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 ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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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)<http://www.ieee-pses.org/list.html> 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. 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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)<http://www.ieee-pses.org/list.html> 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]>> ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. 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