In reviewing the Machinery Regulation, Article 3
defines a safety component as
"...means a physical or digital component, including software, of a product within
the scope of this Regulation, which is designed or intended to fulfil (sic) a safety
function and which is independently placed on the market, the failure or
malfunction of which endanger the safety of persons, but which is not necessary in
order for that product to function or for which normal components may be substituted
in order for that product to function;
(emphasis added.)
The component falls under Annex I, Part, B but is
only sold to OEMs
1) whose equipment would clearly fall under the
Regulation, and
2) who integrate the component into other equipment
before that other equipment is placed on the market,
but
3) is not "independently placed on the market," for
general sale,
is there any reason to conclude that the Regulation
does not apply to the component?
The product is sold into the EU for applications
other than those that would be subject to the
Regulation, so it seems that applicability could
depend on the interpretation of "independently" in
the context of the regulation. Or is the use of
"independently" intended to mean "not manufactured
by the OEM for their own use?"
I note that similar language existed in the
Machinery Directive.
My approach is to apply an abundance of caution and
presume the Regulation applies, but I'd appreciate
the input of the group.
A final couple of questions: should it be assumed
that the same standards published in the EU OJ for
the Machinery Directive will satisfy the Regulation
until a separate list of standards is published and
linked to the Regulation? Also, is there a view on
when such a list will be published?
Regards,
Peter Tarver
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