Brian -- I would think a model number might suffice as "designation of the machinery." In my way of thinking, there has to be something that ties the nameplate to the DoC; we use the model number, not a functional description---have never run into that interpretation before.
Although the Annex describing the contents of the DoC includes a SN, the required markings on the machine in Annex I do *not* require a SN. My approach is that if it's not required to be on the machine and therefore is not on the machine, it doesn't exist and therefore is not required to be on the DoC. I think there's nothing wrong with electronic signatures and generic DoCs. How many of us have seen exactly that printed in owner's manuals? Mike Sherman Graco Inc. ----- Original Message ----- From: "Brian Kunde" <[email protected]> To: "EMC-PSTC" <[email protected]> Sent: Monday, March 16, 2015 12:18:55 PM 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 ________________________________ 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]> - ---------------------------------------------------------------- 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]>
