Dear Scott:
It doesn't matter where, except for convenience or "luck"
in finding the remark should the need arise.
In general, I structure the report to follow the
statements on the face of the Declaration. In this case, I
suggested declaring compliance with 60335-2-24 with exceptions.
So, I'd have substantive remarks at the appropriate section or
sections of the 60335-2-24 checklist, with the substantive
remarks describing how the article or test protocol deviates from
the standard and WHY.
If the risk assessment has a part relating to fire, and
the approach taken is usually limited to "see 60335-2-24
checklist" (fire being possible due to MANY factors), I would
either say nothing different - the substantive remarks under the
standard speak for themselves - or I would amend the remarks to
"meets 60335-2-24 except [cite ONLY clause number where the
substantive remarks were recorded]."
It would be nearly as convenient if the reverse practice
was followed. That is, have the substantive remarks in the risk
assessment, and then in the related part or parts of the
60335-2-24 checklist, refer to that specific part of the risk
assessment.
In addition to trying to make a "substantive observation
of interest" easy to find, another principle I try very hard to
follow is to limit detail design or execution observations to ONE
PLACE in the report, and then refer to that part as needed.
That way, if the report is amended to reflect a revised design,
there is less risk of having inconsistent observations recorded
in the report.
Regards,
Chuck Seyboldt
(207) 893-0352
(207) 838-4026 Cellular
(800) 893-8142 Facsimile
At 04:19 (-0000) on 17.07.22, Scott Xe wrote:
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?
-
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