Charlie & Friends
Whilst those exemptions do exist, the reality is, or could well be, that other requirements will come into play: - The shipping assessment bodies (Bureau Veritas, Lloyds, DNV, etc.) will have their requirements which could well parallel requirements to those of the MD therefore, in this instance, John A in the States should get his customer to discuss these aspects with their own customers who will operate any vessels on which the equipment is to installed. - The majority of European Armed Forces will require rigorous documented safety assessment processes, such as the UK MoD Safety Case requirements, and might even require MD compliance, albeit with possible detail exemptions where compliance cannot be achieved because of role-specific requirements which take an equipment outside permissible MD limitations. John E Allen W.London, UK From: Charlie Blackham [mailto:[email protected]] Sent: 25 August 2016 13:27 To: [email protected] Subject: Re: [PSES] Oil Spill recovery equipment for CE - Exemption?? John The rumour may be based on some fact, but might not be applicable to your product MD Article 1. 2. The following are excluded from the scope of this Directive: (f) seagoing vessels and mobile offshore units and machinery installed on board such vessels and/or units; (g) machinery specially designed and constructed for military or police purposes; Clarified in the guide: § 58 Seagoing vessels and mobile offshore units and machinery installed on board such vessels and/or units Seagoing vessels and mobile offshore units such as, for example, mobile drilling rigs, and machinery installed on them are excluded from the scope of the Machinery Directive by Article 1 (2) (f) since they are subject to the Conventions of the International Maritime Organisation. Some of the equipment concerned by this exclusion may also be subject to the Marine Equipment Directive 96/98/EC18 as amended by Directive 2002/75/EC19 A mobile offshore unit is an offshore unit that is not intended to be located on the oil field permanently or for the long term, but is designed to be moved from location to location, whether or not it has a means of propulsion or of lowering legs to the seafloor. However, floating units intended for production, such as, for example, FPSOs (Floating Production, Storage and Offloading installations - usually based on tanker designs) and FPPs (Floating Production Platforms - based on semi-submersible vessels) and the machinery installed on such units are not excluded from the scope of the Machinery Directive. Machinery intended to be installed on fixed offshore platforms such as, for example, oil production rigs, and machinery which may be used on both fixed and mobile offshore units is also subject to the Machinery Directive. § 59 Machinery for military or police purposes The exclusion set out in Article 1 (2) (g) applies to machinery specially designed and constructed for defence purposes or for the purpose of maintaining order. Ordinary machinery used by the armed forces or by the police but which is not specially designed for defence purposes or for the purpose of maintaining order is subject to the Machinery Directive. In some countries, certain fire services belong to the military, however machinery designed for use by such fire-fighters is not thereby considered to be designed and constructed for military purposes and is thus subject to the Machinery Directive. Regards Charlie From: John Allen [mailto:[email protected]] Sent: 25 August 2016 12:52 To: [email protected] Subject: [PSES] Oil Spill recovery equipment for CE - Exemption?? Hi, We're working with a client that supplies Oil Spill response equipment. We're evaluating the pumps and systems to the Machinery Directive, among others. However, I heard a "rumor" there is an exemption for Emergency Response Equipment. Has anyone heard this or knows of this exemption? I searched on europa and cannot find anything. Thanks, John John Allen | President | Product Safety Consulting, Inc. Your Outsourced Compliance Department® <http://www.productsafetyinc.com> http://www.productsafetyinc.com 630-238-0188 Visit us at the D2P Show in Marlborough, MA. Booth 537 Sept 28th & 29th - ---------------------------------------------------------------- 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) <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]> 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) <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]> 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]>
