This is what we are seeing going on in Europe. Ever since that Mushroom Farm was fined for the injured employee, some companies in Europe are afraid of a similar fate. Laboratory Equipment used in a laboratory environment traditionally has work related risks not associated with other job environments, such as working with glass tubes, chemicals, hot surfaces, open flame, cold materials, moving parts, etc.. Though manufacturers of ISM equipment can Self Declare under the CE Marking Scheme, for reassurance, some customers are seeking 3rd party testing. Such test houses lack the ability to perform a proper Risk Assessment at a customer site so anything they are unable to test is listed on their test reports as a Non-Compliance. 3rd party labs also like to impose their own interpretation to the requirements.
Since the 3rd party lab is not our customer, we cannot communicate with them directly. Plus, all communications has to be translated into their language (French in our most recent case). So we have to work through our customer who is completely ignorant of product safety and regulatory compliance in every way. We have sent test reports, risk assessments, test data, etc. but nothing seems to satisfy them. It is costing our company a small fortune to address these Non-Issues in our opinion. Meanwhile, our customer is afraid to turn on our product in fear of being fined if an employee is injured using it because it has English Text on the warning label. Crazy. I know this is an extreme case but we have had three such cases in the last year. We are considering getting our products Certified by a European test lab. Do you think this would eliminate the 3rd party on-sight testing? We have a good relationship with a local TUV:SUD office. What do you think? Would this help? In the meantime, we are trying to remove all (or most all) English text from our products utilizing symbols, graphics, acronyms and abbreviations where possible. Translated manuals, software, and DoC are provided at the time of setup. I’m not sure what we can do about 3rd party testing’s inability to perform a proper risk assessment on site unless getting a certification would help. Are others out there having similar issues? Thanks for listening. Sorry if you have heard my yammering before. We have meetings setup next week with our European counterparts to find workable solutions. The input I have received from this Email Group has been most helpful. Thanks. The Other Brian From: Brian Gregory [mailto:[email protected]] Sent: Monday, May 04, 2015 4:25 PM To: [email protected] Subject: Re: [PSES] Warning Label: Disconnect from Mains Hello again, Brian; It sure does sound to me like you've done your basic diligence; are the ANSI compliant symbols any different from the JIT compliant symbols? Even when I was with an NRTL/NB organization, I was often irked by standards requirements that were not requested or considered useful by actual customers. That being said, I've got the feeling that an informed answer would require a fairly detailed account of "getting dinged in Europe" Regards, Brian Gregory [Colorado] 720-450-4933 ---------- Original Message ---------- From: "Kunde, Brian" <[email protected]<mailto:[email protected]>> To: [email protected]<mailto:[email protected]> Subject: Re: [PSES] Warning Label: Disconnect from Mains Date: Fri, 1 May 2015 18:15:40 +0000 Thanks Doug and Colorado Brian. We liked the look of the new ANSI labels so we switch over all the warning labels on our products to this style a few years ago. But now we are getting dinged in Europe and have to replace the labels with symbols only or with the text in the language of the country we sold in. This is difficult to do because sometime we ship instruments to our sales offices in Europe but we don’t know what country it might be sold in until it is purchased. Why don’t the EU just decide on one language like the Chinese did? (Those are fighting words). We do explain the meaning of our warning symbols in the User’s Manual and the manuals are translated into different languages depending on the country it is sold and what our customers want. The users of our type of instruments are generally well educated (scientists, chemists, engineers, technicians, etc.) and most of the time they are happy with English only. But when other languages are requested we try to provide them translated copies fairly quickly. It’s very costly , too. Most of our customers send their Users for training at our facility in the US. Classes are in English Only. The other Brian From: dougp01 [mailto:[email protected]] Sent: Friday, May 01, 2015 1:48 PM To: [email protected]<mailto:[email protected]> Subject: Re: [PSES] Warning Label: Disconnect from Mains I agree with Colorado Brian. It seems that more and more, IEC-based standards are requiring a full explanation of symbols and warnings in the user documentation. As it turns out, many clients of mine leave the user manuals to the very last and they are usually very lacking. Where possible using symbols only is an economical option. One exception to using just symbols might be in certain industries where using an ANSI/IEC compliant labeling system is required. In this case some verbiage is required. The text