[PSES] List of Machinery Harmonised Standards

[Nick Williams]

I suspect others were, like us, disappointed that back in March the European 
Commission deleted the online list of standards Harmonised under the Machinery 
Directive from the Europa server. They replaced it with links to a couple of 
downloadable files which are a lot less convenient. 

For our own benefit, and also because it may be of use to others, we have 
resurrected the online list as a web page which you can find at 
https://www.conformance.co.uk/table-of-standards-harmonised-to-the-machinery-directive
 
.

Please let us know if you find this useful, or spot any errors. 

Thanks and regards

Nick. 
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Re: [PSES] Automated listserv error message

[Nick Williams]

It’s not just gmail accounts - I got the same message and my mail goes nowhere 
near gmail. 

If this message gets through then I have not been unsubscribed no matter what 
the message said!

Nick. 


> On 24 Apr 2019, at 16:32, Doug Powell  wrote:
> 
> All,
> 
> Yesterday I received what was called an automatic removal message from
> the listserv.  The subject line was "Your removal from the EMC-PSTC
> list".  And indeed, I was unsubscribed for the first time since 1997.
> I wondered if anyone else with a gmail account has this problem.
> 
> I was advised to contact my email administrator and of course you can
> see I am on gmail.  Apparently there were three separate message
> rejections with error 5.0.0
> 
> Best, Doug
> 
> -- 
> 
> Douglas E Powell
> 
> doug...@gmail.com
> http://www.linkedin.com/in/dougp01
> 
> -
> 
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> 
> 
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Re: [PSES] Brexit and impact on offical langugages

[Nick Williams]

English is an Official Language in Malta as well as Ireland. 

Nick. 


> On 7 Mar 2019, at 17:56, Doug Powell  > wrote:
> 
> All,
> 
> With March 29 approaching, I've seen plenty of discussion on the impact of 
> Brexit.  However, I've seen virtually nothing on official languages of the 
> EEC.  And in particular how this might affect Declarations of 
> Conformity/Incorporation as well as labeling and user documentation.  In the 
> past, my advice has always been to start with one of the official languages 
> and if requested by the end user to provide in another language this then 
> becomes mandatory.  With implementation of Brexit is English no longer an 
> official language of the community?  
> 
> This seems an interesting question to me because it seems that English / 
> French will remain intact for the IEC in Brussels.  I suppose we can continue 
> to watch the O.J. after the withdrawal of Britain.
> 
> Best to all,  Doug
> 
> -- 
> Douglas E Powell
> doug...@gmail.com 
> http://www.linkedin.com/in/dougp01 
> -


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Re: [PSES] CE marking of machinery that moves about

[Nick Williams]

Mobile machines are addressed by section 3 of Annex 1 of the Machinery 
Directive. Machines for lifting loads are addressed by section 4. Machines for 
lifting people are addressed by section 6. 

Regards

Nick. 

> On 2 Aug 2018, at 13:28, Pete Perkins 
> <0061f3f32d0c-dmarc-requ...@ieee.org> wrote:
> 
> Colleagues, I’ve been dealing with CE marking of machinery for some 
> time but now am interested in a variation on that theme, machinery that 
> moves.  Think of a fork-lift or front loader each of which lifts a load and 
> moves it before setting it down again.  What additional requirements are 
> placed upon such a machine.  
>  
> :>) br,  Pete
>  
> Peter E Perkins, PE
> Principal Product Safety & Regulatory Affairs Consultant
> PO Box 23427
> Tigard, ORe  97281-3427
>  


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[PSES] Machinery Directive consultancy

[Nick Williams]

Due to a significant upturn in our workload in the last few months, Conformance 
Ltd are looking to recruit additional personnel. We’d be interested in speaking 
to anyone with experience in CE marking related compliance work but 
particularly we are seeking people with experience of performing risk 
assessments under the Machinery Directive and applying harmonised standards. We 
will consider people for both employee and subcontract status. Candidates will 
need to be UK based. 

Please contact us via the e-mail address mailto:vacanc...@conformance.co.uk>> if you are interested or if you want 
further information. 

Nick. 

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Re: [PSES] Medical device risk assessment - faulty chargers

[Nick Williams]

I knew someone would come back with that reply. 

Technically, it may or may not be correct (does a palliative involve an 
interchange of energy?) but in practice it stretches the original assertion 
beyond any useful application. 

As ever, real life is more complex than it is possible to express in one neat, 
pithy phrase. 

Nick. 




> On 17 Apr 2018, at 21:05, John Woodgate <j...@woodjohn.uk 
> <mailto:j...@woodjohn.uk>> wrote:
> 
> If the device transfers energy, but the energy proves ineffective, that is 
> still an 'energy interchange'.  If the device fails to transfer energy, there 
> is no 'cause' to produce an 'effect', so any injury is not due to the device 
> but to some other energy interchange.
> 
> Do we rename the list 'IEEE Philosophical Society'?(;-)
> John Woodgate OOO-Own Opinions Only
> J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk/>
> Rayleigh, Essex UK
> On 2018-04-17 20:24, Nick Williams wrote:
>> In the medical device context, no this is not correct because the failure of 
>> the device to provide the claimed medical benefit can be a cause of ‘injury’.
>> 
>> Nick. 
>> 
>> 
>>> On 17 Apr 2018, at 20:17, Richard Nute <ri...@ieee.org 
>>> <mailto:ri...@ieee.org>> wrote:
>>> 
>>>  
>> 
>> 
>>>  
>>> Do you agree or disagree with James Gibson’s assertion that
>>>  
>>> “Injuries to a living organism can be produced only by some energy 
>>> interchange”?
>>>  
>>> (ISO 14971, C.2.5 recognizes energy transfer can result in injury.)   
>>>  
>> 
>> -
>> 
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> 
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> 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
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Hucklow Net Limited
The Old Methodist Chapel, Great Hucklow, 

Re: [PSES] Medical device risk assessment - faulty chargers

[Nick Williams]

In the medical device context, no this is not correct because the failure of 
the device to provide the claimed medical benefit can be a cause of ‘injury’.

Nick. 


> On 17 Apr 2018, at 20:17, Richard Nute  wrote:
> 
>  


>  
> Do you agree or disagree with James Gibson’s assertion that
>  
> “Injuries to a living organism can be produced only by some energy 
> interchange”?
>  
> (ISO 14971, C.2.5 recognizes energy transfer can result in injury.)   
>  


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[PSES] Medical device risk assessment - faulty chargers

[Nick Williams]

Colleagues,

EN 60601-1 3rd ed. requires the manufacturer to take a risk assessment based 
approach to the safety of their electrical medical products. 

With the increased used of universal USB power as a source for battery 
charging, it’s easy for the risk assessment to identify use of the medical 
device with a potentially faulty charger either because the device manufacturer 
has not included a USB power adapter/charger wth the product or because the 
user has chosen to use a charger other than the one supplied by the 
manufacturer. 

How far does the manufacturer need to go in order to provide protection against 
the hazards from a faulty charger, not supplied by them? Bear in mind the 
hazardous scenarios may include a patient contact device being used while being 
charged. 

I await opinions with interest!

NIck.

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[PSES] LVD Notified Body technical experts

[Nick Williams]

Yes, I am aware there is no such thing as an LVD NoBo these days, but I need a 
sanity check on an argument I am having with a client and could do with running 
some thoughts past one or two people who have in depth experience of LVD and UK 
Electricity at Work Regulations compliance work. Please contact me directly if 
you can spare 10 minutes of your time to review some information and express an 
opinion. 

Thanks

Nick. 

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Re: [PSES] MD vs LVD for Laboratory Equipment

[Nick Williams]

I agree with everything Charlie says. 

Try talking to some Machinery Notified Bodies instead of ex-LVD Notified 
Bodies. 

Happy to help further if you want to contact me directly. 

Nick. 


> On 30 Mar 2017, at 20:22, Charlie Blackham  
> wrote:
> 
> Brian
>  
> Few comments:
> The scope of the Directive determines applicability, not the scope of the 
> standards – standards are just a way of demonstrating compliance with 
> Directives, which are law (when transposed in national legislation). 
> Directive comes first, standard a distant second.
> There aren’t any Notified Bodies to the LVD, (check here 
> ),
>  so all you are getting is a report from a lab that is accredited against a 
> standard, and an accredited report is not a 100% guarantee that the correct 
> thing has been done.
> The manufacturer is always legally responsible
> “But sir, that’s what they do” is not a legal defence I’d recommend :)
> You can apply any standards you wish to support compliance to the MD – 
> there’s nothing to stop you using EN61010-1 for clause 1.5.1 (and probably a 
> few others)
> The LVD update was just an NLF alignment for market enforcement, and did not 
> change its scope
> Machinery Directive Notified Bodies only really deal with Annex IV
>  
>  
> My view is:
> The application of the Machinery Annex I EHSRs to something that is not very 
> “machine like” shouldn’t be too onerous
> If in doubt, applying the MD instead of the LVD would only mean that you may 
> have done too much, so would always be a defensible position, the reverse is 
> not true.
>  
> Regards
> Charlie
>  
> Charlie Blackham
> Sulis Consultants Ltd
> Tel: +44 (0)7946 624317
> Web: www.sulisconsultants.com 
> 
> Registered in England and Wales, number 05466247
>  
> From: Kunde, Brian [mailto:brian_ku...@lecotc.com 
> ] 
> Sent: 30 March 2017 19:19
> To: EMC-PSTC@LISTSERV.IEEE.ORG 
> Subject: [PSES] MD vs LVD for Laboratory Equipment
>  
> Sorry to say, this issue has once again reared its ugly head. I appreciate 
> any and all input.
>  
> History: For many many years, laboratory equipment fell under the Low Voltage 
> Directive (LVD), even products with moving parts. It was specifically 
> excluded from the Machinery Directive (MD). The Safety Standard for 
> Laboratory Equipment EN 61010-1 is harmonized to the LVD.  Life was good.
>  
> Then a new version of the MD was released which did not exclude Laboratory 
> Equipment. Many of the EHSR from annex I did not apply and there were no 
> harmonized standards specific to laboratory equipment. So the same set of 
> safety rules that apply to Industrial/Factory Machinery must somehow be 
> applied to Carbon Analyzers, Calorimeters, Hardness Testers, and Mass 
> Spectrometers. Life sucks. 
>  
> BUT then the New Safety Standards EN 61010-1 3rd Ed. was released which 
> included hazards from Moving Parts and referenced a Risk Assessment for any 
> hazards not covered by the standard.  The standard now covered all hazardous 
> conditions associated with Laboratory Equipment including moving parts, 
> electrical, chemical, hot/cold temperatures, radiation, pressurized fluids, 
> everything. AND THEN the new LVD was released which was aligned with the NLF. 
>  Can Life be Good Again?
>  
> The Topper:  Recently we have been contacted by two different Notified Bodies 
> in Europe which has informed us that we should be using the LVD and not the 
> MD.  When I asked for a reason why they basically said what I just typed 
> above.  One NB lab in Italy just performed a Safety Evaluation on one of our 
> Cut-Off Saws (considered a prep machine for scientific analysis) and they 
> evaluated it to the EN 61010-1:2010 and the LVD.  When I questioned this and 
> inquired about the MD, they argued that the LVD and EN 61010-1 NOW covers all 
> hazards assessed within the product and the MD would not be the appropriate 
> Directive.
>  
> We have also started to see several of our business partners (companies we 
> work with to produce buy/sell options and laboratory peripherals with moving 
> parts like sample loaders)  declaring compliance to the LVD instead of the 
> MD.  As first I tried to correct them but then they sent us test reports from 
> NB labs in Europe evaluating their products to the LVD.  Whodathunkit?
>  
> However, I checked with the TUV:SUD lab we use here in the states and they 
> are still saying that the MD is the correct directive to use.  Ok, now I’m 
> officially confused. 
>  
> So, has it officially changed? Or is it changing? Can manufacturers of 
> laboratory equipment go back to declaring compliance to the LVD even if their 
> products have moving parts?  Has anyone seen any 

Re: [PSES] Conformity assessment under RED

[Nick Williams]

That is without doubt correct in my view. 

Nick. 




