I concur with Michael Loerzer. IMO, the test labs didn’t feel comfortable doing MD evaluations, so they used the “out” that was in the text of the previous MD (98/37/EC) that said that if the hazards were ‘predominantly electrical in nature” then the MD needn’t apply. Many machines were “slid-past” based on this misuse of the text of the MD, which is why the text was changed in the 2006 edition.
If the device is “an assembly of linked parts, at least one of which moves” it’s a machine. -- Doug Nix [email protected] “Scientists investigate that which already is; Engineers create that which has never been.” - Albert Einstein > On 30-Mar-17, at 17:03, Kunde, Brian <[email protected]> wrote: > > Michael, > > That sounds great. > > I have emails from the TUV:Rheinland inspector who presented his position on > the Cut-off Saw he evaluated to why it should be declared under the LVD and > not the MD. I can send you those emails if you think that would be helpful. > > Looking forward to hearing more from you. Sorry if do not always use the > correct wording or terminology. We are a relatively small company and don’t > have people sitting on committees or attending meetings on these topics. We > must rely on others, such as what consultants tell us, what we read in > publications, from test reports and what test labs tell us, field inspectors, > what our customers expect, and what our competitors are doing. When these > sources start doing things that are different from what we are doing, it is > my job to try and figure out why. > > Thanks so much for your help with this. > > Brian > > > From: [email protected] <mailto:[email protected]> > [mailto:[email protected] <mailto:[email protected]>] > Sent: Thursday, March 30, 2017 4:23 PM > To: Kunde, Brian; [email protected] > <mailto:[email protected]> > Subject: AW: [PSES] MD vs LVD for Laboratory Equipment > > Second comment: on 8th of May, 2017 I have a meeting with the responsible > market surveillance authority in Baden-Wuerttemberg regarding our > experiences, “blooper” and open questions of manufacturers/importers. If you > like I can discuss your “story/experiences” with these officials because one > of the participants is the German representative for the MD in Brussels. > > Michael > > Von: Kunde, Brian [mailto:[email protected] > <mailto:[email protected]>] > Gesendet: Donnerstag, 30. März 2017 20:19 > An: [email protected] <mailto:[email protected]> > Betreff: [PSES] MD vs LVD for Laboratory Equipment > > Sorry to say, this issue has once again reared its ugly head. I appreciate > any and all input. > > History: For many many years, laboratory equipment fell under the Low Voltage > Directive (LVD), even products with moving parts. It was specifically > excluded from the Machinery Directive (MD). The Safety Standard for > Laboratory Equipment EN 61010-1 is harmonized to the LVD. Life was good. > > Then a new version of the MD was released which did not exclude Laboratory > Equipment. Many of the EHSR from annex I did not apply and there were no > harmonized standards specific to laboratory equipment. So the same set of > safety rules that apply to Industrial/Factory Machinery must somehow be > applied to Carbon Analyzers, Calorimeters, Hardness Testers, and Mass > Spectrometers. Life sucks. > > BUT then the New Safety Standards EN 61010-1 3rd Ed. was released which > included hazards from Moving Parts and referenced a Risk Assessment for any > hazards not covered by the standard. The standard now covered all hazardous > conditions associated with Laboratory Equipment including moving parts, > electrical, chemical, hot/cold temperatures, radiation, pressurized fluids, > everything. AND THEN the new LVD was released which was aligned with the NLF. > Can Life be Good Again? > > The Topper: Recently we have been contacted by two different Notified Bodies > in Europe which has informed us that we should be using the LVD and not the > MD. When I asked for a reason why they basically said what I just typed > above. One NB lab in Italy just performed a Safety Evaluation on one of our > Cut-Off Saws (considered a prep machine for scientific analysis) and they > evaluated it to the EN 61010-1:2010 and the LVD. When I questioned this and > inquired about the MD, they argued that the LVD and EN 61010-1 NOW covers all > hazards assessed within the product and the MD would not be the appropriate > Directive. > > We have also started to see several of our business partners (companies we > work with to produce buy/sell options and laboratory peripherals with moving > parts like sample loaders) declaring compliance to the LVD instead of the > MD. As first I tried to correct them but then they sent us test reports from > NB labs in Europe evaluating their products to the LVD. Whodathunkit? > > However, I checked with the TUV:SUD lab we use here in the states and they > are still saying that the MD is the correct directive to use. Ok, now I’m > officially confused. > > So, has it officially changed? Or is it changing? Can manufacturers of > laboratory equipment go back to declaring compliance to the LVD even if their > products have moving parts? Has anyone seen any official new releases, > articles, decisions, on this topic? Does anyone want to research and write > an Article on this topic? > > Is there an official authority who can once and for all settle this topic of > continuing conflict, nightmares, and ulcers? > > Thanks for your time. > 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 > <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]>> > > 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 > <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]>
