I agree with everything Charlie says. Try talking to some Machinery Notified Bodies instead of ex-LVD Notified Bodies.
Happy to help further if you want to contact me directly. Nick. > On 30 Mar 2017, at 20:22, Charlie Blackham <[email protected]> > wrote: > > Brian > > Few comments: > The scope of the Directive determines applicability, not the scope of the > standards – standards are just a way of demonstrating compliance with > Directives, which are law (when transposed in national legislation). > Directive comes first, standard a distant second. > There aren’t any Notified Bodies to the LVD, (check here > <http://ec.europa.eu/growth/tools-databases/nando/index.cfm?fuseaction=directive.main>), > so all you are getting is a report from a lab that is accredited against a > standard, and an accredited report is not a 100% guarantee that the correct > thing has been done. > The manufacturer is always legally responsible > “But sir, that’s what they do” is not a legal defence I’d recommend :) > You can apply any standards you wish to support compliance to the MD – > there’s nothing to stop you using EN61010-1 for clause 1.5.1 (and probably a > few others) > The LVD update was just an NLF alignment for market enforcement, and did not > change its scope > Machinery Directive Notified Bodies only really deal with Annex IV > > > My view is: > The application of the Machinery Annex I EHSRs to something that is not very > “machine like” shouldn’t be too onerous > If in doubt, applying the MD instead of the LVD would only mean that you may > have done too much, so would always be a defensible position, the reverse is > not true. > > Regards > Charlie > > Charlie Blackham > Sulis Consultants Ltd > Tel: +44 (0)7946 624317 > Web: www.sulisconsultants.com > <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> > Registered in England and Wales, number 05466247 > > From: Kunde, Brian [mailto:[email protected] > <mailto:[email protected]>] > Sent: 30 March 2017 19:19 > To: [email protected] <mailto:[email protected]> > Subject: [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]>> > > - > ---------------------------------------------------------------- > 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]>
