comply with the "due dilegence"
(etc) issues.
Let's see what other people think!
The above opinions are my own interpretations, but are those I promote
within our company.
John Allen
Product & System Safety Manager
Communications Division
Racal Defence Electronics
Bracknell
----------
From: [email protected][SMTP:[email protected]]
Sent: 07 December 1999 21:23
To: [email protected]
Subject: Products with high power LEDs
Assume a business product with a high power LED for use in the EU and that
it operates at 230V. It will be subject to the Low Voltage Directive, so
EN60950 and EN60825-1 would apply. Now assume a similar product but it
operates at 24V. The LVD would not apply in this case. What are the legal
compliance requirements for the LED output?
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