Hi Chuck, Thanks for your good pointer!
Regards, Scott On 22/7/2017, 1:23 AM, "Chuck Seyboldt" <[email protected]> wrote: 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 > > > > > > - > > > ---------------------------------------------------------------- > > > > > > 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]>
