That’s what I was questioning.  I’ve not had to certify anything like those 
direct drive products.  But as Doug pointed out earlier if attaching a blade to 
a motor shaft with a screw is considered linkage then it would fall under the 
MD if not excluded for other reasons.

-Dave

From: Kunde, Brian [mailto:[email protected]]
Sent: Thursday, February 01, 2018 1:27 PM
To: Nyffenegger, Dave; [email protected]
Subject: RE: [PSES] GFCI vs GFPE

Dave,

I’ve never heard this position taken on the machinery directive before.  So are 
you saying that anything “direct driven” or that has “direct drive” would not 
meet the definition of a “machine” and thus, not fall under the Machinery 
Directive?  So a saw blade or fan blade mounted directly on the motor shaft is 
not a machine?

But add a belt, or gear, or some other form of energy transmission, and then 
the product falls under the MD.  Is that what you are saying?

If so, I’ll have to re-evaluate everything I’ve done for the last 10 years.  Oh 
well, what else do I have to do?  ☺

I appreciate your comments.
The Other Brian

From: Nyffenegger, Dave [mailto:[email protected]]
Sent: Wednesday, January 31, 2018 5:38 PM
To: [email protected]
Subject: Re: [PSES] GFCI vs GFPE

The pivoting arm operated by human effort would be out of scope of machinery 
definition.  Which leaves just the motor with no real linkage to the blade 
since the blade is screwed directly to the end of the motor shaft.  A 
sophisticated saw perhaps for commercial/industrial use may have a driven arm 
and may use belts/pulleys/gears to drive the blade, would easily fit the 
machinery description.  The same question applies to an inexpensive direct 
drive table saw with no driven parts other than the motor with a blade mounted 
to the end of the shaft vs. a professional grade table saw with a pulleys and 
belt driven blade.

-Dave

From: John Woodgate [mailto:[email protected]]
Sent: Wednesday, January 31, 2018 5:23 PM
To: Nyffenegger, Dave; 
[email protected]<mailto:[email protected]>
Subject: Re: [PSES] GFCI vs GFPE


There is a motor and a blade, which both move and are linked. In a cut-off saw, 
If I have the term right, the whole motor and blade housing swings on a pivot 
at the back of the baseplate.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-01-31 21:33, Nyffenegger, Dave wrote:
I am surprised a basic cut-off saw would fit the definition of ‘machine’ for 
the MD since cut-off  saws (the one’s I’m thinking of) are basically just a 
motor with a blade mounted directly to the armature and I don’t know that the 
blade is even considered part of the product.  Not really an assembly of linked 
parts at least one of which moves, and which are joined together for a specific 
application.

-Dave

From: John Woodgate [mailto:[email protected]]
Sent: Wednesday, January 31, 2018 1:58 PM
To: [email protected]<mailto:[email protected]>
Subject: Re: [PSES] GFCI vs GFPE


IEC 62841 is a multi-part standard with 23 documents. But it's all about 
'hand-held', so unless the 300 lb product is intended for Superman or King 
Kong. they don't apply.

Wiring codes do not specify requirements for load products, except in very 
general terms. Safety requirements for products are in product safety standards.

In Europe, a cut-off saw is a 'machine', so the Machinery Directive applies. 
This influences which safety standard is permitted to be applied to the product.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-01-31 18:38, Kunde, Brian wrote:
Most interesting.  Thanks.

From: [email protected]<mailto:[email protected]> 
[mailto:[email protected]]
Sent: Wednesday, January 31, 2018 1:27 PM
To: Kunde, Brian
Cc: EMC-PSTC
Subject: [BULK] Re: [PSES] GFCI vs GFPE
Importance: Low

IEC TC 116 in in the process of folding the 60745-1 (hand held motor operated 
tool) standards into the 62841 series (Electric motor-operated hand-held tools, 
transportable tools and lawn and garden machinery). See their dashboard at:
http://www.iec.ch/dyn/www/f?p=103:30:13397277133783::::FSP_ORG_ID,FSP_LANG_ID:4112,25

My reference was not from a part 2, but actually from section 21.16 of 60745-1:
"

Tools employing liquid systems shall protect the user against the increased 
risk of
shock due to the presence of liquid under conditions of normal use and the 
faults of the liquid
system.
Tools employing liquid systems shall be either:
• of class III construction;
• of class I or class II construction and be provided with a residual current 
device and comply
with 14.4, 14.5 and 14.6; or
• of class I or class II construction and be designed for use in combination 
with an isolating
transformer and comply with 14.4 and 14.5.
"
Section 14.4 describes using a salt water mix to simulate overfilling or 
misassembling and then testing for leakage.