should simply describe the problem and how to avoid it. Nothing more. Proper use of the keywords Danger, Warning, and Caution are also essential. Since overstating the hazard is not advisable. All the best, Doug From: Brian Gregory Sent: Friday, May 1, 2015 11:31 AM To: [email protected]<mailto:[email protected]> Reply To: Brian Gregory Subject: Re: [PSES] Warning Label: Disconnect from Mains ---------- Original Message ---------- From: "Kunde, Brian" <[email protected]<mailto:[email protected]>> Date: Wed, 29 Apr 2015 18:54:17 +0000 Brian, thanks for your input. Can the potential hazard be addresses without English Text which may be misunderstood by those unfamiliar with the language? Wouldn’t Symbols Only be better? [Colorado Brian here] Symbols ON the equipment are sufficient, and often preferred. John's answer is also correct, that the symbols (even fully JIT-compliant ones) need explained, in all the appropriate languages (as defined by ND's), in the supplied documentation. Any additional needed information can be added at this point by the manufacturer. So if AHJs, NRTLs, etc. like to see some kind of warning on the outside of electrical equipment, then won’t the Hazardous Voltage Warning symbol alone meet this requirement WITHOUT any Text? As the Machinery Directive states, “Information and warnings on the machinery should preferably be provided in the form of readily understandable symbols or pictograms.” Bingo; warnings on the machinery.... And in the case given in the 61010-1 standards, it doesn’t say that you have to use Text, but what the warning marking should state. A symbol or symbols can “state” or have the same meaning as text without the concern of the User needing to be able to understand the language of the text. I advise being verbose as possible in the documentation; this can be in digital format, so needn't incur much additional expense. You, as the manufacturer, are now officially on record as directing the end user: DO this, NOT that... etc. Wordy labels can be expensive, and possibly confusing (esp. when many languages get involved); I was always perfectly happy with symbols. CYA, baby.... The Colorado Brian From: Nyffenegger, Dave [mailto:[email protected]] Sent: Wednesday, April 29, 2015 10:39 AM To: Kunde, Brian Cc: [email protected]<mailto:[email protected]> Subject: RE: Warning Label: Disconnect from Mains Our NRTL asks for the warning “No User Serviceable Parts Inside” when that is the case but that is relative to products complying with UL/EN 60950-1 and EN 60204-1. Of course that needs to be translated into all appropriate languages too. -Dave From: Kunde, Brian [mailto:[email protected]] Sent: Wednesday, April 29, 2015 10:21 AM To: [email protected]<mailto:[email protected]> Subject: [PSES] Warning Label: Disconnect from Mains Greetings. We make laboratory equipment designed to the requirements of the IEC/EN/UL/CSA 61010-1 Ed. 3 standard. Most electrical equipment has at least one warning somewhere visible on the outside of the equipment that states something like, “Disconnect Power Before Servicing”. Where does this requirement come from? I see no such requirement in the 61010-1 standard. The 61010-1 does say, “If the instructions for use state that an OPERATOR is permitted to gain access, using a TOOL, to a part which in NORMAL USE may be HAZARDOUS LIVE, there shall be a warning marking which states that the equipment must be isolated or disconnected from the HAZARDOUS LIVE voltage before access.” However, if our users do not need to gain access inside our equipment, then I assume such warning is unnecessary. We used to have a warning label on any tool assessable panel that has hazardous voltages behind it. However, I do not see this as a requirement in the 61010-1. In the past, we have had inspectors write us up for not having such labels on all panels with hazardous voltage behind it. Does this requirement come from somewhere else? Are the inspectors wrong? The label we commonly use has the Symbol 12 (hazardous voltage warning) and English Text that states something like, “Disconnect Power Before Servicing”. However, when our products are sold into non-English speaking countries, we sometimes get dinged for the English Text; especially in French speaking counties. So, if such a label truly is required, can we get away with only using the Symbol 12?, or can we use a label with a combination of symbols, such as Symbol 12 and maybe the ISO 3864-2 Disconnect Mains Plug symbol? Is text of some kind required or can we just use symbols? Any suggestions or recommendations? Thanks to all for your input. 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]<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]<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]>> - ---------------------------------------------------------------- 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]>> - ---------------------------------------------------------------- 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. 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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]>> - ---------------------------------------------------------------- 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]>
