Ralph
The wording of Article 8 is as follows:
"2. In the event of a challenge, the manufacturer or importer may submit a
report, drawn up by a body, which is notified in accordance with the procedure
set out in Article 11, on the conformity of the electrical equipment with the
provisions of Article 2"
Note the use of the word "may", and NOT "shall", in respect of the the
Notified body report - i.e. it is not compulsory but it could help!
In this respect the wording of current LVD is different to the current wording
of the EMC Directive where the "shall" requirement does apply; but the "shall"
requirement will not appear in the next edition of the EMC Directive, and
neither is there a similar "shall" requirement in respect of the Machinery
Directive for most equipment.
Therefore the LVD "essential requirements" route does not mandate the
involvement of a Notified Body, but you still need plenty of experience to
approach compliance by this route. It can be very useful if you are dealing
with an "oddball" item where there are no specific standards, and/or where it
is a "one-off" where the cost of full standards compliance testing may be
prohibitive but compliance with the Directive can be relatively easily
confirmed by other means.
It can also be very useful where you want to use a piece of equipment intended
for one environment in a different environment and you may thus need to apply
additional, or different, precautions to ensure that it is safe in the latter
environment. Under those circumstances compliance with the original standards
may well not be enough, e.g. the use of "Commercial Off the Shelf" (COTS) ITE
in a non-benign military environment or the use of "industrial equipment" in a
"commercial" environment.
Under these circumstances, you may also need to do other tasks, notably
appropriate risk assessments, design changes, additional protection
/instructions / warnings / restrictions on use and users, etc. If you do use
a Notified Body or other experienced organisation to assist you in these
areas, then make sure they know the target environment and its particular
issues.
Anyway, don't forget that under the LVD and all the other CE Directives, even
compliance with a harmonised standard is not enough on its own. You are also
required to include in the technical documentation all of the other "difficult
things", like giving design and operating information, showing how you control
production and production testing etc. This area is another where you need the
experience and knowledge of what to do and how to do it, and applies whether
you use a Notified Body for the basic product compliance, or not.
Regards
John Allen,
Technical Consultant
EMC and Safety Engineering
ERA Technology Ltd.
Cleeve Road
Leatherhead
Surrey KT22 7SA
UK
Tel: +44-1372-367025 (Direct)
+44-1372-367000 (Switchboard)
Fax: +44-1372-367102
Please take a minute to visit my web pages at
http://www.era.co.uk/services/rcm.asp
and the main ERA Website at http://www.era.co.uk
-----Original Message-----
From: Ralph McDiarmid [ mailto:[email protected]]
Sent: 18 August 2004 23:21
To: [email protected]
Subject: RE: LVD and its safety objectives
http://www.ieee-pses.org/symposium
http://www.emc2004.org/
--------------------------------------------------
It appears that using harmonized standards for a "presumption of conformity"
to the LVD is not the only route to compliance. Article 8 and Annex I of
that directive appear to provide an "essential requirements" route similar
to that available in the EMCD.
A technical file (perhaps more accurately, a TCF) is put together by a
manufacturer and then audited by a Notified Body. (exactly as you would do
in order to claim compliance with the protection requirements of the EMCD
using a Competent Body). The employ of a certified body is thus necessary
and proper in this case to ensure the safety objectives of the LVD are
satisfied.
This seems a reasonable approach, particularly so for industrial equipment,
and it may alleviate the necessity of retesting and reissuing a DofC ever
time a harmonized standard is revised.
This approach wouldn't please all customers, however, and so a manufacturer
might be pressured to update their DofC and test reports regardless.
This is a point I wanted to raise at the PSES symposium, but I could not
find an appropriate moment.
Comments from the group?
Ralph McDiarmid, AScT
Compliance Engineering Group
Xantrex Technology Inc.
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