> On 1 Mar 2017, at 16:04, Sundstrom, Mike <mike.sundst...@garmin.com> wrote:
> 
> Everyone,
> I would opinion that the TV is a broadcast receiver and therefor it falls 
> under RE-D.
>  
> Thanks,
>  
> Michael Sundstrom
> Garmin Compliance Engineer
> 2-2606
> (913) 440-1540
> KB5UKT
>  
> "We call it theory when we know much about something but nothing works, 
> and practice when everything works but nobody knows why."  -- Albert 
> Einstein
>  
> From: Mike Sherman - Original Message - 
> [mailto:msherma...@comcast.net <mailto:msherma...@comcast.net>] 
> Sent: Wednesday, March 01, 2017 9:52 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: Re: [PSES] Conformity assessment under RED
>  
> Seems to me that IR does not communicate in the radio frequency range, but BT 
> and RF do, so I would say IR is out of RED scope but BT and RF are within 
> scope.
>  
> What opinions do others have?
>  
> Mike Sherman
> Graco Inc.
>  
> From: "Scott Xe" <scott...@gmail.com <mailto:scott...@gmail.com>>
> To: "EMC-PSTC" <EMC-PSTC@LISTSERV.IEEE.ORG 
> <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
> Sent: Wednesday, March 1, 2017 8:21:14 AM
> Subject: Re: [PSES] Conformity assessment under RED
>  
> For the traditional TV that comes with an infrared remote controller and 
> latest TV that comes with BT or RF remote controller, does it fall into RED 
> scope?
>  
> Thanks,
>  
> Scott
>  
>  
>  
>  
> From: Scott Xe <scott...@gmail.com <mailto:scott...@gmail.com>>
> Date: Tuesday, 21 February 2017 at 12:25 AM
> To: Michael Derby <micha...@acbcert.com <mailto:micha...@acbcert.com>>, 
> <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
> Subject: Re: [PSES] Conformity assessment under RED
>  
> Hi Michael,
>  
> Thanks for your kind reminder!  The NB also suggests to use the draft EN 303 
> 345 (best available) for Radio Receivers.
>  
> One query about TV, as most of digital TVs still have analogue part (although 
> the transmission had been switched off in lots of areas).  Is there any 
> additional standard for this part?
>  
> Regards,
>  
> Scott
>  
>  
>  
>  
> From: Michael Derby <micha...@acbcert.com <mailto:micha...@acbcert.com>>
> Date: Tuesday, 21 February 2017 at 12:05 AM
> To: 'Scott Xe' <scott...@gmail.com <mailto:scott...@gmail.com>>, 
> <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
> Subject: RE: [PSES] Conformity assessment under RED
>  
> Hi Scott,
>  
> Please don’t forget that for FM Radio Receivers, the Article 3.2 standard (EN 
> 303 345) is not expected to be cited on the RED OJ until September 2017; so 
> those broadcast sound receivers could not be assessed without the use of a 
> Notified Body.
>  
> For TV, it could be different because some of the standards (such as EN 303 
> 340) are already listed on the RED OJ.
>  
> Thanks,
>  
> Michael.
>  
>  
>  
> From: Scott Xe [mailto:scott...@gmail.com <mailto:scott...@gmail.com>] 
> Sent: 19 February 2017 23:00
> To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: Re: [PSES] Conformity assessment under RED
>  
> For TV/Radio receivers and BT/Wifi enabled units, it can use the HSs in 
> RED/LVD/EMC of OJEU without the use of NB as per the interpretation of below.
>  
> Thanks,
>  
> Scott
>  
>  
>  
> On Wed, Jan 4, 2017 at 6:00 AM, Michael Derby <micha...@acbcert.com 
> <mailto:micha...@acbcert.com>> wrote:
> Hi Nick,
>  
> You are completely correct.
>  
> Actually, this approach (NB is only needed for deviations in testing to 
> Articles 3.2 and 3.3; but not needed for deviations in testing for 3.1) was 
> apparently the original intention with 1999/5/EC, but it was not correctly or 
> clearly written.   2014/53/EU corrects that.
>  
> Thanks,
>  
> Michael.
>  
>  
> 
> -Original Message-
> From: Nick Williams [mailto:nick.willi...@conformance.co.uk 
> <mailto:nick.willi...@conformance.co.uk>]
> Sent: 04 January 2017 12:18
> To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
> Subject: [PSES] Conformity assessment under RED
>  
> Happy New Year, EMC-PSTC listers!
>  
> 2014/15/EU article 17 separates the conformity assessment procedures for 
> essential requirement 3.1 (safety and EMC) from those which are applied for 
> essential requirements 3.2 and 3.3 (spectrum efficiency and special 
&

[PSES] Conformity assessment under RED

[Nick Williams]

Happy New Year, EMC-PSTC listers!

2014/15/EU article 17 separates the conformity assessment procedures for 
essential requirement 3.1 (safety and EMC) from those which are applied for 
essential requirements 3.2 and 3.3 (spectrum efficiency and special 
provisions). Notified Body intervention is required for ER’s 3.2 and 3.3 if the 
manufacturer has not applied harmonised standards, but no such requirement is 
applied for ER 3.1. 

My reading of this is that the manufacturer has complete freedom of approach 
under RED for safety and EMC compliance in exactly the same way that they do 
under the LVD and EMC Directive, and can self-certifiy even if they do not 
apply harmonised standards, irrespective of whether or not they are required to 
involve a NoBo for compliance with ER’s 3.2 & 3.3. 

This is not how things worked under 1999/5/EC. 

Is my interpretation correct, and if not, why not?

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Re: [PSES] Authorised Representative

[Nick Williams]

The requirement for the techical documentation to be kept on EU soil was never 
enforceable in practice and has been removed from the directives re-issued 
under the New Legislative Framework. 

The appointment of an Authorised Representative is optional for all directives 
except for the ones which deal with medical devices. 

The Machinery Directive (and the new Marine Equipment Directive, which is not a 
CE marking directive) requires there to be someone who can act as a delivery 
point for the technical file who is resident in Europe. This is not the same 
role as that of an Authorised Representative. 

Nick. 


> On 1 Nov 2016, at 21:40, Nyffenegger, Dave  
> wrote:
> 
> I recall the authorized representative is optional for MD and LDV with 
> respect to who is responsible for placing product into market, either 
> manufacturer or authorized representative.  However, the party responsible 
> for the technical file must be resident inside the EU.  If the manufacturer 
> is not resident inside the EU then there must be an authorized representative 
> who is and identified on the DoC/DoI.
>  
> -Dave 
>  
> From: Kunde, Brian [mailto:brian_ku...@lecotc.com 
> ] 
> Sent: Tuesday, November 01, 2016 4:20 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG 
> Subject: Re: [PSES] Authorised Representative
>  
> John,
>  
> In reference to what?  The name and address displayed on the EE?, the 
> responsible party within the EU?, information appearing on the DoC?
>  
> I’ve always understood that an Authorized Representative within the EU was 
> required for manufacturers outside the EU; and I thought this was a 
> requirements for most all Directives (I’m not familiar with all of them).
>  
> The Other Brian
>  
> From: John Allen [mailto:jral...@productsafetyinc.com 
> ] 
> Sent: Tuesday, November 01, 2016 3:32 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG 
> Subject: [PSES] Authorised Representative
>  
> Hi,
>  
> I always thought an Authorized Representative was required for Machinery but 
> option for other Directives.  I searched Machinery and LVD and only see 
> manufacturer "or" authorised representative.
>  
> If I'm wrong please point me to the particular section of the Directive.
> 
> Thanks,
>  
> John
>  
>  
>  


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Re: [PSES] 2nd hand or refurbished products

[Nick Williams]

Scott,

Many second-hand products will have difficulty meeting current requirements. 
This is a problem for products which have been used outside the EU when they 
are imported into the EU for the first time, but for second hand products which 
are already within the EU (i.e. those which were originally sold into the EU 
when they were new), the rules for new products do not apply when they are sold 
as second hand. 

Nick. 




> On 28 Oct 2016, at 15:00, Scott Xe <scott...@gmail.com> wrote:
> 
> Hi Nick,
>  
> Thanks for your useful advice!
>  
> The Blue Guide’s one refers to refurbished products adequately.
>  
> If imported second hand products are treated as newly introduced products 
> into EU and thus meet the latest directives.  It seems the second hand 
> products is unfit for this law.  How can the second hand products survive in 
> the EU?
>  
> Regards,
>  
> Scott
>  
>  
> From: Nick Williams <nick.willi...@conformance.co.uk 
> <mailto:nick.willi...@conformance.co.uk>>
> Date: Friday, 28 October 2016 at 1:22 AM
> To: Scott Xe <scott...@gmail.com <mailto:scott...@gmail.com>>
> Cc: <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@listserv.ieee.org>>
> Subject: Re: [PSES] 2nd hand or refurbished products
>  
> Funnily enough, I’ve recently been looking into this. So far as the product 
> safety directives are concerned, the answer is in the Blue Guide which says:
>  
> “ Products which have been repaired or exchanged (for example following a 
> defect), without changing the original performance, purpose or type, are not 
> to be considered as new products according to Union harmonisation 
> legislation. Thus, such products do not need to undergo conformity assessment 
> again, whether or not the original product was placed on the market before or 
> after the legislation entered into force. This applies even if the product 
> has been temporarily exported to a third county for the repair operations. 
> Such repair operations are often carried out by replacing a defective or worn 
> item by a spare part, which is either identical, or at least similar, to the 
> original part (for example modifications may have taken place due to 
> technical progress, or discontinued production of the old part), by 
> exchanging cards, components, sub-assemblies or even entire identical units. 
> If the original performance of a product is modified (within the intended 
> use, range of performance and maintenance originally conceived at the design 
> stage) because the spare-parts used for its repair perform better due to 
> technical progress, this product is not to be considered as new according to 
> Union harmonisation legislation. Thus, maintenance operations are basically 
> excluded from the scope of the Union harmonisation legislation. However, at 
> the design stage of the product the intended use and maintenance must be 
> taken into account”
>  
> Bear in mind, however (since I know you are located in the States) that the 
> directives which apply are those which are in force on the day the prodict 
> first comes into Europe, even if it has been used outside the EU before that. 
> In other words, second hand equipment sourced outside the EU is treated as if 
> it were new on the day it crosses the border. 
>  
> Nick. 
>  
>  
>> On 27 Oct 2016, at 18:11, Scott Xe <scott...@gmail.com 
>> <mailto:scott...@gmail.com>> wrote:
>>  
>> Are EU chemical directives such as packaging directive, RoHS, REACH and 
>> safety directives applied to 2nd hand or refurbished products?
>>  
>> Thanks and regards,
>>  
>> Scott
> 
> 
> 


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Re: [PSES] 2nd hand or refurbished products

[Nick Williams]

Funnily enough, I’ve recently been looking into this. So far as the product 
safety directives are concerned, the answer is in the Blue Guide which says:

“ Products which have been repaired or exchanged (for example following a 
defect), without changing the original performance, purpose or type, are not to 
be considered as new products according to Union harmonisation legislation. 
Thus, such products do not need to undergo conformity assessment again, whether 
or not the original product was placed on the market before or after the 
legislation entered into force. This applies even if the product has been 
temporarily exported to a third county for the repair operations. Such repair 
operations are often carried out by replacing a defective or worn item by a 
spare part, which is either identical, or at least similar, to the original 
part (for example modifications may have taken place due to technical progress, 
or discontinued production of the old part), by exchanging cards, components, 
sub-assemblies or even entire identical units. If the original performance of a 
product is modified (within the intended use, range of performance and 
maintenance originally conceived at the design stage) because the spare-parts 
used for its repair perform better due to technical progress, this product is 
not to be considered as new according to Union harmonisation legislation. Thus, 
maintenance operations are basically excluded from the scope of the Union 
harmonisation legislation. However, at the design stage of the product the 
intended use and maintenance must be taken into account”


Bear in mind, however (since I know you are located in the States) that the 
directives which apply are those which are in force on the day the prodict 
first comes into Europe, even if it has been used outside the EU before that. 
In other words, second hand equipment sourced outside the EU is treated as if 
it were new on the day it crosses the border. 

Nick. 


> On 27 Oct 2016, at 18:11, Scott Xe  wrote:
> 
> Are EU chemical directives such as packaging directive, RoHS, REACH and 
> safety directives applied to 2nd hand or refurbished products?
>  
> Thanks and regards,
>  
> Scott


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Re: [PSES] EU Enforcement of CE Marking Directives

[Nick Williams]

http://ec.europa.eu/consumers/consumers_safety/safety_products/rapex/index_en.htm

> On 25 Aug 2016, at 21:45, Jim Hulbert  wrote:
> 
> Hi,
>  
> I am interested in understanding how stringent the enforcement of CE marking 
> directives is within the EU.  Is there someplace where we can find 
> enforcement actions that have been taken against companies for placing 
> products on the market that don’t fully meet the applicable Directives?   I 
> am most interested in the EMC, LVD, MD, and R Directives.
>  
> Thank you.
>  
> Jim Hulbert
>  
> 
> 

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[PSES] CCA cables

[Nick Williams]

I would be interested in hearing from anyone with experience of testing or 
using copper coated aluminium (CCA) conductor cable in mains power 
applications. 

CCA is already widely used for network and booster cables but there now seems 
to be a move to use it in flexible power cord applications (specifically, 
portable extension cables). 

The corrosion problems associated with the use of aluminium are well known and 
I am familiar with the physics and chemistry involved. I’m less familiar with 
how much difference a copper coating makes. 

I’ve so far failed to find any standards which specifically address the 
performance or use of CCA cables, and  I’m not familiar enough with the 
standards for copper cables to know valid it would be to apply these to CCA. 

