Hi Chuck, If we have to look after the additional concern in safety compliance, ie. fire risk for this case, should we put the compliance standard under the risk assessment of LVD or the applicable standards under LVD?
Regards, Scott On 22/7/2017, 10:31 AM, "Scott Xe" <[email protected]> wrote: 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]>
