The keys to product modification in the field vs. maintaining certification are - (a) Is the field modification acceptable to the certifying body? Ordinarily, certification is only for the product as built and shipped from the factory, along with applicable assembly and installation instructions. Field modification without prior approval usually would be considered to invalidate the existing certification, unless the modification is trivial for safety purposes. If the factory inspector from the certifying body would accept the same modification done in the factory without comment, then you may be OK. (b) Who has responsibility - manufacturer, importer, distributor or user/customer? The certification from the manufacturer will cover a specific construction, configuration and usage. However, an end user certainly can get certification for machinery that has been considerably modified from what the manufacturer provided. Of course that would require a new DofC and CE Marking. But if the manufacturer provides the means to do the modification, then the manufacturer apparently is accepting responsibility - even if the modification has not been accepted by the certifying body and therefore invalidates the certification!
Best regards, John McBain On Fri, Jun 2, 2023 at 9:33 AM Lauren Crane < 00001afd08519f18-dmarc-requ...@listserv.ieee.org> wrote: > Hi Steve, > > > > My Friday 2c… > > > > There is a trend of “right to repair” legislation that might > contraindicate that position to some extent. See e.g. > https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023PC0155 > > > > It seems odd that the approval of a product would depend on the whether > the end user can modify the product or not. There isn’t a certified item I > have that I can’t modify in some dangerous way. There is an important > difference between de-certification of a product unit because it has been > modified vs. de-certification of a product line because it can be modified. > > > > Best Regards, > > -Lauren > > > > *From:* sgbrody <sgbr...@comcast.net> > *Sent:* Thursday, June 1, 2023 5:51 PM > *To:* EMC-PSTC@LISTSERV.IEEE.ORG > *Subject:* [PSES] PLC password > > > > > > *External Email:* Do NOT reply, click on links, or open attachments > *unless* you recognize the sender and know the content is safe. If you > believe this email may be unsafe, please click on the “Report Phishing” > button on the top right of Outlook. > > > > I have been asked if there is a standard, or comments within s standard, > that discusses giving a customer the password to allow them to reprogram > the PLC when they remove a device and the light curtain that protected it. > > > > I believe, that other than it being a terrible idea, that it would > probably invalidate any approvals the end product had. > > > > The customer is asking for a document that supports my opinion. > > > > I dud suggest that we send a service person to do the change, and not give > up the pw. > > > > Thoughts? > > > > > > > > Sent from my T-Mobile 5G Device > > > > - > ---------------------------------------------------------------- > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. 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