All insight welcome!

Nick. 

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Re: [PSES] SAFETTY FEATURES controlled by ....SOFTWARE

[Nick Williams]

The problem with focusing on the code is that real world experience is that a 
high percentage of the failures which occur with software related safety are a 
failure of the original specification for what the software is supposed to do, 
not failures of the code to do what the programmer intended. Particular 
problems occur if the limits of operation of the equipment are not properly 
understood: a classic example being a passenger aircraft crash caused by the 
avionics being unable to detect when the aircraft wheels had hit the runway in 
very wet conditions due to aquaplaning whereas in the dry conditions under 
which the system was tested it worked perfectly. 

This is why standards which deal with software in safety related applications 
(including those derived from IEC 61508, and the medical devices software 
standard, IEC 62304) focus much more on the overall procedure for specifying 
and designing the software and then checking that the specification has been 
met, and are not overly prescriptive about language, structure or other 
detailed requirements for code. 

Nick. 


> On 4 Aug 2016, at 21:49, B Rowland  wrote:
> 
> Indeed, Brian, there is a difference between a provably-correct code block, 
> and actual execution of the code, in other than a dedicated run-time, without 
> interrupts, or real-time OS, or … interesting point about the core, whether 
> it has been proven to execute correctly, in every possible case ;-)  That's a 
> couple of test vectors, no?
> 
> Barry
> 
> 
> 
> 
> On  04/08/2016, at 21:23 , Brian O'Connell  wrote:
> 
>> Whom considers Ada (the language name is not an acronym) provably correct? 
>> How do you prove the program is deterministic? What if a Verification 
>> Condition is not proven? Is the code incorrect? Is the assertion not correct 
>> or incomplete? Does P = NP ? SPARK 2014 did attempt to address some of this 
>> stuff, BTW.
>> 
>> Do not think that we will find answers to these questions in ISO8652. What 
>> Ada does provide is a formalized programming method for concurrency + design 
>> by contract, which offer a little more hope for code safety and test 
>> coverage.
>> 
>> The weakness for all human code solutions is a provable processor core where 
>> the assumption is a provable algorithm. If a static evaluation indicates a 
>> deterministic algorithm, and if a contract violation occurs at runtime, what 
>> is 'wrong'? The language? The Compiler? The design assumptions? The 
>> processor core? Once you get past Ada (or any other language) compile-time 
>> protection, you return to the electronic jungle where you are part of the 
>> food chain.
>> 
>> Brian
>> 
>> 
>> From: B Rowland [mailto:bfr...@direct.ca] 
>> Sent: Thursday, August 04, 2016 11:33 AM
>> To: EMC-PSTC@LISTSERV.IEEE.ORG
>> Subject: Re: [PSES] SAFETTY FEATURES controlled by SOFTWARE
>> 
>> Hi List-colleagues;
>> 
>> I think, if the safety-related functions are life-critical, they need to be 
>> written in a "provably-correct" language/environment, like ADA, or some 
>> equivalent. And, of course, that also means that such functionality needs to 
>> be isolated from software that is NOT provably-correct (is Windows 
>> "provably-correct" ?).
>> 
>> In any case, life-critical systems need to be, at least, redundant, with 
>> fail-safe shutdown if the processes do not agree at timed checkpoints, and 
>> also have hardware-based watchdog timers (sometimes built-in to the 
>> microcontroller, itself) to guarantee continued function. Furthermore, it is 
>> also typical that the software that runs on the redundant processors is 
>> written by different teams, so that an error in a program on one "side" is 
>> not duplicated in the other half/third of the redundant CPUs.
>> 
>> Since, as some have pointed out, it is readily-accomplished to have a 
>> provably-correct hardware implementation of the safety functions that are 
>> "at the edge" of the system, FPGA's, PALs, etc., with ROM, or 
>> check-summed-on-load-firmware, are much more reliable.. 
>> 
>> In another discussion that I had, a while back, we even discussed how to 
>> ensure that the semiconductor devices, at the safety interface, are made 
>> reliable-enough to allow proper operation, even in the typical fail-short 
>> conditions. I think that this is why we have relays costing > $1000 used in 
>> train/subway applications ;-)
>> 
>> Cheers,
>> Barry Rowland
>> Muenchen, Bayern
>> 
>> -
>> 
>> 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 
>> 
>> 
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>> 
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>> http://product-compliance.oc.ieee.org/ can be used for graphics 

Re: [PSES] Partly Completed Machinery...or not???

[Nick Williams]

John,

I suspect what you are dealing with is actually a sheave block, not a ‘pulley' 
as mentioned in the extract from the guide quoted by Steve. 

This being the case, it’s not a lifting accessory because a lifting accessory 
is intended to go between the load and a piece of lifting machinery. It is 
however “an assembly of linked parts or components, at least one of which moves 
and which are joined together, intended for lifting loads and whose only power 
source is directly applied human effort” so it’s a machine within the meaning 
of the Directive. 

Regards

Nick. 




> On 14 Apr 2016, at 21:06, John Allen  wrote:
> 
> Thanks guys, but still struggling agreeing with the fact it's not part of the 
> machinery directive.  A rope can be but a pulley block is not??
> 
> Steve - the last part of the first sentence is  that do not have a specific 
> application and that are intended to be incorporated into machinery.  The 
> pulley block is being sold by itself and has an application.
> 
> Also, is it not a lifting accessory??
> 
> 


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Re: [PSES] Partly Completed Machinery...or not???

[Nick Williams]

The deciding factor is whether the manufacturer has control of compliance with 
all of the applicable EHSRs and, by extension, whether it is expected that the 
product will under go a further conformity assessment procedure before it is 
placed on the market or put into service. If, and only if, the answer to the 
first question is ‘no’ and to the second question is ‘yes’ then the Declaration 
of Incorporation route is correct. If the answer to either question is the 
reverse then compliance with the applicable EHSRs is the responsibility of the 
manufacturer and the product must be CE marked and have a Declaration of 
Conformity. 

It’s important to realise that ‘control of compliance with the EHSRs’ may just 
mean that the manufacturer describes the relevant protections in their 
installation instructions. For example, if the product is a machine tool which 
is supplied without complete guarding because it is going to be incorporated 
with other machinery into a manufacturing cell, the manufacturer is still able 
to describe the guarding requirements within their documentation and hence has 
control of that EHSR even if they don’t provide the hardware which forms the 
protection. Thus, the machine must be CE marked, even if the guards are 
supplied by someone else. 

Nick. 


> On 13 Apr 2016, at 23:05, John Allen  wrote:
> 
> Hi guys, 
> 
> I'm hoping to feedback and clarification if I'm reading the Machinery 
> Directive correctly.
> 
> The product is a Pulley Block with a brake/ratchet mechanism.  It is not 
> supplied with the rope.  It is used for lifting machinery, not people.
> 
> We believe this to be partly completed machinery and should not bear the CE 
> mark and be supplied with a Declaration of Incorporation.  We have heard 
> different opinions and some believe because it has a brake/ratchet it should 
> be marked CE and supplied with a Declaration of Conformity.
> 
> Your thoughts and opinions would be appreciated.
> 
> Best Regards,
> 
> John


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[PSES] EC Blue Guide

[Nick Williams]

A new edition of the Commission’s Blue Guide has been published:

http://ec.europa.eu/DocsRoom/documents/16210 


Nick. 
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Re: [PSES] EU's new approach directive transitions

[Nick Williams]

No, they have aways been the responsibility of the manufacturer. And there are 
no longer any Notified Bodies under the new LVD. 

Nick. 


> On 1 Apr 2016, at 23:19, Scott <0182a58d8335-dmarc-requ...@ieee.org> 
> wrote:
> 
> Didn't risk assessments fall exclusively under the responsibility of a body 
> notified for safety?
> 
> Scott B
> 
> Sent from my iPhone
> 

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Jim Bacher:  
David Heald: 

Re: [PSES] EU's new approach directive transitions

[Nick Williams]

Scott, 

> On 1 Apr 2016, at 15:18, Scott Xe  wrote:
> 
> Dear David,
> 
> Will the EU enforcement body use this format to inquire the LVD compliance to 
> the suppliers in the future in replacement of getting the test report to the 
> harmonised standard now?  

What materials/documents exist by way of evidence of compliance with the 
Directive will form part of the risk assessment performed by the authorities. 
If, for example. there is a test report from a fully accredited laboratory 
which shows that the product fully complies with the applicable standard then 
this will considerably reduce the likelihood of a product recall being required.


> Where to get a copy of the Decision 2010/15/EU?
> 


http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1459525315001=CELEX:32010D0015

Regards

Nick. 

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Re: [PSES] EU's new approach directive transitions

[Nick Williams]

David,

The risk assessment you refer to below is not same as the risk assessment 
referred to in the new LVD (and some other NLF directives). The risk assessment 
below is specifically aimed at determining whether or not the product presents 
a risk which is sufficient to warrant post market action, and in particular 
whether or not a product recall is necessary. This is obviously related to the 
product design risk assessment which is required before placing the product on 
the market, but it is not the same thing.

Nick. 




> On 31 Mar 2016, at 22:09, David K Bell  wrote:
> 
> Scott,
> 
> With regard to the risk assessment requirement in the Directives revised 
> under the New Legislative Framework (NLF):
> 
> This excerpt is from a discussion of the proposed EU Consumer Product Safety 
> Regulation (CPSR):
> 
>  
> The European Commission will undertake a risk analysis of the product to 
> determine whether the product is likely to pose a 'serious' risk. The default 
> risk analysis methodology to be used is the already established EU Risk 
> Assessment Methodology (Decision 2010/15/EU), by which products can be 
> assessed and classified as posing a 'Low', 'Medium', 'High' or 'Serious' 
> risk. If this risk assessment methodology is not appropriate for the 
> particular product, the Commission must give a detailed description of the 
> methodology used in its place.
>  
> Appendix 5 of Decision 2010/15/EU on pages 33—64 covers Risk Assessment.  
> This is the methodology that a EU enforcement body would use to determine if 
> a product poses a serious risk and should therefore be withdrawn from the 
> market and notified to other EU member states via the EU RAPEX rapid alert 
> system.  Any risk analysis that we do to satisfy the requirements of the new 
> LV  and EMC Directives should be no less rigorous.
> 
> Best regards,
> 
> David K. Bell
> Senior Regulatory Compliance Engineer
> Milestone AV Technologies
> 
> david.b...@milestone.com 
> +1.952.225.6782
> 
> 
> 
> On Thu, Mar 31, 2016 at 11:35 AM, Scott Xe  > wrote:
> There are two major changes in new LVD.  One is the risk assessment that is 
> to be the obligation for the manufacturers.  The other one is that the DoC is 
> required to have object of declaration.
> 
> The risk assessment is unclear how to do it and any reference to follow.  
> Currently there is few testing laboratories to provide such service to the 
> manufacturers.  Hope there is harmonised standard and/or guidance for 
> compliance in near future.
> 
> Scott
> 
> 
>> On 31 Mar, 2016, at 1:50 am, Ronald Pickard 
>> > > wrote:
>> 
>> Hi Charlie,
>> Thank you for your reply along with those linked references. Those ETSI 
>> links provide projected target dates for approval and availability for the 
>> new/revised standards being drafted for the RED, which are generally 
>> targeted to be complete by the 13-Jun-2017 effectivity date for the RED. 
>> Kudos to ETSI for that work.
>>  
>> Best regards,
>>  
>> Ron Pickard
>> Regulatory Compliance Engineer
>> Compound Photonics 
>> D | +1 (602) 883-8039 
>>  
>> From: Charlie Blackham [mailto:char...@sulisconsultants.com 
>> ] 
>> Sent: Tuesday, March 29, 2016 11:34 PM
>> To: Ronald Pickard > >; EMC-PSTC@LISTSERV.IEEE.ORG 
>> 
>> Subject: RE: EU's new approach directive transitions
>>  
>> Ron
>>  
>> Few short answers:
>>  
>> · No sign of that happening at all and I cannot see it happening
>> · No, existing Directives are repealed by the new Directives on the 
>> dates indicated,  but you may wish to look at Recommended format for DoC 
>> that can reference existing and new 
>> Directives,http://ec.europa.eu/DocsRoom/documents/14886/attachments/1/translations/en/renditions/native
>>  
>> 
>>   (referenced from 
>> http://ec.europa.eu/growth/sectors/electrical-engineering/emc-directive/index_en.htm
>>  
>> 
>>  )
>> · ETSI are working hard on updating over 150 standards, some more 
>> information available:
>> o   https://docbox.etsi.org/Workshop/2015/201511_RED-WORKSHOP/ 
>>  for 
>> presentations from November workshop
>> o   Work program on radio standards: 
>> http://webapp.etsi.org/ena/cvp.asp?search=RADIO 
>>  and a number of RED 
>> standards have a been published or are available as final draft
>> o   Work program on EMC standards: 
>> 

Re: [PSES] EU's new approach directive transitions

[Nick Williams]

EN ISO 12100 is good and useful but EN ISO 14971 "Medical devices — Application 
of risk management to medical devices” is actually more relevant to some 
consumer type products 

Nick. 



