In message <[email protected]>, dated Fri, 26 Apr 2013, Charlie Blackham <[email protected]> writes:


Looking at the LVD guidance, (and of course it's "guidance" not "law") http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , page 28

 

Products              Scope of LVD     Examples of products    Comments

Cables                   Yes                         [picture of cable]             Marked with HAR to increase tractability

'tractability' - the quality of being easily managed

I suspect weasel wording here. The Commission has no business apparently elevating a private marking scheme to a requirement under a Directive. So using a confusing word may be a way to 'fog' the issue. Some people will assume it's a typo for 'traceability'.

Participation in the HAR scheme is *effectively* restricted to certification bodies (it's not a manufacturers' organization) in Europe because ENs and HDs must be in force in the country - from the HAR site:

QUOTE

Within the country of the applicant, the European ENs and HDs must have formally entered into force; any conflicting national standards must have been withdrawn. Assessment of capability and qualification of the candidate by a HAR assessment team, according to harmonised requirements; positive results to be formally endorsed by the HAR Group.

ENDQUOTE

This restriction must, in fact, bear some responsibility for the widespread presence of dangerous fake 'HAR' marked cables. I have a sample alleged to have 0.75 mm^2 conductors, which are barely 0.3 mm^2 in fact, fitted with a fake British 13 A plug marked '10 A' but without a fuse.

The point is that if you use a test house and the cable isn't HAR marked, the test house may well want to test the cable to whichever of HD 21, HD 22, EN 50525, EN 50143, EN 50214, EN 60702 or EN 61138 applies, and that is extremely costly.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
They took me to a specialist burns unit - and made me learn 'To a haggis'.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-
----------------------------------------------------------------
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]>

Reply via email to