All,
Well letting it stew longer usually makes the soup thicker.
The mfgrs of semi processing equipment worked to get
clarification hoping to use 61010 as the basis for the electrical portion of
their CE certification but using the needed machinery standards for mechanical
hazards. This would allow a full CE cert invoking both the MD and the LVD.
The EU fathers, however, didn’t want to go that direction so another part of
60204 has been developed to with cover these units – done in parallel the TC66
efforts to develop their -2-120 machinery standard covering the needed
mechanical req’mts.
So it appears that those folks have two paths to full
certification and could invoke both the MD and the LVD in their Declaration
(which, it seems, is most pleasing to low level approval folks who have to
accept the Declaration and don’t want to spend too much time deciding if all
the necessary things have been covered.
The nightmare is spreading, equipment is getting more complex
and larger so the boundaries are being stretched or broken down. Hopefully,
the system will get some sense and work to allow any combo of technical
requirements to show compliance – electrical requirements for the LVD and
mechanical requirements for the MD. We’ve done that many times in the past
and it has worked well technically. o
I vote for watering the soup and not serve stew.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
<mailto:[email protected]> [email protected]
From: Peter Tarver [mailto:[email protected]]
Sent: Friday, March 31, 2017 9:05 AM
To: [email protected]
Subject: Re: [PSES] MD vs LVD for Laboratory Equipment
I’m with you here, Dave. Just because a product contains a cooling fan should
not mean the MD applies. But then, the products you cite are explicitly
excluded from the scope of the MD (I’m sure you know this, since it appears you
took the text directly form the MD).
However, in Article 2 of the MD, where the text Doug mentions is located, goes
on to say that they’re, “intended for lifting loads and whose only power source
is directly applied human effort.” This encompasses:
• automotive lifts and jacks
• come-alongs
• block and tackle sets (if sold as a unit)
Peter Tarver
From: Nyffenegger, Dave
Sent: Thursday, March 30, 2017 17:40
But there are products meeting that definition of machine that are covered by
the LVD and specifically excluded from the MD:
— household appliances intended for domestic use,
— information technology equipment,
— ordinary office machinery,
-Dave
From: Douglas Nix
Sent: Thursday, March 30, 2017 5:20 PM
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] <mailto:[email protected]>
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