Lauren, I went through a few years ago what you are going through now. Your six points are good which we also considered. We also received advise from our NB on what to do. Our goal was to hang onto the LVD on all or at least the majority of our product line. But that is not how it ended up.
The turning point was input from our customers in Europe. At first we started receiving inquiries, but later complaints that our products should be declared to the MD and not the LVD. We were afraid our customers might lose faith in our self declaration and that it might affect sales. Again, trying to hang onto the LVD, we initially declared compliance to the MD only on instruments that had external moving parts. But it became too confusing for everyone. So now, all of our instruments are declared to the MD. Almost everything has at least one moving part, such as a cooling fan. We still test to the 61010-1. I'm hoping in the future that this standard will become harmonized to the MD, or that laboratory equipment will once again be excluded from the MD. Or maybe laboratory equipment will have its own directive. Laboratory equipment has been the red headed step child long enough. :) I hope you find this helpful. The Other Brian Merry Christmas! Sent from my Windows Phone ________________________________ From: Crane, Lauren Sent: 12/23/2013 7:07 PM To: [email protected] Subject: [PSES] Any 'official' opnions on Laboratiry Equipment Machinery? Dear Experts, I am now facing a decision that had until now been nicely absent from my work…. Is a *slightly* mechanical piece of laboratory equipment (a microscope with an automated stage) a machine in scope of the MD? I have reviewed the archived PSTC discussions about fans, and similar threads on LinkedIn. This is how I summarize them 1. “small mechanicals” fall within the definition of Machine in the MD. 2. The MD specifically excludes 6 types of products that potentially also have “small mechanicals” in article 1.2.k, but none of these are “laboratory equipment”. 3. The MD specifically excludes machinery where the hazards referred to in Annex I are wholly or partly covered more specifically by other Community Directives. 4. It is reasonably arguable that lab equipment with “small mechanicals” are specifically covered by the LVD. 5. The LVD references mechanical hazards in its essential requirements. 6. 61010-1 (an LVD listed standard) addresses mechanical hazard issues relevant to “small mechanicals”. Does anyone know if any significant authorities have weighed in on this question since it was last addressed in this forum (~July 2011). I have Googled, and found nothing on which to hang this hat. Regards, Lauren - ---------------------------------------------------------------- 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]<mailto:[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://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[email protected]>> ________________________________ 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
