Folks,

If you are interested in safety requirements within Europe you may wish to
take a look at the following URL:

http://europa.eu.int/eur-lex/pri/en/oj/
at/2003/c_297/c_29720031209en00210022.pdf

This is titled "COMMISSION OPINION of 8 December 2003 within the framework of
Council Directive 73/23/EEC relating to electrical equipment designed for use
within certain voltage limits - Safety of cable reels (2003/C 297/06)"

You will see that the specific case referred to is the failure of Harmonised
Standard EN 61242 "Electrical accessories - Cable reels for household and
similar purposes" to meet Directive 73/23/EEC (the LVD) in that it "is not
regarded as giving a presumption of conformity with regard to the risk of fire
and of electrical shock in cases of foreseeable overload".  

As a consequence, the European Commission has asked (polite for told!) CENELEC
to revise this standard to ensure that the above mentioned risks are
adequately addressed.  Until such time that a revised Harmonised Standard is
available, manufacturers of cable reels will have to make an additional risk
assessment in order to ensure that the risk of fire and electrical shock, in
cases of foreseeable overload, are adequately addressed.  Only once such an
assessment has been made by the manufacturer will it be possible to state that
compliance with the requirements of the Low Voltage Directive has been
achieved.

Finally, the opinion requires that "Member States' Authorities take account of
this opinion in the context of market surveillance."  In other words, the
surveillance authorities throughout the EU are put on notice that they should
look out for cable reels and confirm with the manufactures that they have
performed the above mentioned risk assessment, in addition to complying with
the Harmonised Standard.  Non conforming products can of course be taken off
the market and the manufacturers prosecuted.

Notes: 

1) If I recall correctly, the "cable reels" in question are essentially the
type of extension reels for portable tools etc. that are rolled onto a drum.

2) The term 'manufacturer' above is as described in the Blue Book covering New
Approach Directives.  As such, it includes e.g. companies that 'own brand'
products produced by OEM suppliers.


Of course, the bigger picture is that complying with a Harmonised Standard is
not the be all and end all (i.e. all that needs to be done) as regards CE
marking.  It is also a large responsibility for those involved with writing
such standards (bloated or otherwise!).

This is certainly not the first such case that I am aware of, but the
fallibility of Harmonised Standards and the possibility of an action resulting
in the need to withdraw a product from across the whole of the EU if it fails
to comply with the safety objectives of the LVD may be new to some.

Regards,

Richard Hughes

Safety Answers Limited
www.safetyanswers.ltd.uk



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