Doug, my recommendation is to obtain approval marks for the US and Canada
due to the potential of litigation. You will have shown due diligence which
may assist in limiting any liability issues. In the EU, however, they have
"no-fault" liability - if someone is hurt by a defect in your equipment, you
are at fault no matter what approvals you have. A safety approval in Europe
is for useful for marketing purposes only.
Richard Woods
----------
From: Massey, Doug C. [SMTP:masse...@ems-t.com]
Sent: Monday, June 04, 2001 8:47 AM
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: masse...@lxe.com
Cruise our website at: http:\\www.lxe.com
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Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/
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All emc-pstc postings are archived and searchable on the web at:
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