Hello. For the following, I have (nearly) concluded that the Machinery Directive applies, but I have some lingering uncertainty. I'm looking for reasonable arguments to say that it does or doesn't apply before I dive headlong into the tasks related to supporting a declaration against the Machinery Directive.
Consider a product that is completely sealed but contains a rotating mass. The mass rotates as a primary part of the product's function. In the strictest sense, it is (or contains) a machine. However, any number of products contain rotating masses (e.g., fans) that are not generally subject to the Machinery Directive and which have other standards under the Low Voltage Directive that address the relevant safety concerns. Among the many use cases for the product are autonomous or robotic mail delivery and security systems, which will move along the ground or along floor surfaces. These pieces of motive host equipment would require application of the Machinery Directive. For these and other use cases,the product could serve as a safety component, though perhaps not in any traditional sense, but within the context of Annex V of the Machinery Directive. There are no specific standards in the OJ list of harmonized standards that apply directly to the product's primary applications function, so I assume EN 60204-1 will apply, with perhaps some peripheral standards that are in the OJ list. FWIW, I've performed a review of the mechanical hazards using IEC 62368-1 and found that the product falls squarely into MS1. What ever arguments you can make either in favor of applying the Machinery directive or against it are welcomed and encouraged. I look forward to hearing from you. Peter - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