> On 31 Mar 2016, at 20:32, Nyffenegger, Dave  
> wrote:
> 
> Risk assessments are not new and it’s a requirement of the current Machinery 
> Directive from 2006 and probably for some time before.  A principle HS for 
> the MD is EN ISO 12100:2010.  Many of the basic concepts can be applied to 
> non-machinery. I’d think that standard or one similar would become an HS for 
> the LVD.
>  


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[PSES] NRTL required for field equipment approval

[Nick Williams]

I’m looking for assistance with field approval for some automated test 
equipment destined for a US automotive factory. Please would anyone interested 
in working with Conformance on this (or who can recommend someone who may be 
interested in working with Conformance) contact me directly. 

Thanks

Nick. 


Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk <mailto:nick.willi...@conformance.co.uk>



Conformance Limited. The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG 
England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk 
<http://www.conformance.co.uk/>
Registered in England, Company No. 3478646


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Re: [PSES] Energy in certain items

[Nick Williams]

Oh, goody, a chance to discuss one of my ‘spare time’ specialist subjects!

Dynamite is properly a tradename originally owned by Nobel’s Explosives and 
consists of nitroglycerine stabilised by being absorbed in kieselghur (a type 
of absorbent clay). It made Alfred Nobel a very, very rich man. 

Nitroglycerine based explosives have a poor shelf life and are difficult to 
handle safely so nitroglycerine has never been popular as a basis for military 
explosives. Military plastic explosives (i.e. those used for sabotage or 
demolition operations) and shaped charges tend to be based on substances like 
RDX and HMX which have a higher velocity of detonation than NG (so they work 
better on metals and concrete) and are much more stable. TNT was primarily used 
as a filler in aircraft dropped bombs, hence its use as a baseline for 
explosive power comparisons with nuclear weapons.

Nitroglycerine explosives are actually fairly difficult to get these days - 
their use is mainly confined to ‘permitted’ explosives - i.e. those certified 
for use in explosives atmospheres in (mainly) coal mines. Reasons for its use 
are largely historical - there aren’t many coal mines which rely on drill and 
blast these days (most coal is mined mechanically) so it’s not worth the 
explosives manufacturers doing the tests to formulate and certifiy new 
explosive mixtures which eliminate the NG. 

Most modern quarry and (non permitted) mining explosives are ammonium 
nitrate/fuel oil emulsions which are initiated by primers or detonating cords 
based on PETN, the primer in turn being initiated by a detonator based on lead 
azide. These days, ANFO emulsions are often delivered to quarries by tankers 
which keep the constituents separate (and hence unlikely to explode) until they 
actually enter the shot hole. 

I’ve been involved with this stuff for more than 30 years, in which time I’ve 
played with a very wide variety of different explosives, but I’ve never 
actually seen a real stick of Dynamite or a pound (let alone a ton) of TNT. 
Nevertheless, notwithstanding the rather snooty comments on the web page linked 
by Rich Nute, the point about the comparison between the energy in a pound of 
dynamite and a similar quantity of gasoline (petrol to us Brits!) is the 
message about the speed of delivery so comparing the explosive power of 
Dynamite vs a fuel/air cloud is rather missing the point. 

The world is rather a different place at 10,000 m/s!

Nick. 


> On 19 Feb 2016, at 22:43, Brian O'Connell  wrote:
> 
> Played with this stuff in the military. TNT is NOT the composition of 
> industrial or military 'dynamite'.
> 
> Typical dynamite, at least the stuff we played with, is cornstarch binders 
> +oil +TNT+RDX; and there were some compositions that were buffered with 
> sodium carbonate. Dynamite, depending on the size of the stick and intended 
> end-use, will contain well under 20% TNT by both mass and volume. 
> Mechanical/chemical stabilization and reaction rates are more controlled in 
> modern 'dynamite.
> 
> For large construction and mining stuff, dynamite yields poor results, so 
> tends to be limited to use for ignition of an oil+ammonium nitrate bulk-type 
> explosive. 
> 
> Brian
> 
> 
> -Original Message-
> From: Richard Nute [mailto:ri...@ieee.org] 
> Sent: Friday, February 19, 2016 1:45 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] Energy in certain items
> 
>> Does anyone know the energy [joules] in a standard stick of
>> dynamite, or a gallon of gasoline?
> 
> Not the answer, but may be useful:
> 
>   4,184,000,000 J  =  1 ton of TNT
> 
> For a comparison of energy in dynamite and gasoline, and for "The nonsense 
> about gasoline and dynamite," see: 
> 
>   http://home.earthlink.net/~jimlux/energies.htm#GasDynamite
> 
> 
> Rich
> 
> 
>> -Original Message-
>> From: Macy [mailto:m...@basicisp.net]
>> Sent: Friday, February 19, 2016 9:59 AM
>> To: EMC-PSTC@LISTSERV.IEEE.ORG
>> Subject: [PSES] Energy in certain items
>> 
>> Does anyone know the energy [joules] in a standard stick of
>> dynamite, or a gallon of gasoline?
> 
> -
> 
> 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 
> 
> 
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Re: [PSES] EU Regs on live work

[Nick Williams]

Doug,

This would be covered by employer occupational safety legislation which remains 
a Member State level competence (albeit with a minimum level of performance 
mandated by directives issued under article 153 of the TFEU). 

In the UK, the relevant Regulations are the Electricity at Work Regulations 
1989. It should be noted that these apply to operations on all electrical 
installations in the work place, not just those within the scope of the LVD. 
Live working is strongly discouraged although clearly it cannot be outlawed 
entirely. 

You can find good guidance on the Regulations on the HSE website 
www.hse.gov.uk. You can also expect all other member states to have similar 
requirements. 

More practically, it should be noted that the requirements for protection 
against direct and indirect contact with live parts contained within EN 60204-1 
are not really consistent with the accepted practice for working on energised 
cabinets which is why in reality finger protection of live components within 
cabinets is commonly required even though this is not an explicit part of the 
standard. 

Regards

Nick. 




> On 28 Sep 2015, at 16:20, Douglas Nix  wrote:
> 
> I’d like to verify the regulations relating to live work on electrical 
> control panels in the EU. Is it permitted? If yes, what are the limits? A 
> reference to the applicable regulations would be helpful. I’m expecting it’s 
> covered in the PUWER regs, but would like confirmation from someone who knows.
> 
> Doug Nix
> d...@ieee.org
> 

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[PSES] EMC test lab, New York

[Nick Williams]

I’m looking for recommendations for EMC testing services for a client in New 
York state. I need a well equipped lab which charges by the hour, properly 
understands the EMC Directive, has a good technical understanding of the EN 
standards and can recommend solutions in the case of minor compliance issues. I 
don’t want a lab who are only interested in maximising their income by 
performing unecessary tests.

Contact details gratefully received by direct message. 

Thanks

Nick. 

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Re: [PSES] Machinery Directive: seagoing vessels

[Nick Williams]

I’d just treat it as if it were under the Machinery Directive but not put the 
CE logo on it, and issue a simple Certificate of Conformity instead of an EC 
Declaration of Conformity. 

Regards

Nick. 



 On 20 Aug 2015, at 14:13, MARK HONE mar...@btinternet.com wrote:
 
 Colleagues –
  
 Can you help me?
  
 In the Machinery Directive, it says:
  
 2. The following are excluded from the scope of this Directive:
  
 (f) seagoing vessels and mobile offshore units and machinery installed on 
 board such vessels and/or units;
  
 So what takes the place of the Directive for equipment that may be fitted on 
 a ship?
  
 The Marine Equipment Directive seems to cover very specific products from 
 what I can see on the MarEd website and my frustratingly limited ability with 
 Google hasn’t turned up anything else.
  
 Can anyone help me identify a standard or directive that would cover a 
 control system, a pump, some solenoid valves and some sensors etc., joined 
 together to form a process plant, that might possibly be used on a “seagoing 
 vessel”?
  
 Ever hopeful,
  
 Mark


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Re: [PSES] EU Pressure Equipment Requirements

[Nick Williams]

Jim,

The short answer is that if vessels contain only air or nitrogen and are CE 
marked as Simple Pressure Vessels, and you have no hydraulic accumulators, then 
you can ignore the PED. 

The longer answer is that (in theory at least) you need to identify each piece 
of pressure equipment and confirm whether or not it is higher than category 1 
under the PED. If you have any equipment that is higher than cat. 1 then you 
have created a ‘pressure assembly’ within the scope of the PED and you will 
need a PED Notified Body to get involved (quite how the NoBo will be involved 
will depend on the category).

In practice, if you do the classification then you will find that if your only 
pressure equipment are ‘normal’ fluid power (hydrualic or pneumatic) 
components, with no accumulators, then nothing will be higher than cat. 1 PED 
(most of it will actually be SEP). The PED says that if your equipment is no 
higher than cat. 1 and is part of a machine (i.e. within the scope of the 
Machinery Directive) then you can ignore the PED. 

Drop me a line if you need any further guidance. 

Nick. 



 On 4 Jun 2015, at 16:39, Jim Hulbert jim.hulb...@pb.com wrote:
 
 Colleagues,
 I’m trying to understand the applicability of the Simple Pressure Vessel 
 Directive 2009/105/EC and the Pressure Equipment Directive 97/23/CE.
 For a compressor/tank system (max pressure around 70 PSI/4.8 bar) that is 
 entirely contained with a machine, I believe the Simple Pressure Vessel 
 Directive applies to the tank.   However, I’m not so sure that the PED 
 applies since the equipment is part of and totally contained within another 
 system.  Any insight would be appreciated.
  
 Jim Hulbert
 


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Re: [PSES] D of C and product safety warnings and caution markings

[Nick Williams]

Neither the LVD nor the EMC Directive require the Declaration to accompany the 
product so all you are legally obliged to do is to make it available to the 
authorities on request. Making it available via a web site is (in my view) a 
good idea. 

Some of the directives (e.g. Machinery, ATEX, R+TTE) require the declaration to 
accompany the product when it is shipped to the end user and so for products 
within the scope of these directives, paper copy is a mandatory requirement. 

The answer to your final question is that, strictly, if product carries the CE 
logo, the authorities are required to assume that it complies with the 
directive unless they can prove otherwise. In practice, of course, they have 
powers to demand information which in effect places the burden of proof on the 
manufacturer. If you think there is a possibility that customs will holsd up 
the shipment the supplying a Declaration witht he product seems like a simple 
measure to minimise the likelihood of this happening. 

Nick. 



 On 28 May 2015, at 21:43, Ron Baugh ron...@verifone.com wrote:
 
 I have a question that has been presented to me for several years now and I 
 need this groups help.
  
 When we ship our products to the end user and our products meets all of the 
 LVD requirements (per IEC/EN 60950), we place a physical copy of our D of C 
 with EACH terminal. 
  
 I have been ask if we could put our D of C on our company web site and make 
 reference,  physically  on the shipping box to the web address where our D of 
 C would be posted. 
  
 The issue I need help with is this….. does the D of C have to be shipped 
 physically with EACH product in the shipping box OR can the shipping box have 
 a web address printed on it to direct the end user to our D of C?
  
 Also, if the D of C is NOT physically in the shipping box, how does the 
 country customs inspector know if we meet the required EU LVD requirements?
  
 Thanks
  
 Ron Baugh


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Re: [PSES] Using NEMA Receptacles in Europe

[Nick Williams]

There is no reason not to use them so long as they meet the relevant insulation 
requirements.  IME some of them don’t meet the finger access prevention 
requirements (which are not just that you shoud not be able to touch live 
parts, you must maintain double insulation from live parts even while the 
plug/socket combination is being un-coupled). 

Nick. 



 On 3 Feb 2015, at 21:54, Kunde, Brian brian_ku...@lecotc.com wrote:
 
  
 Can I use a NEMA Inlet Connector (twist lock type) on the back of a product 
 for a detachable power cord (provided) and market it in Europe?
  
 Can I use a NEMA Outlet Receptacle (twist lock type) on the back of a product 
 to power a unique accessory (power cable provided) and market it in Europe?   
  
 I would still use a European Style Plug on the main power cord. 
  
 Is this allowed or can’t NEMA plugs/receptacles be used in Europe? How about 
 other counties outside of North America?
  
 Thanks,
 The Other Brian



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Re: [PSES] CE Declaration of Conformity

[Nick Williams]

Surely if you declare compliance with any particular Directive on your 
Declaration then you must follow the attestation procedures for that Directive. 
On the basis of a quick look, there is no attestation route under the NAWID 
which does not require some form of Notified Body intervention. I know that 
this is not completely true for the MID, but in practice most measuring 
instruments do require NB intervention for CE marking under the MID. 

