In message <[email protected]>,
dated Thu, 7 Jun 2012, "ce-test, qualified testing bv - Gert Gremmen"
<[email protected]> writes:
It seems that the MD formally IS a New Approach Directive, and that is
what I assumed in the first place.
Yes, well, I think it's an example of EU pragmatism.
But John, you are not completely ignorant in these, so I expect there
is something behind your statement.
You made me worry (a bit): so now you owe us some explanation other
than a one-liner. Share your view with us: Why do you consider the MD
NOT a New Approach and where did the EC fail here ?
OK. The original 89/392 Directive contained a large amount of text which
one would expect to be in standards, not in a Directive and, I think, it
pre-dated the New Approach. The next revision introduced CE marking and
eliminated much of the 'standards-type' text but really didn't change
the underlying approach. In other words, I think it met the letter of
the law as 'New Approach' but not the spirit of it.
The response to the protests that *anything* with a moving part
qualified as 'machinery' was to include a statement (Article 3) that
many think is obscure and not reassuring, which is indeed why we have
this discussion about laboratory equipment:
"Where, for machinery, the hazards referred to in Annex I are
wholly or partly covered more specifically by other Community
Directives, this Directive shall not apply, or shall cease to
apply, to that machinery in respect of such hazards from the
date of implementation of those other Directives."
The obvious question is 'Who decides whether that is the case?' Does
IEC/EN 61010 give blanket, or qualified, exemption from the MD or not?
And if qualified, what are the qualification criteria? The situation was
exacerbated by a refusal of the bodies responsible for the Directive to
respond constructively to questions and protests.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Instead of saying that the government is doing too little, too late or too
much, too early, say they've got is exactly right, thus throwing them into
total confusion.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
-
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