Between 1995-2012, I sold a lot of electronic communication and training systems to the UK & Canadian MoD's. This equipment would have had very little value to any commercial market, but the equipment was always required to meet all commercial safety and health requirements as well as the contractual military requirements.
Much military hardware eventually gets sold as surplus to the public, but the military has the responsibility to "de-militarize" it. For instance, a tank might be sold, but only after classified systems are ripped out and the weapons systems are destroyed beyond any hope of functionality. If some non-weapon device was bought only to a MoD/DoD specification, and was not CE/FCC compliant, then the military would probably have no way of allowing that hardware into the public domain; they would probably just destroy it and sell it smashed or shredded. I wonder how dual-use equipment, CE/FCC compliant at the time the military purchased it, would be treated when, maybe 15 years later, it would first be dumped onto the civilian market as surplus? Would the civilian market treat that as "used" equipment, or "new" equipment, in that this was the first time it was entering civilian use? Ed Price WB6WSN Chula Vista, CA USA -----Original Message----- From: John Allen [mailto:[email protected]] Sent: Tuesday, November 18, 2014 11:33 AM To: [email protected] Subject: Re: [PSES] RoHS2 and Police Equipment Carl Can't say a lot about the police forces, but from experience dealing with UK and other MoDs, I would say: - if the product is "dual use" - i.e. it is or can be sold in the normal commercial sectors - then that Directive states that it must meet the normal application "CE" and other commercial market safety requirements". - if not "dual use" then it may well depend on the attitude of the buying force - some military forces may accept "no CE" but only if the product is nothing like a commercial product. Otherwise, if it is pretty similar to the commercial products, they may ask why it cannot be made to meet "CE requirements" and not accept it if it does not (UK MoD often takes that approach). - Many military forces - and notably in the UK - are also bound by the law (e.g. the UK Health and Safety At Work, etc. Act 1976) to protect their military forces, the civilians who work with them and the "3rd party" civilians who visit their establishments to the letter of civilian law, and that means "CE" (and remember that in the UK, the Provision of Equipment for Use at Work Regs or "PUWER", calls for equipment to be used at work to be "CE" where relevant "CE" regs can apply). Almost all non-UK military forces are bound by similar legislation in one form or another. - Even if military forces don' require "CE", they now almost always require some form of "Safety Case" to be generated by the supplier to prove that their products are safe to install/ operate / maintain / dispose of (and would mean RoHS, WEEE, etc.) - and let me tell you that it is some big task to have to do and a lot more work than "CE" generally. However if you can show that the product is "CE" then that can take a big chunk of effort out of the task of generating the Safety Case. - I suspect that the police forces - generally being more "civilian" than "military" - would lean far more to requiring "CE". I should mention that I once had discussions with one of the UK government agencies that provides secret secure communications equipment to the UK government civilian intelligence forces, and they were actively pursuing the "CE" route for most or all of their equipment (and that was about 10 years ago, so they must be well into that now!). Therefore, tanks and special purpose military weapons almost certainly does mean "no CE" but anything else including police weapons (which could be used in and around the general public) else will probably have to comply! Food for thought, maybe? Regards John Allen Compliance with Experience W. London, UK -----Original Message----- From: Carl Newton [ <mailto:[email protected]> mailto:[email protected]] Sent: 18 November 2014 15:20 To: <mailto:[email protected]> [email protected] Subject: [PSES] RoHS2 and Police Equipment List members, This company manufactures weapons sights that are distributed within the EU to military and police customers. I'm seeking confidence that weapons devices distributed to police organizations can be properly defined as excluded equipment "which is necessary for the protection of essential interests of the security of Member States" as stated in Article 2.4a): Article 2(scope) "4. This Directive does not apply to: (a) equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions and war material intended for specifically military purposes;" At first glance that clause appears to be dedicated entirely to military equipment. But I believe that this exclusion should also apply to police weapons, etc. as well in view of the fact that their entire reason for existence is security. However, I've been unable to find any hard evidence that this is the case. Do any of you have experience or examples with this particular RoHS question? Thanks very much in advance, Carl -- - ---------------------------------------------------------------- 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 < <mailto:[email protected]> [email protected]> All emc-pstc postings are archived and searchable on the web at: <http://www.ieee-pses.org/emc-pstc.html> 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/> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: <http://www.ieee-pses.org/> http://www.ieee-pses.org/ Instructions: <http://www.ieee-pses.org/list.html> http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: <http://www.ieee-pses.org/listrules.html> http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas < <mailto:[email protected]> [email protected]> Mike Cantwell < <mailto:[email protected]> [email protected]> For policy questions, send mail to: Jim Bacher: < <mailto:[email protected]> [email protected]> David Heald: < <mailto:[email protected]> [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://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]>
