Mark, You need to do a comprehensive risk assessment and determine if the risk of injury to persons using or servicing the equipment is more mechanical or more electrical. You may have a moving part that is inside the equipment and inaccessible. How fast is that moving part? How is it secured? Is it accessible to a service person? Can the interlock of access doors be defeated? Lots and lots of questions that your engineering team need to ask before deciding which Directive must be applied.
Best Regards Peter Sent from my iPhone Peter S. Merguerian [email protected] Go Global Compliance Inc. www.goglobalcompliance.com (408) 931-3303 On Apr 30, 2012, at 6:11 AM, Mark Hone <[email protected]> wrote: > 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: [email protected] > 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. Wellman Defence Limited accepts no liability for any loss > or damage suffered by any person arising from the use of this email. > > Neither Wellman Defence Limited nor the sender accepts any responsibility for > viruses and it is your responsibility to check the email and attachments (if > any). If you received this mail in error, please destroy and delete the > message from your computer. > > - > ---------------------------------------------------------------- > 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 > <[email protected]> > > 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 <[email protected]> > Mike Cantwell <[email protected]> > > For policy questions, send mail to: > Jim Bacher: <[email protected]> > David Heald: <[email protected]> - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
