________________________________
From: Philip Stevenson <[email protected]>
Sent: 16 January 2017 18:43
To: '[email protected]; Philip Stevenson; Philip Stevenson
Subject: RE: [PSES] Machinery Directive Exemption for products specially
designed and constructed for military purposes
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 is
[email protected]<mailto:[email protected]>.or
my home Emaol address [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]
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