Brian et al,
Too bad you are getting beat-up by some local authorities (in
France, altho that's probably not the only place where such folks push their
authority). Altho Rich Nute recommended getting the references for the
requirements (which is a good idea) it may not come from the complaining
authorities and might not be accepted when coming from the originators of
the requirements. Unfortunately, there does not seem to be a good court of
last resort to sort this out.
Perhaps I've been more fortunate than most as an independent
consultant I usually get CE marking projects that are one-off, custom
versions of a machine that are usually adapted for each customer; so it is
unique and, since the company doesn't get too many foreign orders, the
entire process is captured as a project and the final step is the signed
MDoC (a unique document for a unique machine).
It seems that these complainers believe that machines are all unique
units and the detailed rules aren't a burden under those circumstances. I
know that is not always the case.
Perhaps there is some way to reposition the product so that is isn't
a machine but rather some other sort of product that is better handled
outside the MD? I've dealt with some pretty complex process control
equipment that has never been claimed to be a machine. You are probably
familiar with other situations that might fall into such a category.
Not having had such a reaction (knock-on-wood) I don't have 1st hand
experience.
Good luck in sorting it all out.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201 fone/fax
[email protected]
-----Original Message-----
From: Kunde, Brian [mailto:[email protected]]
Sent: Monday, March 16, 2015 10:19 AM
To: [email protected]
Subject: [PSES] Nameplate and DoC requirements Machinery Directive
I'm getting beat up again in France for non-compliances according to the
machinery Directive on our Nameplate and DoC. I know we have discussed these
issues in the past but I was wondering if things have changed or become
clearer over time. We want to do things right but some items are hard for us
to implement and don't want to have to do unless we really have to.
Nameplate (label) according to MD 1.7.3 "- designation of the machinery".
The Test Lab in France wants up to put something like "Carbon and Sulfur
Determinator" on our nameplate which we just do not have room for. Do others
struggle with this requirement? What ways have you found to comply with this
requirement?
Declaration of Conformity according to MD Annex II, Serial Number. The Test
Lab insist that the serial number must be on the DoC even though many have
explained why this is not required. TUV:SUD has also told us that the serial
number does not have to be on the DoC unless it is needed to determine a CE
Compliant instrument from a non-CE compliant instrument, but we do not have
this in writing. All of our products are CD compliant so the serial number
has no purpose. Does anyone have a document that clearly explains when the
serial number is and is not required on the DoC? We cannot really use the
methods described in the Guide, such as using a Range of serial numbers
because we built one at a time per customer order. The Test Lab wants the
DoC to have the exact same information as the Nameplate so they say we
cannot use "Series" in the model number or Product Name. Do others use such
shortcuts? To do what they want we would have to type up a custom DoC for
every instrum!
ent we build with a dedicated document number, have it signed, and store
copies either paper or electronic file for 10 years. That's crazy.
Should I just give in or do I have any ammo in fighting this? Some of the
items this Test Lab said was "required" six months they are now backing down
saying things like "it would be nice . . . ".
Thanks for the help.
The Other Brian
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http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used
formats), large files, etc.
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