I've said this before. The status of standard DOES NOT determine whether product is within the scope of a particular Directive or not.
To put it in its simplest terms, if a product has powered moving parts then, irrespective of the status or otherwise of any standards, it is within the scope of the Machinery Directive unless it is excluded by one of the clauses in Article 1. That's all there is to it. Nick. On 30 Apr 2012, at 17:00, Ted Eckert wrote: > The first question I would ask is whether there is a product specific > standard that covers your product. If so, then determine if that product > specific standard is a harmonized standard under one of the other directives. > In that case, the machinery directive would not apply. > > For example, an air conditioner has plenty of moving parts. However, a small > portable air conditioner intended to be installed and used by general users > is covered by EN 60335-2-40, which is a harmonized standard under the Low > Voltage Directive. This air conditioner would not fall under the Machinery > Directive. > > On the other hand, a large commercial air conditioner designed to be > installed on the roof of a building is not within the scope of EN 60335-2-40. > There are general standards covering the mechanical safety and the safety of > the pressurized system, but not an overarching product standard for this type > of product. As such, it falls under the Machinery Directive. > > You may need to do some research to see if your product is within the scope > of a product specific standard. However, if it is and if that standard is a > harmonized standard under the Low Voltage Directive, the LVD would likely > apply. These standards are designed to cover potential mechanical hazards > specific to certain product types, but they are recognized as covering > product where electrical hazards predominate. > > This is not just the case for the LVD. There are medical products with moving > parts and toys with moving parts and those are each covered under their own > directives. If your product has a radio, and it is covered by a standard > harmonized under the R&TTE Directive, that Directive may be the one that > applies. > > Ted Eckert > Compliance Engineer > Microsoft Corporation > ted.eck...@microsoft.com > > The opinions expressed are my own and do not necessarily reflect those of my > employer. > > -----Original Message----- > From: Mark Hone [mailto:mh...@wellmandefence.co.uk] > Sent: 30 April 2012 14:12 > To: EMC-PSTC@LISTSERV.IEEE.ORG > Subject: [PSES] Machinery Directive silly question? > > Dear Colleagues, > > I know that you are all patient with what might seem silly questions, so I > hope you'll be patient with mine. > > I have not had to consider the Machinery Directive before, but a new > electrical product has a moving part in it. It's a wholly enclosed > (inaccessible in the middle of the equipment) fan that blows air through the > equipment (not a cooling fan). > > The MD defines machinery: " an assembly, fitted with or intended to be fitted > with a drive system... consisting of... components, at least one of which > moves, and which are joined together for a specific application". > > So the silly question is, if the moving part is wholly contained within the > equipment and is inaccessible, does the MD apply or do I apply the LVD? > > I have Googled this question and have found references that say the MD does > apply (it's the enclosure that makes the moving part safe), and references > that say the MD does not apply (as the moving part is wholly internal, one > doesn't need to even consider it). I strongly suspect the former statement > is the correct one. > > Your authoritative opinions are sought! > > With thanks in anticipation, > > Mark > > > -- > Mark Hone > HESS Manager > > Wellman Defence Limited > Dolphin House > Williams Road > Portsmouth > Hampshire > PO3 5FP > > T: +44 (0)23 9262 9239 > F: +44 (0)23 9269 7864 > E: mh...@wellmandefence.co.uk > W: www.wellmandefence.co.uk > > ________________________________ > Wellman Defence is a limited company registered in England and Wales. > > Company Registration No. 953609 > > Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West > Midlands, B69 3ET, England. > > The contents and any attachments to this email include information that is > private and confidential and should only be read by those persons to whom > they are addressed. 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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> Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: nick.willi...@conformance.co.uk ----- Conformance Ltd - Product safety, approvals and CE-marking consultants The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk Registered in England, Company No. 3478646 - ---------------------------------------------------------------- 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>
