Dear Scott:
It does. See Articles 13 and 14 of 2014/35/EU
Regards,
Chuck Seyboldt
(207) 893-0352
(207) 838-4026 Cellular
(800) 893-8142 Facsimile
At 13:00 (-0000) on 17.07.21, Scott Xe wrote:
Hi Chuck,
Appreciate your good advice!
In other directive, such as RED, if harmonised standard is not
available, relevant national or international standard can be
used. Is there any reason for LVD not to have these options?
Regards,
Scott
On 22/7/2017, 12:47 AM, "Chuck Seyboldt" <[email protected]> wrote:
Dear Scott:
I wouldn't worry much about market surveillance. What
I've done in some cases is have the Declaration cite the standard
mostly followed (even if not harmonized), and list qualifications
or exceptions, etc. to make the market surveillance conformity
assessment job easier.
The typical case is some concerned enforcement authority
asserting non-compliance or seeking more information. Try to
anticipate the question and answer it on the face of the
Declaration. Otherwise the manufacturer has to deal with the
phone calls and rejection letters as they come in.
Given the nature of withdrawal of 60335-2-24, the
statement might be along the lines of "EN 60335-2-24 except rear
panel is ...." and give a clinical description of the back panel,
flame rating, non-flammable, or whatever. That addresses the
specific reason for the withdrawal, and shows manufacturer
awareness of the issue.
Everybody involved should have the same interest, which
is no reasonable person is injured by a product, when the injury
could have been prevented with a reasonable design alternative.
I know that's vague, but it is the legal standard. In court, the
question is settled by the better of the opposing experts.
Conformity with a standard does not confer immunity from
liability. It only shifts the burden of offering the marginally
safer design to the injured plaintiff's expert.
Market surveillance folks don't have time for that.
They are taught to look for quick outward signs. Brief statement
on the Declaration takes care of their protocol.
Regards,
Chuck Seyboldt
(207) 893-0352
(207) 838-4026 Cellular
(800) 893-8142 Facsimile
At 12:11 (-0000) on 17.07.21, Scott Xe wrote:
> Hi Chuck,
>
> Thanks for your guidance! The source is useful to know the
> reason(s) of objection. It will leave the supplier how to
> tackle those issues. How can the market surveillance determine
> the adequate level of acceptance?
>
> Regards,
>
> Scott
>
>
>
> On 20/7/2017, 10:49 PM, "Chuck Seyboldt" <[email protected]> wrote:
>
>
> Find the reason for the withdrawal, and adapt inspection to
> account for that.
>
> Even short of withdrawal, it is prudent to keep abreast of
> objections to standards.
>
> Formal Objection against EN 60335-2-24:2010 Household and similar
> electrical appliances - Safety - Part 2-24: Particular
> requirements for refrigerating appliances, ice-cream appliances
> and ice makers
>
> https://ec.europa.eu/docsroom/documents/19502
>
> For other objections, see this URL ...
>
>
http://ec.europa.eu/growth/single-market/european-standards/notification-system_en
>
> Chuck Seyboldt
>
> (207) 893-0352
> (207) 838-4026 Cellular
> (800) 893-8142 Facsimile
>
> At 10:37 (-0000) on 17.07.20, Scott Xe wrote:
>
> > The harmonised standard EN 60335-2-24 is removed from the
> > harmonised standard list on OJEU. The common compliance route
> > of self-declaration of conformity to LVD using harmonised
> > standard becomes lost. What are other options to demonstrating
> > the compliance with LVD?
> >
> >
> >
> > Thanks and regards,
> >
> >
> >
> > Scott
> >
> > -
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All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at
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