Our company makes laboratory equipment (the red-headed step child) which has no 
defined category of its own so it generally falls under the LVD unless it has a 
moving part to which it is now subject to the machinery directive (which is a 
new nightmare for me). But like many products produced these days, our products 
are built-to-order with dozens of variations and possibly hundreds of different 
combinations. We evaluate each model family in its maximum configuration with 
all possible variations installed for EMC and Safety which generally includes a 
sample loader or autoloader (moving parts). So we evaluate, test, and declare 
compliance to the Machinery Directive and generate a DOC for that product 
family.

Question #1

When a customer orders a configuration that does not include the sample loader 
(moving part), can we still declare compliance to the MD or in these cases do 
we have to generate a different DOC declaring to the LVD? In this case, would 
we have to establish a system to produce custom DOCs for each device produced 
depending on the options ordered by the customer?


Question #2

Because the MD requires an accompanying unique signed DOC for each such device 
built and to include the specific model number (based on options ordered) and 
serial number, how do most companies logistically handle this? I don’t imagine 
that each company has a “Managing Director” sitting at the end of the product 
line signing, copying, packing, and filing the DOC for each product built. So 
how can this be reasonably done and still meet the intent of the Directive?

Thanks to all in advance.

The Other Brian




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