For the LVD, the assumption is that the always is a relevant harmonized standard. This is because third-party safety certification was the rule for very many years before the LVD, so safety standards already existed.
With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. -----Original Message----- From: Scott Xe [mailto:[email protected]] Sent: 21 July 2017 18:01 To: [email protected] Subject: Re: [PSES] Harmonised standard withdrawn [60335-2-24] Hi Chuck, Appreciate your good advice!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 > > > > - > > ---------------------------------------------------------------- > > > > 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]> > > > > > > > > - ---------------------------------------------------------------- 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]> - ---------------------------------------------------------------- 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]>
