Charlie

Thanks for taking the time to reply. I agree that military products are only 
exempt from some of the CE Marking, those you have listed and the Machinery 
Directive.

Regards

Philip Stevenson - BSc(Eng), BSc(Open) (Hons), MSc (Open) (M:MT) CEng MIET MIEEE
Senior Specialist Engineer - Electronics, Advanced Weapons, Belfast

Thales
Land & Air Systems
Alanbrooke Road, Belfast, Northern Ireland, BT6 9HB
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From: Charlie Blackham [mailto:[email protected]]
Sent: 02 July 2019 13:12
To: [email protected]
Subject: [EXTERNAL EMAIL] Re: [PSES] ATEX Directive Applicability to Airborne 
Military Products

Doug

Military products are exempted under certain Directives, such as RoHS and RED, 
“exclusively used for activities concerning public security, defence, State 
security”, but there’s no such exemption in other Directives such as EMC and LVD

Some earlier versions of Directives, such as EMC, had exemptions, but no longer

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Douglas Nix <[email protected]>
Sent: 02 July 2019 12:44
To: [email protected]
Subject: Re: [PSES] ATEX Directive Applicability to Airborne Military Products

Military products are excluded from the CE Marking requirements. Check the Blue 
Guide for details.

https://ec.europa.eu/growth/content/‘blue-guide’-implementation-eu-product-rules-0_en
Best,
Doug Nix

[email protected]<mailto:[email protected]>
Mobile: (519) 729-5704

On Jul 2, 2019, at 06:31, STEVENSON Philip 
<[email protected]<mailto:[email protected]>>
 wrote:
Dear Members
I am looking for information on whether the CE Marking ATEX Directive 
2014/34/EU is applicable to Airborne Military Products or not? This is because 
I have no previous experience of applying or assessment of the ATEX Directive.
The Military Product is a detachable Airborne Launcher that is designed to be 
fitted to an Air Platform. The Airborne Launcher is designed to fire Explosive 
Munitions under control of the Air Platform.
The ATEX Directive 2014/34/EU Chapter 1 Article 1 Scope clause 2 (b) states 
“equipment and protective systems where the explosion hazard results 
exclusively from the presence of explosive substances or unstable chemical 
substances.”. In my research I have found technical articles on the ATEX 
Directive which state that “equipment using explosive products” are excluded 
from the scope of the directive! My initial thoughts where that this exclusion 
applied but the use “exclusively” in the statement is causing me concern. This 
is because the Airborne Launcher is also operating in an air platform fuel-air 
explosive atmosphere and not “exclusively” in the presence the Explosive 
Munitions. But I could find no further clarification on this in the EU ATEX 
Guidelines.
Note the Explosive Munition is covered by a separate CE Marking assessment and 
therefore is not part of this assessment.
This military product is not covered by the Article 346 exemption for military 
equipment but has its own documented Safety Case. It has also been assessed for 
potential sources of ignition which concluded that the potential ignition 
sources on their own could not facilitate the ignition in an air platform 
fuel-air explosive atmosphere.
Therefore based on this information should this product be included or excluded 
from the scope of the ATEX Directive?
Finally if it is within the scope of the ATEX Directive would I be required to 
involve a Notified Body in the assessment or not?
Any help and advice would be greatly appreciated. If you would prefer to 
contact me off-line my contact Email addresses are listed below and I will not 
put any off-line replies on the PSES Server.

Regards
Philip Stevenson
Work Email: 
[email protected]<mailto:[email protected]>
Home Email: [email protected]<mailto:[email protected]>

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