Therefore, it seems to me that unless you engage an NB to help you declare 
compliance for your complete machine, you cannot include a declaration of 
compliance to the NWAID or the MID on the Declaration of the complete machine. 

The Machinery Directive says that you also need to identify any other 
applicable Directives on your Declaration:

a sentence expressly declaring that the machinery fulfils all the relevant 
provisions of this Directive and where appropriate, a similar sentence 
declaring the conformity with other Directives and/or relevant provisions with 
which the machinery complies.” (2006/42/EC annex II (1 )A item 4).

A strict reading of this means you have to declare compliance with the NWAID in 
addition to the Machienry Directive, but applying my logic above that would 
imply involving an NB to be involved in attestation of the complete machine, 
something I’m sure you won’t want to do. 

My advice is to issue a Declaration in which you claim compliance only for 
those Directives where you have competed the correct attestation procedure 
(likely to be Machinery, EMC and RoHS in this case) and supply a copy of the 
weighing machine’s DofC alongside your machinery DofC. If you attempt to 
‘badge' the weighing machine as your own by not supplying the OEM’s Declaration 
then I think you will need to comply with the NWAID and/or the MID which means 
applying the relevant procedures from these directives. 

Nick. 







 On 16 Jan 2015, at 18:13, Nyffenegger, Dave dave.nyffeneg...@bhemail.com 
 wrote:
 
 Hi folks,
 
 I design and manufacture light machinery that includes some sub-assemblies 
 which we purchase and integrate.  The sub-assemblies come with their own DoI. 
  In particular I may integrate automatic and non-automatic weighing scales 
 that would come with a DoI or DoC for the machinery and directive and a DoC 
 or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC 
 Non-automatic Weighing Instruments directives.  I do not modify the weighing 
 functionality of the scales nor do I do any additional certification on them.
 
 The metrology directives require special marking, the CE mark as well as the 
 M mark and notified body ID which come already on the units I integrate.
 
 There are no weighing devices that  I directly manufacturer that are part of 
 the machinery.  What I'm not clear on is whether I should claim compliance to 
 the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing 
 Instruments directives on my DoC and/or product nameplate for the complete 
 machine or whether I should just include the OEM's DoC along with my DoC in 
 the paperwork supplied with the machine (and technical file).
 
 I don't know if this situation is different than any are CE marked component 
 within the machine but it would seem so.  The EU directives do not actually 
 apply directly to many components that the OEM marks and claims compliance to 
 CE to make it easier for system builders like me.  (Some actually state that 
 on their DoCs).   The Metrology directives are specific to the scales.
 
 Does anyone have any experience with this or something similar?
 
 thanks
 
 David P. Nyffenegger, PMP, SM-IEEE
 Product Development Manager
 

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Re: [PSES] Seismic requirements- Euro Machinery Directive

[Nick Williams]

Some of the product specific standards include requirements for protection 
against siesmic effects, although I don’t know of any which are harmonised 
under the Machinery Directive. Probably the one closest is: BS ISO 11031. 
Cranes. Design principles for seismic load” which is still a draft 
(12/30269745 DC). Purchaseable from BSI for GBP20. 

I’ve just had a quick look at it, and it contains quite a lot of maths, but it 
also gives risk factors for different territories worldwide. I’d say it’s 
probably a good start for answering the question you asked (and since it’s a 
draft, it’s cheap!).

I’m not sure whether or not I agree with Lauren that the MD does not require 
you to consider siesmic effects. What I do know is that it’s wrong to think 
that just because the risk is very low in places like the UK then you never 
need to do anything about earthquake protection.* If you are designing serious 
infrastructure (rail, power stations etc) then earthquake risk definitely needs 
to be on your radar. 

Nick. 

*note: not that I’m accusing you of this!

 On 24 Nov 2014, at 21:37, Pete Perkins 
 0061f3f32d0c-dmarc-requ...@ieee.org wrote:
 
 ok group,
 
   I'm dealing with a large machine which, by design, seems top-heavy.
 The issue of stability in an active seismic environment has been raised.
 Are there any specific requirements or guidance in Euro standards pertaining
 to seismic stability?  
 
 :) br, Pete
 
 Peter E Perkins, PE
 Principal Product Safety Engineer
 PO Box 23427
 Tigard, ORe  97281-3427
 
 503/452-1201 fone/fax
 p.perk...@ieee.org
 

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[PSES] R+TTE consultant needed

[Nick Williams]

I’m looking for some specialist advice on the relevant standards for wide area 
paging systems. Please would anyone with relevant expertise who would be 
willing to help drop me a line direct and I will let you know more specifically 
what I’m looking for. 

Thanks

Nick. 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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Re: [PSES] GUARDS AND PROTECTIVE DEVICES

[Nick Williams]

Dave,

EN 60204-1 is really only any use as a means of addressing the electrical 
safety and some of the control system/interface requirements of the Machinery 
Directive. You certainly can’t use it as the basis for compliance with the 
requirements for guard design or any of the other EHSRs related to mechanical 
hazards. 

EN 953 covers the points in EHSR 1.4.1 (and more besides) although frankly 
there is not a great deal in it which is not common sense for someone 
experienced in machine design. 

EN 953 is a CEN standard, EN 60950 is an IEC/CENELEC standard and I doubt the 
people who wrote the two standards speak to each other much, if at all. EN 
60950 is really not a good starting place for compliance with the Machinery 
Directive (even the electrical safety aspects) - if EN 60204-1 won’t tell you 
what you need to know then for machine designers the second port of call should 
be EN 60335-1 (which, unlike EN 60950, is listed in the OJ under the Machinery 
Directive). 

IEC 60950 is probably the most globalised of all the safety standards and so it 
has to be acceptable to many territories outside of Europe where there is no 
local equivalent of the Machinery Directive. I don’t think you can expect to 
see it listed in the OJ under the Machinery Directive any time soon. 

One key message that people who come from an electrical apparatus background 
need to understand when they start dealing with the Machinery Directive is that 
(with the possible exception of EN ISO 12100, which contains general guidance 
only)  there is no one standard they can use as the basis of compliance with 
all EHSRs. Being a machinery designer means having familiarity with a range of 
typically 20 or more standards and applying only the bits which are relevant to 
your particular application. 

Happy to discuss/debate further if you have any more questions. 

Regards

Nick. 




 On 20 Nov 2014, at 19:26, Nyffenegger, Dave dave.nyffeneg...@bhemail.com 
 wrote:
 
 Folks,
 
 The Machinery Directive MD 2006/42/EC ANNEX I states
 
 1.4. REQUIRED CHARACTERISTICS OF GUARDS AND PROTECTIVE DEVICES
 1.4.1. General requirements
 Guards and protective devices must:
 - be of robust construction,
 - be securely held in place,
 - not give rise to any additional hazard,
 
 We normally use EN 60204-1 Safety of machinery - Electrical equipment of 
 machines - Part 1: General requirements to certify paper and mail handling 
 machinery to the Machinery Directive.   I don't really see anything in there 
 that addressed the first and third bullets above.  
 
 The OJ for MD harmonized standards lists  EN 953:1997+A1:2009 Safety of 
 machinery - Guards - General requirements for the design and construction of 
 fixed and movable guards.  I don't currently have a copy.  Does anyone know 
 if this standard addresses the above requirements?  Sounds like it should.  
 Is there any other harmonized standard to apply to meet these requirements?
 
 EN 60950-1 has requirements for flammability and mechanical strength of 
 guards well defined but EN 60950-1 itself is not in the list of harmonized 
 standards for the MD.  It is applicable to the Low Voltage Directive and the 
 MD does state that the requirements of the LVD apply.I'm wondering if the 
 EN 953 standard has the same requirements in the same level of detail or if 
 they are at least consistent.
 
 Thanks
 -Dave
 
 David P. Nyffenegger, PMP, SM-IEEE
 Product Development Manager
 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646

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[PSES] Fwd: Australian plugs and sockets

[Nick Williams]

Cancel that request, it turns out the New Zealanders have a much more helpful 
approach. 

Nick. 

Begin forwarded message:

 From: Nick Williams nick.willi...@conformance.co.uk
 Subject: Australian plugs and sockets
 Date: 1 October 2014 17:26:30 BST
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 
 Please can anyone tell me what the full title/citation is for AS/NZ 3112 - 
 which I believe is the standard for Australian domestic plugs and sockets? 
 
 Standards Australia have delegated the sales of their standards to SAI 
 Global, and SAI Global’s website doesn’t work. Deep joy. 
 
 TIA. 
 
 Nick. 
 
 


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[PSES] Australian plugs and sockets

[Nick Williams]

Please can anyone tell me what the full title/citation is for AS/NZ 3112 - 
which I believe is the standard for Australian domestic plugs and sockets? 

Standards Australia have delegated the sales of their standards to SAI Global, 
and SAI Global’s website doesn’t work. Deep joy. 

TIA. 

Nick. 



Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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Re: [PSES] weird stuff in agency agreement form

[Nick Williams]

I’d agree that this will have been driven by the accreditation body rather than 
by the Notified Body themselves. It may also be worth pointing out that the 
opportunity for unannounced visits has always been in the Directive, it’s just 
that no-one ever did it. TuV Rheinland’s failure to do unannounced visits was 
one of the key factors in the judgement going against them in the court case 
which followed the scandal. 

The fact that there has actually been no change in the legislation may be a 
good arguing point when negotiating the contract renewal with the NB. 

Nick. 


On 12 Sep 2014, at 07:07, Michael Derby micha...@acbcert.com wrote:

 Hello,
  
 I think Nick is correct, except that the requirement may not originate from 
 the Notified Body directly.
  
 I was at a meeting with a Medical Directive Notified Body recently and, 
 chatting over coffee, he mentioned that his company now needs to make these 
 unannounced visits.   A roll of the eyes and a shake of the head.   A 
 requirement of the accreditation body.
  
 I think you’re correct that it comes from the breast implant issue and from 
 what I can tell, it is all part of the duel-factory idea.
 A manufacturer has one sparkly nice factory in location A which is used on 
 accreditation day; and one other factory in location B which is used for the 
 other 364 days of the year.
 With the breast implant issue, I believe, I am told, that the NB had 
 inspected the factory but the implants were not being manufactured at the 
 factory which had been inspected.
 The idea is that the Notified Body must be able to turn up and check.
  
 At least, that’s what I was told.
  
 Michael.
  
  
 Michael Derby
 Senior Regulatory Engineer
 Director
 ACB Europe
  
 From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
 Sent: 11 September 2014 23:03
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] weird stuff in agency agreement form
  
 I’m not a betting man, but if I were, I’d lay a few quid on this having come 
 from an EU Notified Body which has a presence in the medical devices market. 
 It looks very like a reaction to the PIP breast implant scandal. 
 
 Think of it in the context of the NB trying to be seen to react to the 
 lessons from that and it may make a bit more sense. Doesn’t make it any more 
 enforceable though. 
 
 Nick. 
 
 
 On 11 Sep 2014, at 19:13, Brian Oconnell oconne...@tamuracorp.com wrote:
 
 
 Am looking at the latest 'agency' general agreement form that all CABs make 
 their clients sign in blood.
 
 A new clause states ... has the right to conduct unannounced audits at the 
 manufacture's premises as well as the premises of the manufacturers component 
 supplier and has the right to take samples. It is the obligation of the 
 holder of the certificate to ensure that an audit at the component supplier's 
 premises can be conducted.
 
 Unless all of my suppliers have previously signed this agreement, or if we 
 can somehow get all of my bazillion suppliers to sign an agreement, it would 
 seem that the test house is attempting to enforce a 'transitive' legal 
 property. Do not see how this can fly in most North American jurisdictions. 
 Is this something peculiar to EU law?
 
 Brian
 
  

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Re: [PSES] weird stuff in agency agreement form

[Nick Williams]

I’m not a betting man, but if I were, I’d lay a few quid on this having come 
from an EU Notified Body which has a presence in the medical devices market. It 
looks very like a reaction to the PIP breast implant scandal. 

Think of it in the context of the NB trying to be seen to react to the lessons 
from that and it may make a bit more sense. Doesn’t make it any more 
enforceable though. 

Nick. 


On 11 Sep 2014, at 19:13, Brian Oconnell oconne...@tamuracorp.com wrote:

 Am looking at the latest 'agency' general agreement form that all CABs make 
 their clients sign in blood.
 
 A new clause states ... has the right to conduct unannounced audits at the 
 manufacture's premises as well as the premises of the manufacturers component 
 supplier and has the right to take samples. It is the obligation of the 
 holder of the certificate to ensure that an audit at the component supplier's 
 premises can be conducted.
 
 Unless all of my suppliers have previously signed this agreement, or if we 
 can somehow get all of my bazillion suppliers to sign an agreement, it would 
 seem that the test house is attempting to enforce a 'transitive' legal 
 property. Do not see how this can fly in most North American jurisdictions. 
 Is this something peculiar to EU law?
 
