Dieter,

IMO, the key words are "...intended to be used permanently at a predefined 
location". If the machine could be purchased by any customer and used in any 
location, even if it's a one-off, then it is apparatus under the definitions in 
the directive. If it can only be installed in one location and is designed 
specifically for that location and application, then it would be a fixed 
installation under the definition.

Based on my knowledge of your company's products, I don't think anything you 
normally build would meet the definition for a fixed installation. I am 
available to discuss on the phone if you want to chat about it.

Regards,

Doug NIX, C.E.T.
Compliance InSight Consulting Inc.

Know Risk... Design Safety

Office: +1 (519) 650-4753
Mobile: +1 (519) 729-5704
Skype: cic-inc
email: [email protected]
Want to meet?

On 10-July-2013, at 16:49, "Paasche, Dieter" 
<[email protected]> wrote:

> Hi ,
>  
> I have the feeling I am still in the grey area, mainly in the definition of 
> what is a mobile system.
>  
> Also, the guidelines mentions in section 1.3.1 (4th Paragraph) that “Large 
> machines, in the usual sense of this term, are normally apparatus and have to 
> be treated as such.”
>  
> In my opinion, if the machine has its own control panel and can operate its 
> function independently, then it is to be considered as an apparatus. Am I 
> wrong?
>  
> It looks however from John’s comments that a machine is a fixed installation, 
> if it is custom made and there will never be another machine like that in 
> another place. So, if I have two of the same machines in different locations, 
> then they are not fixed installation. Is that correct?
>  
> In any case, apparatus and fixed installation reference Article 5, so 
> strictly speaking from the testing point of view, both have to be tested for 
> EMC. Is that correct?
>  
> Thanks
>  
> Dieter Paasche
>  
>  
> From: Doug Nix [mailto:[email protected]] 
> Sent: July 10, 2013 2:37 PM
> To: Paasche, Dieter
> Subject: Re: [PSES] Fixed Installation vs Apparatus
>  
> Dieter,
>  
> Have a look at the attached Guidance document from the EC. On page 15, 
> Section 1.1.5 and flowchart 2 show how to determine whether the equipment is 
> apparatus or a fixed installation.
>  
> Regards,
>  
> Doug NIX, C.E.T.
> Compliance InSight Consulting Inc.
>  
> Know Risk... Design Safety
>  
> Office: +1 (519) 650-4753
> Mobile: +1 (519) 729-5704
> Skype: cic-inc
> email: [email protected]
> Want to meet?
>  
> On 10-July-2013, at 14:22, "Paasche, Dieter" 
> <[email protected]> wrote:
> 
> 
> Hi group,
>  
> At which point could you define a piece of machinery a fixed Installation?
>  
> What are the differences in reference to EMC testing? It looks to me that 
> regardless of a piece of machinery being  considered an apparatus or a fixed 
> installation, it still has to be tested to comply with EMC requirements.
>  
> Thanks
>  
> Dieter Paasche
>  
> -
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