Brian > People who claim to have the Commission’s ear and claim to know what they want Bear in mind that the Commission don’t enforce the rules ☺
I don’t either I hasten to add ☺ It’s not mandatory to put the serial number on the DoC as its not mandatory to put the serial number on the unit – but if you do put serial number on it, it is then mandatory to include serial number on DoC – either explicitly or in a range of numbers. Regards Charlie From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: 04 January 2012 20:10 To: Charlie Blackham; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Machinery Directive DOC Questions As I explained, we built products to order. One at a time per the order. We do not build in “Batches” or “Large Series” so I would not believe that we can use a range of serial numbers. Some interpret the Guide text to mean the serial number on the DOC is not mandatory, others tell me it is. The Guide text says, “As a general rule”. What the does that mean? Also, if you refer to the previous paragraph it states, “The particulars required for the description and identification of the machinery are essentially the same as those to be marked on the machinery. However, in the EC Declaration of Conformity the particulars of the machinery must be given in full.” Doesn’t this mean that if the serial number is marked on the machinery then it should also be on the DOC? Don’t get me wrong, I don’t want to have to include the serial number on the DOC, but I’m hearing both sides of this issue from very influential people. People who claim to have the Commission’s ear and claim to know what they want. Thanks for all the input (and sympathy). The Other Brian From: Charlie Blackham [mailto:char...@sulisconsultants.com] Sent: Wednesday, January 04, 2012 2:32 PM To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Machinery Directive DOC Questions Brian Re: Question 2 “2nd Edition of the Guide to application of the Machinery Directive 2006/42/EC”, available from http://ec.europa.eu/enterprise/sectors/mechanical/machinery/ , offers the following guidance §383 The content of the EC Declaration of Conformity ..........As a general rule, the serial number of the machinery covered by the EC Declaration of Conformity shall be indicated. In the case of machinery produced in large series, it is possible to draw up a single EC Declaration of Conformity covering a range of serial numbers or batches, in which case the range covered by the declaration must be specified and a new EC Declaration of Conformity must be issued for each new range of serial numbers or batches. In any case, the necessary identification must be provided to ensure the link between each item of machinery and the EC Declaration of Conformity that applies to it....... Regards Charlie From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: 04 January 2012 17:38 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive DOC Questions 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 ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
