Brian, I've faced similar situations when dealing with safety engineers in world areas that tend to take an overly rigid view of requirements. I think the underlying problem is subtleties getting lost in translation - so to be safe (that is their job!), a very literal translation of the requirements is what ends up being interpreted. Also, keep in mind that your Australian customer more than likely uses labs in their hemisphere rather than shipping their devices to western countries for safety approvals - which is probably why they have the same message. If you have an authoritative western contact at your safety agency, they can often clear up the misconceptions for you and save a lot of headaches.
I don't remember the exact details that I've been through, but I received some very non-applicable safety requirements that were put to rest with a call to my more local contacts. I'll admit I haven't had to deal with the exact equipment types you're describing, but the problem on a higher level sounds like something I'm all too familiar with. Best Regards, -Dave Heald On Fri, Jun 1, 2012 at 2:27 PM, Kunde, Brian <[email protected]> wrote: > More trouble in the world of Laboratory Equipment (red headed step > child) and the Machinery Directive. > > > > I’ve had TUV offices in 3 Asian countries and a customer in Australia tell > us our products (Laboratory Equipment) must have an AC Lock Out Device, an > Emergency Stop Switch, and a Light Tower because “Laboratory Equipment now > falls under the Machinery Directive”. > > > > They are telling us that any AC product requires a lock out device. What? > > > > On one instrument we make, the only moving part is a small dc motor with a > wire brush similar to an electric tooth brush that cleans an electrical > contact between analysis. You can stop this motor by hand without injury. > This motor is also behind a double interlock door (due to an electrical > hazard), but yet they say we must have an E-Stop switch and Light Tower. > > > > I’m not familiar with the Light Towers. I’ve seen them on Large Production > Machines but what purpose do they serve on laboratory equipment no larger > that an upright piano? I understood they are only required to show the > operational status of a machine if not knowing the status could cause a > hazard or injury. Is there more to it? I don’t see why it would be needed > if there are no accessible hazards. > > > > I’m getting the feeling that some believe these things are required just > because laboratory falls under the machinery directive and not for any > other reason, which seems silly to me. In the past, the machinery directive > mainly covered the safety of Production Machines which generally require > these safety components. > > > > Can you imagine your next spectrum analyzer having an E-Stop switch > because of the cooling fan or the motorized CD drive door? Is this what it > is coming to? > > > > Why or why don’t you large powerful laboratory equipment manufacturers > fight for the official recognition of “Laboratory Equipment” and have our > own Directives, Standards, and requirements and not have to wade through > all the machinery Directive nonsense? What sense is the IEC/EN 61010-1 > standard if they are not harmonized to the MD? Why are we being forced to > apply the IEC/EN 60204-1 to Laboratory Equipment where 90% of the > requirements don’t or shouldn’t apply? > > > > Sorry for my rant. It’s been a long week. I’m just a small powerless voice > trying to sell safe products to a crazy crazy world.. > > > > 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. 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]>