 Brian
 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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Re: [PSES] No Performance Declared

[Nick Williams]

Hi Amund, 

The relevant product standard will identify the characteristics of the product 
which are regulated by the CPR and of these there will be a minimum set of 
characteristics which must be declared for the CE marking to be valid. The 
manufacturer may choose to identify the other (non-mandatory) characteristics 
as “NPD” on their Declaration of Performance. 

There has to be at least one characteristic for which performance is declared 
in order for the CE mark to be valid but for some products, only one 
characteristic is mandatory, and all others can be ‘NPD’.

Note that it is still up to individual Member States to determine which 
performance levels for specific characteristics are required for their market 
place, which means that a manufacturer may find that their product cannot be 
legally used in some territories even though it is perfectly legitimate for 
them to CE mark and sell it. 

Nick. 


On 22 Aug 2014, at 13:16, Amund Westin am...@westin-emission.no wrote:

 CPR - Construction Products Regulation (former CPD):
  
 I’ve been told that CPR products have been potted on the marked, even though 
 they clearly do not fulfill all the requirements for CE under the CPR regime.
 Is it allowed to place products into the marked if the manufactures «DoP - 
 Declaration of Performance» states «NPD - No Performance Declared»? I didn’t 
 though so …
  
 Best regards
 Amund
  
  

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Re: [PSES] Another Machinery Directive Question

[Nick Williams]

This seems to come up every time we have a discussion about the Machinery 
Directive on this mailing list. Let me say this one more time: the scope of the 
CE marking directives is defined only by the wording of the directives, not by 
the wording of any standards. There are no products where the mere existence of 
a standard moves the product in or out of the scope of the Machinery Directive. 
None. At. All. 

There are SOME products to which the Machinery Directive does not apply even 
though they meet the basic definition of a machine (an assembly of linked 
parts, at least one of which moves…”). Among these, article 1(k) of the 
Machinery Directive contains a list of six categories of product which will be 
excluded from the scope of the Machinery Directive if they are within the scope 
of the LVD. 

One of the six categories is household appliances intended for domestic use”. 
The generic standard for such equipment is EN 60335 “Household and similar 
electrical appliances. Safety”. Part 1 of EN 60335 contains an annex where the 
members of the CENELEC committee responsible for the standard have listed the 
part 2’s (“particular requirements”) of the standard and helpfully provided 
their opinion as to whether or not the type of equipment generally covered by 
the part 2 meets the definition of a household appliances intended for 
domestic use” and hence whether or not the exclusion from the Machinery 
Directive can be applied. 

Manufacturers can use the Annex as a pretty reliable guide to whether their 
product is covered by the LVD or by the Machinery Directive. However, the annex 
is only a guide. It has no legal force whatsoever, and it is still the 
responsibility of the manufacturer of the product to decide which Directive 
they should apply. 

Many manufacturers make products which are covered by EN 60335 but are not 
''intended for domestic use and hence even though the Annex may tell them that 
the product is covered by the LVD, in fact this is incorrect since the 
exclusion defined in the Machinery Directive does not apply to them. (There is, 
incidentally, a definition of ‘domestic use’ in the Machinery Guide published 
by the Commission.)

With regard to the x-ray sub system which originally started this thread, it 
fits none of the categories of exclusion defined in Article 1(k) and so if it 
has powered moving parts it is covered by the Machinery Directive. In fact, it 
sounds like it is ‘partly completed machinery’ and hence requires a Declaration 
of Incorporation rather than a Declaration of Conformity, but that’s probably 
better left as a topic for another day. 

Nick. 

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Re: [PSES] Another Machinery Directive Question

[Nick Williams]

On 15 Jul 2014, at 16:34, Carl Newton emcl...@gmail.com wrote:

 I understand the literal definition that you're applying, and when applied 
 literally I agree.  However, it appears to me that the fundamental intention 
 of the MD is to provide protection against moving parts.  

The MD covers a great deal more than just protection for moving parts. 

 With that view in mind, it's difficult to see the need for application of the 
 MD to equipment such as this where there are no exposed moving parts.  

There is a logical fallacy in this. If the purpose of the Directive is to 
ensure that moving parts are protected, you can’t then exclude items when the 
protection required by the Directive has been applied. 

 I was hoping to find a list member that has had some specific experience with 
 an AHJ or notified body concerning internal motorized parts and the MD.  
 Without another interpretation or other precedent of some kind I believe that 
 the literal interpretation will have to be applied.

Plenty of experience over here if you need it. 

 One of the problems is that there are specific colors for operator indicator 
 lights that are X-ray industry standards in both N.A. and EU for this type of 
 equipment.  Those colors don't line-up with EN 60204 and I'm not seeing any 
 other MD safety standard that can apply.

Not a diffcult problem to solve if you apply the principles of the Directive 
(including the voluntary nature of standards) correctly. 

I’m happy to provoide specific guidance if required but this is probably better 
done privately rather than via the mailing list. 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Registered in England, Company No. 3478646


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Re: [PSES] Another Machinery Directive Question

[Nick Williams]

This wording comes from 2006/42/EC, not 2006/95/EC. There is no mention of the 
Machinery Directive in any version of the LVD (including the new one, 
2014/35/EU). 

On 15 Jul 2014, at 18:20, Rick Busche rick.bus...@qnergy.com wrote:

 There have been some recent changes to the LVD, in particular 2006/95/EC 
 where the LVD addresses the machinery directive if the equipment is primarily 
 electrical. On the VDE website I found a discussion on this but I am not sure 
 if it is allowable to post that link. You can search for “redefined against 
 Low Voltage Directive”. Basically they state that LVD adequately addresses 
 the Machinery Directive for the following products.
  
 1.household appliances meant for household used
 2.audio systems and video recorders
 3.information-technology appliances
 4.normal office equipment
 5.electrical switches
 6.electric motors
  


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Re: [PSES] Another Machinery Directive Question

[Nick Williams]

I am not making a debating point, you are making an error. It’s one you have 
made on several previous occasions. Normally your posts appear to be 
authoritative, on this topic they are not, so I think it is important to 
correct you lest others with less knowledge or experience are misled. 

There is nothing in the Machinery Directive which, as you put, it recognizes 
certain product types as having, or being likely to have, a safety standard 
that addresses the same issues as the MD does, and thus do not need to have the 
MD applied”. There is a very strictly defined exclusion relating to certain 
products which are covered by the LVD, but the presence or absence of standards 
has nothing to do with whether or not a manufacturer applies that exclusion. 

It is undoubteldy true that the people who wrote the Directive had in mind that 
products covered by this exclusion have a set of well developed standards which 
can be applied and which include the mechanical risks which would otherwise be 
covered by the Machinery Directive. However, that’s not a basis on which a 
manufacturer is able to make a decision as to which Directive applies.

Your conclusion with regard to the OP is correct, but your reasoning is not. 



On 15 Jul 2014, at 19:04, John Woodgate j...@jmwa.demon.co.uk wrote:

 In message 552134b8-c906-4cf7-9ea3-e718815f9...@conformance.co.uk, dated 
 Tue, 15 Jul 2014, Nick Williams nick.willi...@conformance.co.uk writes:
 
 There are no products where the mere existence of a standard moves the 
 product in or out of the scope of the Machinery Directive. None. At. All.
 
 If that's a comment on one of my posts, I think you are just making a 
 debating point. The MD recognizes certain product types as having, or being 
 likely to have, a safety standard that addresses the same issues as the MD 
 does, and thus do not need to have the MD applied.
 
 My point is that if, as in the OP's case, there is no such standard, there is 
 no question but that the MD applies.
 -- 

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Re: [PSES] Another Machinery Directive Question

[Nick Williams]

On 15 Jul 2014, at 21:10, John Woodgate j...@jmwa.demon.co.uk wrote:

 In message 362333c8-bb29-4fd9-baba-3282cebc9...@conformance.co.uk, dated 
 Tue, 15 Jul 2014, Nick Williams nick.willi...@conformance.co.uk writes:
 
 There is nothing in the Machinery Directive which, as you put, it 
 recognizes certain product types as having, or being likely to have, a 
 safety standard that addresses the same issues as the MD does, and thus do 
 not need to have the MD applied”. There is a very strictly defined exclusion 
 relating to certain products which are covered by the LVD, but the presence 
 or absence of standards has nothing to do with whether or not a manufacturer 
 applies that exclusion.
 
 As far as I am concerned, that is a debating point and I have made no error.

Well, we will have to agree to differ then.


 The LVD, whether it should or not, does not cover mechanical hazards due to 
 the equipment itself. See Annex I, clause 2.

Veering off topic, but if this is the case then what is Annex I clause 2 item c 
referring to then?


 However, most if not all standards notified under the LVD, and all of those 
 applying to the cited exclusions in  Article 2 (k) of the MD, do cover such 
 mechanical hazards (at least I suppose the electric motor standard does: I 
 haven't seen it).

EN 60034 does not contain any provisions for mechanical safety. 

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Re: [PSES] EN60204 Safety of machinery - Electrical equipemnt of machines

[Nick Williams]

Just because it’s not listed as an ‘A’, ‘’B’, or ‘C’ standard does not mean it 
does not confer a presumption of conformity. 

The Directive does not actually recognise the ABC hierarchy of standards - this 
is a feature of EN ISO 12100 and has no legislative basis. 

Regards

Nick. 





On 27 Jun 2014, at 12:08, Ian White (SXS UK) ian.wh...@uk.spiraxsarco.com 
wrote:

 Could l please have your feedback.
  
 EN60204 appears in the OJ for the Machinery Directive, (MD) but does not give 
 a Presumption of conformity as it is not  classified as B or C standard.
  
 With other Directives if a standard is in the OJ  you get a presumption of 
 conformity, so the MD is different this respect. Just what is the status of 
 standards which appear in the MD, OJ and are not classified as A,B or C 
 standards
  
 We would like to use this standard, is there anything we can do to obtain the 
 presumption of conformity or do we just have to use a different standard ?
  
 Regards
  
 Ian White
 Compliance and Reliability.
  
 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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Re: [PSES] Machinery Directive 1.7.1

[Nick Williams]

)
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Re: [PSES] RoHS on Hardware

[Nick Williams]

Lauren,

Are you able to point to anything published by the Commission on this?

Nick. 

On 20 May 2014, at 18:15, Crane, Lauren lauren.cr...@kla-tencor.com wrote:

 
 It has recently been interpreted (by Commission and other authorities) as 
 prohibiting the resale of any in-scope but out-of-compliance EEE after July 
 2019 because of an awkward wording in Article 2(2) -- i.e., no 
 grandfathering even for items already on the market.  There is a project 
 afoot to possibly amend this concern (a public consultation recently closed 
 about this, I believe). 
 
 Regards,
 Lauren Crane
 KLA-Tencor
 
 

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[PSES] Comprehensive list of exclusions exemptions from RoHS

[Nick Williams]

Having spent some time looking and failing to find a comprehensive, 
consolidated list of exemptions and exclusions from RoHS2, which takes into 
account all of the Commission’s decisions on exemptions made since the original 
Directive was published, I have created my own. If anyone on this list would 
like a copy I’m happy to send them one on the understanding that if they spot 
any errors or omissions they tell me!

Please e-mail me direct if you would like a copy. 

Nick 


Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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Re: [PSES] PED and TPED Directives

[Nick Williams]

Not answering the question, but may be helpful:

The TPED is seen as the more stringent set of requirements. Conventionally, a 
Pi marked (i.e. TPED compliant) vessel may be installed in a CE marked pressure 
assembly without need for separate certification (CE marking) under the PED. 
The reverse is not the case. 

List of TPED Notified Bodies here:

http://ec.europa.eu/enterprise/newapproach/nando/index.cfm?fuseaction=directive.notifiedbodydir_id=141121

List of PED notified bodies here:

http://ec.europa.eu/enterprise/newapproach/nando/index.cfm?fuseaction=directive.notifiedbodydir_id=19

There are not as many names common to both lists as you might at first expect. 

Nick. 



On 10 Apr 2014, at 16:25, Rick Busche rick.bus...@qnergy.com wrote:

 I seem to have difficulty locating a copy of Directive 2008/68/EC Inland 
 Transport of Dangerous Goods. This document is referenced by Directive 
 2010/35/EU Transportable Pressure Equipment (TPED).  A related document is 
 Directive 93/23//EC Pressure Equipment Directive (PED).  I have an 
 application where the pressure vessel is intended to be stationary, BUT may 
 be transported pressurized. Obviously I am trying to understand the 
 applicability of each directive and gain a general understanding of the 
 construction details and equipment category prior to discussions with my 
 Notified Body.
  


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Re: [PSES] Pressure Vessel Directive (PED)

[Nick Williams]

Probably not. I’m not familiar with CFR 49 but the correct certification for 
portable pressure vessels in the EU is the Transportable Pressure Vessels 
Directive (TPED) 2010/35/EU, not the PED 97/23/EC. 

