Hi Mike,
Thanks for short and long answer :)
Reading RED Guide I understand: If RED than no EMCD and no LVD but it is
_only_ guide.
With EMCD everything is clear - in EMCD RED (R&TTE) devices are clearly
excluded from EMCD scope.
There is no such exclusion in LVD.
Reading RED I'm not sure how to read it to understand it (about LVD) the
same way as the RED Guide.
I really understand 1,4 and 3,1 (a) as RED devices are covered by LVD
(in some aspects but it looks for me as all aspects).
Regards
Piotr
W dniu 2017-08-02 o 16:19, Mike Sherman pisze:
Short answer: no.
Long answer: look at sections 9.5 and 11 of the "RED Guide," the Guide
to the Radio Equipment Directive 2014/53/EU dated 19 May 2017.
Mike Sherman
Graco Inc.
------------------------------------------------------------------------
*From: *"Piotr Galka" <[email protected]>
*To: *"EMC-PSTC" <[email protected]>
*Sent: *Wednesday, August 2, 2017 8:58:54 AM
*Subject: *[PSES] RED DoC and LVD
Dear list members,
I'd like to know if the RED DoC should list LVD or not.
RED says:
1,4.Radio equipment falling within the scope of this Directive shall not
be subject to Directive 2014/35/EU, except as set out in point (a) of
Article 3(1) of this Directive.
3,1. Radio equipment shall be constructed so as to ensure: (a) the
protection of health and safety of persons and of domestic animals and
the protection of property, including the objectives with respect to
safety requirements set out in Directive 2014/35/EU, but with no voltage
limit applying;
Annex V (DoC) 5: relevant Union harmonisation legislation: -RED, - Other
Union harmonisation legislation where applicable.
I really can't say that being/not being subject to LVD is clear for me
here!
My understanding:
3,1(a) - protection of persons, animals and property covers really the
whole LVD requirements (extending its range on low voltage devices).
1,4 - Radio equipment is not subject to LVD but in aspects from 3,1(a)
it is subject to LVD.
So, as 3,1(a) covers the whole LVD requirements the RED device is
subject to LVD so LVD is applicable and should be listed in RED
equipment DoC.
May be my understanding stand up from that then till now, I have been
reading the RED in Polish version. I have opened English version for
first time when I come to copy citations from RED to this post.
Translating Polish to English it would be something like that:
1.4 Radio devices ... are not subject to LVD, except cases defined in
3,1(a).
The essence of my question is:
Do the 'except' in 1.4 should be understand that what is after 'except':
- describes aspects of LVD in which the RED devices are subject to LVD,
- describes requirements from LVD to be applied to RED devices without
understanding that they are subject to LVD.
Or may be my mistake is that I don't see what parts of LVD are not
covered by 3,1(a).
This leads to reading LVD Annex I and selecting points which should be
not applied to RED devices as being not covered by 3,1(a) (can be the
next question if here the decision would be to go that way).
If I can be sure that at least one of points from LVD Annex I is not
covered by 3,1(a) than I can understand that RED devices are not subject
to LVD and only some points from LVD Annex I should be applied as
requirements of applying RED and not requirements of applying LVD.
I hope you help in my doubts.
Best Regards
Piotr Galka
MicroMade
Poland
-
----------------------------------------------------------------
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] <mailto:[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] <mailto:[email protected]>>
Mike Cantwell <[email protected] <mailto:[email protected]>>
For policy questions, send mail to:
Jim Bacher <[email protected] <mailto:[email protected]>>
David Heald <[email protected] <mailto:[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]>
