Philip, I concur with John Woodgate on this. If you were talking about a mitre saw or a vehicle lift, i.e., products which are the same whether used for civilian or military/police purposes, then they would be exempt. In this case, there is no civilian version of the training system or the weapons system (at least I hope not!), and therefore the training system would be held exempt from the MD.
-- Doug Nix [email protected] "We do not remember days. We remember moments." - Cesare Pavese > On 16-Jan-17, at 13:43, Philip Stevenson <[email protected]> wrote: > > Dear Members > > I am writing to ask for your advice on the use Machinery Directive 2006/42/EC > Exemption for products specifically designed and constructed for military > purposes. > > My question is whether this exemption can be applied to a Military Training > System specifically designed to train the Military Forces in the use of a > Weapon System that is designed and constructed for defence purposes. The > Training System is only used for this sole purpose. That is no other uses. > The Training System will be installed and used in a restricted/controlled > area and the instructors, maintainers and operators will be trained in its > use. > > The Training System includes a mechanism which in the terms of the directive > is classified as a “lifting accessory”. This mechanism along with the > complete Training System will be subjected to a documented Safety Assessment > and Risk Assessment before the system is put into service. > > The EU Guidelines for the Machinery Directive relating to this exemption are > as follows: > > Article 1 (2) > (g) Machinery specially designed and constructed for military or police > purposes; > > 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 > > Does the second sentence “Ordinary machinery used by the armed forces or by > the police but which is not specially for defence purposes or for the purpose > of maintaining order is subject to the Machinery Directive.” apply to a > Military Training System designed specifically to train the armed forces in > the use of a Weapon System for defence purposes or not? > > If a specially designed Military Training System intended for a single use is > not exempt, would it be considered acceptable for the fore mentioned > documented Safety Assessment and Risk Assessment to be used as suitable > evidence for meeting the essential health and safety requirements of the > Machinery Directive or not? > > I would be greatly for the members help. If you would prefer to contact > directly instead of via the listing my Email work address > [email protected] > <mailto:[email protected]>.or my home Emaol address > [email protected] <mailto:[email protected]>. > > > > Regards > > Philip Stevenson > Senior Specialist Engineer - Electronics, Advanced Weapons, Belfast > > Thales > Land & Air Systems > Alanbrooke Road, Belfast, Northern Ireland, BT6 9HB > www.thalesgroup.com/uk <http://www.thalesgroup.com/uk> > > Tel: +44 (0)28 90465665 > e-mail: [email protected] > <mailto:[email protected]> or [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 > <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 (including how to > unsubscribe) <http://www.ieee-pses.org/list.html> > 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 <[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]> 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]>
