Brian, The MD guide clarifies that both the AR and the person authorized to compile the technical file (and they can be different people) can both be a "natural or legal person". In other words the both can either be a named individual or a company. Companies tend to last longer than individuals in a particular position, so it seems better to indicate a company as AR.
A DoC that references a name (whether individual or company) that is no longer correct is, I think, well..., no longer correct. Regards, Lauren From: Kunde, Brian [mailto:[email protected]] Sent: Tuesday, July 16, 2013 8:37 AM To: [email protected] Subject: Re: [PSES] Future of marking authorized representative on machines? On our DoCs we have always listed our Sales and Service Office in the EU for our European Contact. The Machinery Directive required that we include the NAME of a Person in the EU, which we have been doing for several years now. HOWEVER, this person just recently quit our company. Now What? What good is his name on all our previous DoCs if he no longer works for our company? Does he personally still hold some responsibility for products and a company he no longer works for? And, what is our obligation to update our DoCs with a new person's name on them? It could take weeks or months to work the new DoCs into manuals, Bill of Materials, go through the approval cycle, etc.. The same would hold true if the AR or Importer's name was on the product. You may have thousands of products labeled and warehoused ready to be shipped to the EU when the person quits. Nightmare. The Other Brian From: [email protected]<mailto:[email protected]> [mailto:[email protected]] On Behalf Of Nick Williams Sent: Monday, July 15, 2013 6:39 PM To: Crane, Lauren Cc: [email protected]<mailto:[email protected]> Subject: Re: Future of marking authorized representative on machines? The BIS view at the last Machinery Directive Notified Bodies meeting I went to (in May) was that there were unlikely to be any revisions to the Machinery Directive for at least five years. Nick. On 15 Jul 2013, at 23:25, "Crane, Lauren" <[email protected]<mailto:[email protected]>> wrote: In the Machinery Directive.... 1. If a manufacturer has designated an Authorized Representative, the AR name must be marked on the machine (ref Annex I, 1.7.3 1st indent). 2. A person must be identified in the Declaration of Conformity who is established in the EU and is authorized to compile the technical file (ref Annex II (1)(A)(2)) Both these criteria are absent from the new legislative framework (NLF) model, and the recent directives implementing the NLF model, namely RoHS2, LVD3 (still in works), EMCD3 (still in works). The NLF model requires the importer of equipment to "indicate their name, registered trade name or registered trade mark and the address at which they can be contacted on the apparatus/equipment or, where that is not possible, on its packaging or in a document accompanying the apparatus/equipment." Does anyone know if the MD anomalies marking the AR on the machine and indicating in the DoC the person authorized to compile the technical file will be retired soon through some sort of NLF revision of the Machinery Directive? Regards, Lauren Crane KLA-Tencor - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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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]>