The mark of compliance with the TPED is the Pi Mark, not the CE mark. 

Nick. 



On 8 Apr 2014, at 22:27, Rick Busche rick.bus...@qnergy.com wrote:

  
  
 Do I understand it correctly, that having a vessel certified to the PED by a 
 notified body, means that it is also accepted by CFR 49 (DOT) for 
 transportation within the U.S.?


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Re: [PSES] machinery - lifting hooks, eyes, etc

[Nick Williams]

Pete,

EN 1677 (various parts) applies to the hook. For anything more sophisticated 
than a simple hook, take a look at EN 13155. 

Regards

Nick. 




On 2 Apr 2014, at 17:14, Pete Perkins peperkin...@cs.com wrote:

 Greetings,
 
   What is your experience with machinery lifting accessories such as
 hooks, eyes etc?  These devices are usually attached to chains and ropes or
 webbing slipped in to lift the load.  What European requirements seem to
 apply other than the EHSRs in the machinery Directive.  
 
   Your comments appreciated.  
 
 :) br, Pete
 
 Peter E Perkins, PE
 Principal Product Safety Engineer
 PO Box 23427
 Tigard, ORe  97281-3427
 
 503/452-1201 fone/fax
 p.perk...@ieee.org
 
 
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[PSES] South Africa - certification requirements for commercial electrical apparatus

[Nick Williams]

A client wishes to ship electrical apparatus to South Africa. The apparatus is 
for fixed installation in a commercial environment (it’s a type of alarm, non 
safety related). 

Is third party certification mandatory, or just a ‘nice to have’?

All insightgreatfully received. 

Regards

Nick. 


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Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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Re: [PSES] EU Declaration of Conformity

[Nick Williams]

Dave,

The person ‘authorised to compile the technical file’ does not have to be the 
Authorised Representative. The manufacturer’s DofC signatory does not have to 
be located within the EU. 

Our explanatory pages at www.doceupoint.eu may help to clarify the 
requirements. 

[Apologies if the latter point is seen to be advertising, but the pages in 
question directly address the OPs questions and I think it is more appropriate 
to provide a web link than to paste the content here]. 

Regards

Nick. 



On 27 Feb 2014, at 18:32, Nyffenegger, Dave dave.nyffeneg...@bhemail.com 
wrote:

 Hello PSES Forum,
 
 I'm looking for some feedback interpreting the DIRECTIVE 2006/42/EC OF THE 
 EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2006.   
 
 Article 3 defines:
 
 (i) 'manufacturer' means any natural or legal person who designs and/or 
 manufactures machinery or partly completed machinery covered by this 
 Directive and is responsible for the conformity of the machinery or the 
 partly completed machinery with this Directive with a view to its being 
 placed on the market, under his own name or trademark or for his own use. In 
 the absence of a manufacturer as defined above, any natural or legal person 
 who places on the market or puts into service machinery or partly completed 
 machinery covered by this Directive shall be considered a manufacturer;
 
 (j) 'authorised representative' means any natural or legal person established 
 in the Community who has received a written mandate from the manufacturer to 
 perform on his behalf all or part of the obligations and formalities 
 connected with this Directive;
 
 ANNEX II declares
 
 The EC declaration of conformity must contain the following particulars:
 
 2. name and address of the person authorised to compile the technical file, 
 who must be established in the Community;
 .
 10. the identity and signature of the person empowered to draw up the 
 declaration on behalf of the manufacturer or his authorised representative.
 
 It's not clear to me if  the person authorised to compile the technical 
 file is intended to be one and the same as 'authorised representative' or 
 not.
 
 I have often heard the that signature on the DoC also needed to come from a 
 member of the Community.  The way I read the directive that is only the case 
 for  or his authorised representative.   The Directive also states the 
 signature can be the person empowered to draw up the declaration on behalf 
 of the manufacturer .  There is nothing in the declaration that requires the 
 manufacturer or person empowered by the manufacturer to be a member of the 
 Community.  
 
 Does anyone know if there have been any further clarifications or 
 interpretations on this?
 
 David P. Nyffenegger, PMP, SM-IEEE
 Product Development Manager
 Bell and Howell
 3791 South Alston Avenue
 Durham, NC 27713
 Phone: 919.767.6419
 Web: www.bellhowell.net
 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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Re: [PSES] General Product Safety Directive

[Nick Williams]

Scott,

There is no Declaration required for the GPSD, so the question does not arise. 

Charlie is correct that the GPSD is a catch-all which applies where other 
safety directives such as those which require CE marking do not, but it’s 
probably also worth making two other points:

1. The GPSD gives enforcement officers powers relating to product problems and 
recalls which they do not have under the CE marking Directives. These powers 
extend to products covered by the CE Directves. 

2. The GPSD is not a single market directive so Member States are free to 
introduce national requirements for products which it covers. 

Regards

Nick. 


On 31 Jan 2014, at 16:19, Scott Xe scott...@gmail.com wrote:

 Charlie,
 
 Thanks for your useful info.  Is it correct to have either CE Directives or
 GPSD in the DoC?  In general, the CE Directives have their harmonised
 standard to reference.  For GPSD, it does not have the reference standard so
 what we should put in the DoC?  State the guidelines or national standard if
 any.
 
 Regards,
 
 Scott
 
 
 On 30/1/14 5:10 am, Charlie Blackham char...@sulisconsultants.com wrote:
 
 Scott
 
 Is this directive applicable to all products?
 
 No - it's more of a catch-all for consumer products not covered by other (CE
 marking) directives.
 More information  
 http://ec.europa.eu/consumers/safety/prod_legis/index_en.htm
 
 Article 3.3 of the GPSD discusses the hierarchy for demonstration of
 compliance through application of standards and/or other documents.
 
 Regards
 Charlie
 
 
 
 -Original Message-
 From: Scott Xe [mailto:scott...@gmail.com]
 Sent: 29 January 2014 03:34
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: [PSES] General Product Safety Directive
 
 Hi
 
 Is this directive applicable to all products?  If the product complies with
 the standard listed in OJ, the product is considered in compliance with GPSD?
 
 If I cannot find any relevant harmonised product specific standard for
 verification, how can the supplier demonstrate the product in compliance with
 GPSD?
 
 Best regards,
 
 Scott

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[PSES] Any TuV Rheinland North America contacts on the list?

[Nick Williams]

If so, please would they contact me directly. 

Nick. 


Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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[PSES] WEEE Directive - user information

[Nick Williams]

Article 14 of the new WEEE Directive requires manufacturers to provide 
information to product users on the process and benefits of dealing with WEEE 
in accordance with the Directive (as opposed to just thowing it away with other 
household waste). 

This requirement is not new - it was previously contained in article 10 of the 
old WEEE Directive. 

The Directive gives Member States freedom to decide how to require 
manufacturers to deliver this information and UK government guidance on the 
Directive makes it clear that providing a web link to the information in the 
user instructions, with the bulk of the information accessible via the web 
link, is an acceptable solution. 

I’d be very interested to hear what the Group’s experience of the requirements 
of other Member States is in this regard. 

Thanks

Nick. 

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Re: [PSES] Declaration of Conformity

[Nick Williams]

The reason for this is that the workplace safety requirements introduced under 
Article 137 of the TFEU require an employer to ensure that equipment which they 
supply for the use of their employees complies with the applicable essential 
requirements. The Declaration is a useful piece of paper to assist an employer 
in this task. 

Nick. 



On 3 Dec 2013, at 00:11, Kunde, Brian brian_ku...@lecotc.com wrote:

 
 The MD requires the DoC (not DoI) or a document calling out the content of 
 the DoC to be provided in the Instruction Manual. The purpose of this 
 requirement is not clear to me but it says it so you have to do it. 
 



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[PSES] Fwd: New OJEU publication of Harmonised Standards Machinery 2006/42/EC

[Nick Williams]

This will be of interest to some members here.

Regards

Nick. 

Begin forwarded message:

 From: no-re...@circabc.europa.eu
 Subject: New OJEU publication of Harmonised Standards Machinery 2006/42/EC
 Date: 28 November 2013 21:29:28 GMT
 To: nick.willi...@cem-international.co.uk
 Reply-To: mario.gabrielli-cosse...@ec.europa.eu
 
 Dear Machinery Committee and Working Group Members,
 
 We have the pleasure to announce that the new lists of references of 
 Harmonised Standards under the Machinery Directive 2006/42/EC have been 
 published today 28.11.2013 on the Official Journal of the European Union, C 
 348 (p. 5-62):
 
 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:C:2013:348:0005:0062:EN:PDF
 
 This publication is in 23 EU official languages, including Croatian, and, for 
 the first time, with the CEN references classified in A-, B- and C-type 
 standards.
 
 Best regards
 
 Mario GABRIELLI COSSELLU
 
 Mechanical Engineering Assistant Policy Officer
 

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Re: [PSES] Does conformance to EN 60335-1 + -2-29 sufficiently address possibilitiy of overcharging?

[Nick Williams]

Lauren,

I think the standards committee would argue that this hazard is dealt with by 
the requirement in EN 60335-2-29 §7.1 for a statement in the instructions  
WARNING: Explosive gases. Prevent flames and sparks. Provide adequate 
ventilation during charging. 

Regards

Nick. 






On 9 Oct 2013, at 16:58, Crane, Lauren lauren.cr...@kla-tencor.com wrote:

 Experts,
  
 I’m getting into some new (for me) territory, looking at a system with a 
 battery charger and a sealed, no maintenance, lead acid battery. The battery 
 charger claims an IUU charging profile and assessment to the subject 
 standards. I have read the standard’s abnormal operation section and see it 
 requires consideration of potential “dangerous malfunctions”.
  
 Does anyone know whether application of these standards to a charger 
 typically sufficiently considers the possibility of overvoltage output that 
 could over charge the target battery (potentially producing more H2 than the 
 battery can absorb)?
  
 Regards,
 Lauren Crane
 KLA-Tencor
  

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Re: [PSES] Ill formed question again

[Nick Williams]

Gary,

So far as I am aware there isn't a standard for x-ray scanners, but a baggage 
scanner is essentially a conveyor with a detector around it so I don't see why 
the unit load conveyors standard (EN619) and the radiation emitted by machinery 
standard (EN 12198) can't form the basis of your risk assessment. You'd also 
need to look at the other type B standards. 

Drop me a direct line if you need more help. 

Regards

Nick. 



On 8 Oct 2013, at 21:28, McInturff, Gary gary.mcintu...@esterline.com wrote:

 I have a piece of X-ray scanning equipment used in airports and I’m trying to 
 determine the appropriate Machinery directive harmonized standard it might 
 fall under – suggestions?  I’m really only doing the scanning interface but 
 it is then installed by our customer onto the rest of his equipment – which I 
 presume includes things like the luggage conveyor belt.
  
  
 Gary McInturff
 Reliability/Compliance Engineer
  
  
  
  
 Esterline Interface Technologies
 Featuring
 ADVANCED INPUT, GAMESMAN, LRE MEDICAL, and MEMTRON  products
 600 W. Wilbur Avenue
 Coeur d’Alene, ID  83815-9496
 Toll Free: 800-444-5923 X1XXX
 Tel:  (208) 635-8
 Fax: (208) 635-8
  
 www.esterline.com/interfacetechnologies
  
 Technology, Innovation, Performance…
 Information in or attached to this e-mail message may be subject to export 
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 If you have any questions about this obligation, please contact me.
  
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Re: [PSES] EMC Directive Test Plan

[Nick Williams]

David,

The EMC Directive does not mandate testing, so it's can't mandate a test plan. 
I suspect someone in a test lab has been giving you their spin. 

The Directive requires you to do an assessment, although you can substitute 
testing for the assessment if you want to. 

Of course, your assessment may conclude that you need to test. 

Nick. 



On 7 Oct 2013, at 17:01, David barid61...@yahoo.com wrote:

 All,
  
 I have been told that the EMC directive requires a test plan to be created 
 before testing begins, especially when using a third party lab.  I flipped 
 through the directive and guide to 2004/108/EC, and was unable to find this 
 requirement. 
  
 Did I miss something?  Is it just that the manufacturer is supposed to do an 
 EMC assessment? 
  
 Thanks,
  
 David
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Registered in England, Company No. 3478646


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Re: [PSES] Future of marking authorized representative on machines?

[Nick Williams]

The BIS view at the last Machinery Directive Notified Bodies meeting I went to 
(in May) was that there were unlikely to be any revisions to the Machinery 
Directive for at least five years. 

Nick. 