I do not know whether your product falls within scope of 62841; perhaps your 
favorite NRTL could help. Your favorite NRTL might even have someone on the 
committee who could help with a question.

Mike

________________________________
From: "Brian Kunde" <[email protected]<mailto:[email protected]>>
To: [email protected]<mailto:[email protected]>
Cc: "EMC-PSTC" <[email protected]<mailto:[email protected]>>
Sent: Wednesday, January 31, 2018 11:58:25 AM
Subject: RE: [PSES] GFCI vs GFPE

Mike,

Thanks for your offer. I assume the requirement for RCD is limited to hand-held 
or portable power tools that uses water. This is interesting because I didn’t 
know this was a requirement.

In our case, the cut-off saw we are looking at weighs over 300 lbs. Defiantly 
not hand-held any probably not considered portable (depending on your 
definition).

Do you know if there are similar requirements for non-hand-held electric 
saws/tools?

Thanks,
The Other Brian

From: [email protected]<mailto:[email protected]> 
[mailto:[email protected]]
Sent: Wednesday, January 31, 2018 12:29 PM
To: Kunde, Brian
Cc: EMC-PSTC
Subject: Re: [PSES] GFCI vs GFPE

Brian --
I think I've seen a Part 2 standard for 60745-1, as I recall, that required a 
RCD if the tool used water and the water ended up in the wrong place 
electrically. If you'd like a screen shot of the section, I can probably find 
it for you.
Mike Sherman
Graco Inc.

________________________________
From: "Brian Kunde" <[email protected]<mailto:[email protected]>>
To: "EMC-PSTC" <[email protected]<mailto:[email protected]>>
Sent: Wednesday, January 31, 2018 11:06:36 AM
Subject: Re: [PSES] GFCI vs GFPE

Where Pete stated, “The Euro systems use of RCDs require this protection in 
many installations (but I’m not familiar with the installation code details)”. 
This “Code” is probably what I am seeking.

Has anyone run across a Code rule that requires the Product to employ a RCCB 
within the product?  If the local electrical code requires a RCCB, cannot this 
protection be provided as part of the site protection?  Why burden the cost of 
a product where such a requirement may only be necessary in a small percentage 
of installations?

The main purpose of my question on this topic is cost.  Here in the USA, a GFCI 
receptacle is very inexpensive; costing around $10 at most home stores.  But a 
3-phase RCD Circuit Breaker can cost $300-$400.  On some products, such as a 
tile saw that uses water, this can more than double the cost of the entire 
product.  So knowing when and where they are required is very important.

Thanks again to everyone for your consideration.  From what I have read so far 
on this topic, it is a moving target as electric codes from different states 
and countries are always evolving and the code governing the requirements of 
RCDs and GFCIs are common to change.

Thanks,
Brian


From: John Woodgate [mailto:[email protected]]
Sent: Wednesday, January 31, 2018 11:13 AM
To: Kunde, Brian; [email protected]<mailto:[email protected]>
Subject: Re: [PSES] GFCI vs GFPE


You can rely on the recent post in this thread by Pete Perkins.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-01-31 15:52, Kunde, Brian wrote:
Thanks for the input everyone.

I know that GFCI protectors in North America will trip between 4-6mA.  Do other 
countries, such as Europe, have the same requirements?
Or are 30mA protectors used in Europe? If so, does Europe use 30mA ground fault 
protectors because of nuisance tripping even though the studies have shown that 
30mA can be fatal?

These 3-phase cut-off saws that I’m evaluating comes with a power cord, but no 
plug. They can be field wired or a plug could be added and plugged it into a 
receptacle.  The choice is left up to the customer.

The saw uses water but the work environment would not normally be considered a 
“wet location”.  It would not be used in a construction location.

So again, I’m trying to figure out why the saw manufacturer used the expensive 
30mA ground fault breakers in their product.

Thanks,
The Other Brian





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