All,
Paragraph C4 in cfr 1020.40 States: " Each door of a cabinet X-Ray
system shall have a minimum of two safety interlocks.
One, but not both of the required interlocks shall be such that the door
opening results in physical disconnection of the energy supply circuit to
the high voltage generator, and such disconection shall not be dependent
upon any moving part other than the door".
I see this as an end result and not stating explicitly the "how" to
accomplish the end results. If that is correct, can a low voltage relay be
used to control another relay which has a set of contacts that when
activated, removes the energy supply circuit to the
high volatage generator? This combination would make up "one" of the two
safety interlocks required. This may seem a round about way to have two
interlock circuits but its the design that was inherited when my Company
purchased the product line from another manufacturer. Currently Im in the
process of filling out the initial report for the FDA and Im curious if this
design is acceptable and not require a change to meet the intent of
paragraph C4.
Bob Chaplis
Genrad.
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