I do know that the scope exclusions of the machinery directive are small, but I disagree, that a directive such as the LVD and its standards cannot address moving part hazards.
For example, a fan in a scientific product such as a 230V spectrophotometer, does not make it a machine (except in the current rewrite). Compared to an electrocution hazard a hazard from a moving interior fan is miniscule. If the primary hazard (electrocution) is covered by another directive such as LVD and the applied LVD 'standard's' (e.g. EN 61010-1:2010) comprehensive risk assessment and protection requirements 'very' thoroughly addresses a moving part hazard from a device such as a fan, then I'd say moving parts from this ISM equipment is addressed. The machinery directive used to allow this. The re-write no longer does, but moving part hazards are clearly addressed in this case by a LVD standard. MY opinion only not my company's. Gail Birdsall Hach Compliance Dept. Manager w.970.663.1377 ext 2682 Hach Company | www.hach.com [email protected] -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Charlie Blackham Sent: Monday, April 30, 2012 10:35 AM To: Ted Eckert; [email protected] Subject: RE: Machinery Directive silly question? Ted I disagree, for Europe: Directives apply to products. Standards may be used to demonstrate compliance with Directives - but are not mandatory for many products. If you are using Harmonised Standards to give a Presumption of Conformity you should apply a product specific standard or failing that, a standard that covers your (type of) product. Regards Charlie -----Original Message----- From: Ted Eckert [mailto:[email protected]] Sent: 30 April 2012 17:01 To: [email protected] Subject: Re: [PSES] Machinery Directive silly question? 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 [email protected] The opinions expressed are my own and do not necessarily reflect those of my employer. -----Original Message----- From: Mark Hone [mailto:[email protected]] Sent: 30 April 2012 14:12 To: [email protected] 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: [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. 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