EN60950 would apply, under the general product safety directive, however,
you would not be required to CE mark the item.

The directive is
                                                                            
 Council Directive 92/59/EEC of 29 June 1992 on general product safety      
 http://europa.eu.int/comm/consumers/policy/developments/prod_safe/ps02_en. 
 html                                                                       
                                                                            
 In specific...                                                             
                                                                            
 Article 4                                                                  
                                                                            
                                                                            
 1. Where there are no specific Community provisions governing the safety   
 of the products in question, a product shall be deemed safe when it        
 conforms to the specific rules of national law of the Member State in      
 whose territory the product is in circulation, such rules being drawn up   
 in conformity with the Treaty, and in particular Articles 30 and 36        
 thereof, and laying down the health and safety requirements which the      
 product must satisfy in order to be marketed.                              
                                                                            
                                                                            
 2. In the absence of specific rules as referred to in paragraph 1, the     
 conformity of a product to the general safety requirement shall be         
 assessed having regard to voluntary national standards giving effect to a  
 European standard or, where they exist, to Community technical             
 specifications or, failing these, to standards drawn up in the Member      
 State in which the product is in circulation, or to the codes of good      
 practice in respect of health and safety in the sector concerned or to the 
 state of the art and technology and to the safety which consumers may      
 reasonably expect.                                                         
                                                                            
                                                                            
 Per article 2, you are still required to conform with a European standard, 
 or community technical specification, or member state standard, or to      
 codes of good practice (i.e., industry standards), in that order of        
 preference.                                                                
                                                                            
                                                                            
 Best regards,                                                              
                                                                            
                                                                            
 Frank West                                                                 
                                                                            




---[From the computer of...]-----------------------------------------
Mr. Frank West
Sr. Engineer
TUV Rheinland
7853 SW Cirrus Dr.
Beaverton, OR. 97008
T 503-469-8880 Ext 205
F 503-469-8881
[email protected]



                                                                                
                                             
                    "Massey, Doug C."                                           
                                             
                    <[email protected]>           To:     "'IEEE Forum'" 
<[email protected]>                      
                    Sent by:                       cc:                          
                                             
                    owner-emc-pstc@majordom        Subject:     RE: Product 
Safety: A Matter of Law or Litigation?           
                    o.ieee.org                                                  
                                             
                                                                                
                                             
                                                                                
                                             
                    06/04/2001 10:24 AM                                         
                                             
                    Please respond to                                           
                                             
                    "Massey, Doug C."                                           
                                             
                                                                                
                                             
                                                                                
                                             





Alex,
Thanks for your reply, and I agree. However, I don't need convincing.
Here's
the rub - EN60950 is a harmonized standard under the LVD. If the LVD does
not apply to the product, then how can I argue that EN60950 applies to the
product?

Doug

-----Original Message-----
From: Alex McNeil [mailto:[email protected]]
Sent: Monday, June 04, 2001 12:14 PM
To: 'Massey, Doug C.'
Cc: 'IEEE Forum'
Subject: RE: Product Safety: A Matter of Law or Litigation?


Doug,

As a general rule you should always have your products "Safety Approved".
This is showing Due Dilligence in that you have had the product safety
evaluated. The latest EN60950:2000 covers ..."mains powered or
battery-powered ITE ....with a Rated Voltage not exceeding 600V"  i.e.
there
is no lower voltage limit!

I hope this helps?

Regards
ALEX

 -----Original Message-----
From:     Massey, Doug C. [mailto:[email protected]]
Sent:     Monday, June 04, 2001 1:47 PM
To:  'IEEE Forum'
Subject:  Product Safety: A Matter of Law or Litigation?


Colleagues:

I have been tasked with justifying the need for independent, third party
evaluations of the safety of our company's products to applicable
standards.
Our company manufactures various ITE equipment, either handheld, battery
powered devices, or ITE devices powered by vehicle batteries. In
particular,
the scope of the LVD states that it is applicable to devices rated
50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market
these products in 35 countries; North America, the EU/EFTA, and others - in
fact, pretty much all of the countries participating in the CB Scheme.

In the US, OSHA regs justify this requirement, as our equipment is sold
through direct channels solely for logistics applications - in other words,
US workers will be using the equipment - it's not for general consumer use.
TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table
of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to
this subpart. Acceptable. An installation or equipment is acceptable to the
Assistant Secretary of Labor, and approved within the meaning of this
Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or
otherwise determined to be safe by a nationally recognized testing
laboratory; or (ii) With respect to an installation or equipment of a kind
which no nationally recognized testing laboratory accepts, certifies,
lists,
labels, or determines to be safe, if it is inspected or tested by another
Federal agency, or by a State, municipal, or other local authority
responsible for enforcing occupational safety provisions of the National
Electrical Code and found in compliance with the provisions of the National
Electrical Code as applied in this subpart; or ...

In the EU/EFTA, the justification is not so easy.  As I mentioned earlier,
the products are exempt from the LVD. The General Product Safety Directive,
and the Product Liability Directive, do not give me an easy justification,
such as in the case of the OSHA regs stated in US Federal Code. My company
has always had all products evaluated to the -950 standards, but has
observed that other manufacturers of similar equipment do not have their
products evaluated to applicable safety standards, and CE mark their
products based on compliance to the EMC Directive, but not to the LVD.

I would greatly appreciate your insights, opinions, and assistance with
this
question.

Doug Massey
Safety Approvals Engineer
LXE, Inc.
Norcross, GA., USA
Ph.  (770) 447-4224 x3607
FAX (770) 447-6928
e-mail: [email protected]

Cruise our website at: http:\\www.lxe.com



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