In message <p06230916c06c146a6ccd@[192.168.1.62]>, dated Wed, 19 Apr 
2006, Nick Williams <[email protected]> writes
>I do not agree. This approach may work for the LVD but it will rapidly 
>lead to a dead end when applied to equipment within the scope of the 
>Machinery Directive.

Well, I was surprised to read what you wrote, because it's regularly 
spot-on.
>
>The approach to the use of standards defined in the Machinery Dorective 
>is somewhat different to that which is normally applied under the LVD. 
>Crudely put, the Machinery Directive approach to standards is to use 
>the bits which are relevant and to ignore the bits which are not. EN 
>60335-1 is listed under the Machinery Directive in the OJ and so I can 
>see no difficulty whatsoever is using  relevant parts of it to 
>demonstrate compliance with the EHSR's of the Directive.

I consider that a dangerous defect in the MD, then.

>It may well be that additional measures are also required, but this is 
>a judgment that the individual user will have to make.

Yes, and bear in mind that safety committee experts on household 
appliances may amend or revise the standard so as to make his product 
non-compliant without him ever knowing about it.

Also, in the vent of a challenge to the product's conformity, the 
manufacturer is immediately on the defensive, trying to justify the use 
of a standard that ids intended for quite another sort of product.
>
>In any event, from the scope of EN 60335-1:
>
>"Appliances not intended for normal household use but which 
>nevertheless may be a source of danger to the
>public, such as appliances intended to be used by laymen in shops, in 
>light industry and on farms, are within
>the scope of this standard."
>
>which seems to pretty clearly open the possibility that this product is 
>within the scope of EN 60335-1 even if it is not a 'household 
>appliance'.
>
>
I regard that as desperately bad standardization. It opens the scope to 
embrace ANYTHING. This has already raised serious issues when it was 
copied into EN 50336 on EMF emissions.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
2006 is YMMVI- Your mileage may vary immensely.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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