On 15 Jul 2013, at 23:25, Crane, Lauren lauren.cr...@kla-tencor.com wrote:

 In the Machinery Directive….
 1.   If a manufacturer has designated an Authorized Representative, the 
 AR name must be marked on the machine (ref Annex I, 1.7.3  1st indent).
 2.   A person must be identified in the Declaration of Conformity who is 
 established in the EU and is authorized to compile the technical file (ref 
 Annex II (1)(A)(2))
  
  
 Both these criteria are absent from the new legislative framework (NLF) 
 model, and the recent directives implementing the NLF model, namely RoHS2, 
 LVD3 (still in works), EMCD3 (still in works). The NLF model requires the 
 importer of equipment to “indicate their name, registered trade name or 
 registered trade mark and the address at which they can be contacted on the 
 apparatus/equipment or, where that is not possible, on its packaging or in a 
 document accompanying the apparatus/equipment.”
  
 Does anyone know if the MD anomalies marking the AR on the machine and 
 indicating in the DoC the person authorized to compile the technical file 
 will be retired soon through some sort of NLF revision of the Machinery 
 Directive?
  
  
 Regards,
 Lauren Crane
 KLA-Tencor
  
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Re: [PSES] 60950-1 durability test solvent

[Nick Williams]

Lighter re-fill fluid (as used in Zippo type cigarette lighters) is a pretty 
good match for the solvent required and comes in handy sized containers from 
many high street locations. 

Nick. 




On 26 Mar 2013, at 18:32, Gelfand, David david.gelf...@ca.kontron.com wrote:

 Is there a product I can buy at the hardware store that is roughly equivalent 
 to the hexane specified in durability test:
 
  The petroleum spirit to be used for the test is aliphatic solvent hexane 
 having a maximum aromatics content of 0,1 % by volume, a kauributenol value 
 of 29, an initial boiling point of approximately 65 °C, a dry point of 
 approximately 69 °C and a mass per unit volume of approximately 0,7 kg/l. 
 
 Thanks in advance.
 
 David
 Kontron Canada Inc.
 
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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

[Nick Williams]

Surely 'information for the user..' has to accompany every unit and if the DofC 
has to accompany the information then it does not seem to me there is much room 
for doubt  that the Directive requires a Declaration to accompany every unit. 
Can you explain the basis on which you think this is not the case?


On 30 Nov 2012, at 19:01, John Woodgate j...@jmwa.demon.co.uk wrote:

 In message 3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk, dated 
 Thu, 29 Nov 2012, Nick Williams nick.willi...@conformance.co.uk writes:
 
 AIUI, the R+TTE Directive also requires this, and there are others which do 
 the same.
 
 Article 6 3. of the RTTED says:
 
 3. Member States shall ensure that the manufacturer or
 the person responsible for placing the apparatus on the
 market provides information for the user on the intended
 use of the apparatus, together with the declaration of
 conformity to the essential requirements.
 
 Nowhere that I can find does it say a DoC has to accompany every unit.

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

[Nick Williams]

A DofC must go with every unit. 

AIUI, the R+TTE Directive also requires this, and there are others which do the 
same. 

Nick. 


On 29 Nov 2012, at 16:18, Jim Hulbert jim.hulb...@pb.com wrote:

 From article 5 of the Machinery Directive, the manufacturer or authorized 
 representative shall, among other things:
 (e) draw up the EC declaration of conformity in accordance with Annex II, 
 part 1, Section A and ensure that it accompanies the machinery;
 
 Does the above mean the DoC must be supplied with each piece of equipment, or 
 as John stated:  One full copy should go with every shipment that crosses an 
 EU border, or a Member State border...?
 
 Jim Hulbert
 

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Nick Williams]

You would not be alone if you did, Michael...



On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote:

 
  
 Honestly, I don’t actually hear these voices in my head.
  
  


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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

[Nick Williams]

There is a list of the official languages in the Commission Guide to the 
Machinery Directive, available here:

http://ec.europa.eu/enterprise/sectors/mechanical/machinery/

See §246. 

English will not suffice - if the Directive says the Declaration needs to be 
translated, then it needs to be in one of the official languages of each state 
in which the product is sold. 

I'm pretty sure that failure to deliver the Declaration in the correct 
language(s) has been cited as a non-compliance in enforcement actions in the 
past, although only as one item among several - I'v e never seen it cited as  
sole reason for rejection. 

Nick. 





On 28 Nov 2012, at 20:43, Monrad Monsen monrad.mon...@oracle.com wrote:

 RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) section 
 2 states:  The EU declaration of conformity ... shall be translated into the 
 language or languages required by the Member State on the market of which the 
 product is placed or made available.
 
 This raises some questions:
 1.  What languages are required by the member states for translating 
 declarations of conformity (DOCs)?  
 
 2.  Would English suffice for a DOC?  I would hope that any one language 
 within the community would be acceptable for the DOC, and English would be 
 the easiest language for American companies to use.
 
 3.  If a member state does want a DOC in a language other than English, would 
 they the English version immediately and then allow the manufacturer time to 
 translate the DOC like a period of two months?
 
 RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these 
 questions are urgent.
 
 Monrad Monsen
 +1.303.272.9612
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The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
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Registered in England, Company No. 3478646


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[PSES] Telephone connection accessories

[Nick Williams]

Esteemed colleagues,

What are the appropriate standards, if any, for telephone accessories such as 
extension connection cords and bells/sounders?

All help gratefully received!

Nick. 

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Re: [PSES] EU-DoC - list of applied standards with full title

[Nick Williams]

It's actually a requirement of some of the directives, not just an addition 
brought in by transposition in certain countries. Generally, where the 
Directive requires the Declaration to accompany the product, it must be 
translated in to the language of the country of the end user. 

I guess the Commissiion's logic is that the instructions will need to be 
translated into the same language(s) so it's not a significant additional 
burden to require the DofC to be translated as well. 

Nick. 



On 18 Nov 2012, at 07:56, John Woodgate j...@jmwa.demon.co.uk wrote:

 In message 
 867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com, dated 
 Sat, 17 Nov 2012, Carpentier Kristiaan kristiaan.carpent...@technicolor.com 
 writes:
 
 Some countries require in their national transposition that the EU DoC is 
 issued in the local language. Although most are still in draft: France in 
 French, Portugal in Portuguese, Germany in German,  etc..  
 
 In worst case, we have some 24 languages in EU, so lots of fun for 
 translation.
 
 Now that IS a hardship for manufacturers. The way to deal with it is for 
 manufacturers' associations to petition the Commission for a clarification of 
 the 'reference' requirement to mean just EN X:

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Re: [PSES] Standard for water hoses

[Nick Williams]

Ken,

Try EN 61770:2009 Electric appliances connected to the water mains. Avoidance 
of backsiphonage and failure of hose-sets

Regards

Nick. 

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Re: [PSES] RoHS Question

[Nick Williams]

I don't have any clearer answer than those already been given by Lauren Crane 
and William Brown, but a couple of points occur which may be grist to the mill. 

Firstly, I suspect that the original intention of including wording in the 
Directive to restrict the use of other marks has, at least in part, grown from 
the New Legislative Framework requirement intended to protect the CE mark, and 
so the intention was not to outlaw other marks per-se, but was to outlaw other 
marks which might be confused with (and taken to mean the same as) a legitimate 
CE mark. 

Secondly, and somewhat less conjecturally, the UK enforcement authority turned 
out to be spectacularly wrong in their interpretation of at least one aspect of 
the old Directive (the large scale industrial tools exemption) and so I'd be 
inclined to take anything else they say with a pinch of salt as well. 

Nick. 


On 6 Sep 2012, at 20:10, Brown, William wrote:

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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Re: [PSES] Buzzer loudness standard?

[Nick Williams]

Try EN ISO 7731. 

Regards

Nick. 



On 4 Sep 2012, at 05:34, Curt McNamara wrote:

 We have a customer product where they desire to reference an industry 
 standard for the loudness of a buzzer. They started with OSHA 3dB over 
 ambient:
 the instrument shall have an audible indicator detected 3dB above the maximum 
 OSHA 8 hour day background limit @ 3 meters.
 
 However that doesn't really tell us how loud it needs to be. It is used in a 
 clinic where animals are treated.
 
 Any suggestions?
 
 Thanks!
 
  Curt
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Re: [PSES] Ignition sources and exposure time

[Nick Williams]

On 19 Aug 2012, at 21:37, Bob Johnson wrote:

 
 This is why the safety of a product needs to be addressed by a product safety 
 engineer, not an auditor. After careful review of the hazards and conditions 
 of use, you may end up with a design with either tighter or looser 
 constraints than the standard, but you should have produced a careful 
 rationale you feel can stand up to the review of other product safety 
 engineers. 

A near- perfect encapsulation of the application of standards under the CE 
marking directives. 

Thank you. With your permission I will use these words in many of my training 
presentations from now on. 

Nick.  

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Re: [PSES] CE Marking Provoqium

[Nick Williams]

Which takes us pretty neatly back to Caveat Emptor. 

Mebbe them 'uropeen's are on to something!

Have a good weekend, all. 

Nick. 




On 17 Aug 2012, at 21:57, Peter Tarver wrote:

 There are several NRTLs in the US.  Pick your poison.
  
 With some, you pays yer money and you takes yer chances.
  
  
 Peter Tarver
 From: Brian Ceresney [mailto:bceres...@delta-q.com] 
 Sent: Friday, August 17, 2012 10:41
  
 I agree with you Ralph. I’d like to see that type of approach here as well. 
 It would help to remove the (almost) monopolies that exist for North American 
 safety compliance.
 Brian C.
  
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[PSES] Non-rewireable plugs

[Nick Williams]

Which countries, if any, require that products for domestic and office type use 
are supplied only with a moulded mains plug (i.e. do not permit products to be 
fitted with a re-wireable plug)?

Regards

Nick. 

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Re: [PSES] Interview Questions

[Nick Williams]

This has the makings of an extremely esoteric pub quiz, if we're not careful!

Here is one, adapted from a phone enquiry I dealt with this morning this 
morning: 

You have two appliances. One is marked 110 - 230V ~50Hz and the other is 
marked 110/230V ~50Hz. What do you look for on one which is missing from the 
other? 

I'll let the group answer. 

Nick. 

On 3 Jul 2012, at 19:38, Kevin Robinson wrote:

 Hello All,
 
 I have recently been tasked with writing a set of questions that job
 candidates would need to answer at the same time they apply for a
 position requiring  knowledge of product safety evaluation, testing
 and practices.  These questions would serve as an automated pre
 screening mechanism.  Questions like What does the term creepage
 distance mean? would be perfect , however the challenge that I am
 facing is finding questions that the answers are not easily found
 using Google.  If anyone has any product safety related questions that
 they would not mind sharing, I would greatly appreciate it.
 
 Kevin Robinson
 
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 Jim Bacher:  j.bac...@ieee.org
 David Heald: dhe...@gmail.com

Nick Williams
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Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


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Re: [PSES] Interview Questions

[Nick Williams]

First prize to Scott. Well done. 

Nick. 


On 3 Jul 2012, at 20:59, Aldous, Scott wrote:

 I believe Nick may be fishing for the answer - a voltage selector switch.
  
 Back to the original question… Of course, an interview is much better for 
 assessing this type of knowledge, but if you have to have questions on an 
 application where candidates fill it out from home, you could ask questions 
 based on personal experience, such as “describe an experience you have had 
 where you solved an issue with creepage distance and how you did it” or 
 something like that. People could always just lie and make something up, but 
 it should be pretty easy to tell if someone has no idea what they’re talking 
 about. Much harder to Google this type of specific problem and solution, I 
 would think.
  
 Scott Aldous
 Compliance Engineer
 AE Solar Energy
  
   +1.970.492.2065 Direct
   +1.970.407.5872 Fax
   +1.541.312.3832 Main
 scott.ald...@aei.com
 1625 Sharp Point Drive
 Fort Collins, CO 80525
  
 www.advanced-energy.com/solarenergy
  
  
 From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of IBM Ken
 Sent: Tuesday, July 03, 2012 1:43 PM
 To: Nick Williams
 Cc: Kevin Robinson; EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: Interview Questions
  
 Not sure this is what you are looking for; but the 110-230V unit is rated as 
 a range, so the tolerance would be below 110 and above 230.  The 110/230 V 
 has two distinct rating ranges, so the tolerances would be above and below 
 110 AND above and below 230VAC.  That's the first thing that pops into mind, 
 anyway.
  
 PS: Who operates at 110VAC 50Hz?
  
 
  
 On Tue, Jul 3, 2012 at 3:21 PM, Nick Williams 
 nick.willi...@conformance.co.uk wrote:
 This has the makings of an extremely esoteric pub quiz, if we're not careful!
  
 Here is one, adapted from a phone enquiry I dealt with this morning this 
 morning: 
  
 You have two appliances. One is marked 110 - 230V ~50Hz and the other is 
 marked 110/230V ~50Hz. What do you look for on one which is missing from 
 the other? 
  
 I'll let the group answer. 
  
 Nick. 
  
 On 3 Jul 2012, at 19:38, Kevin Robinson wrote:
 
 
 Hello All,
 
 I have recently been tasked with writing a set of questions that job
 candidates would need to answer at the same time they apply for a
 position requiring  knowledge of product safety evaluation, testing
 and practices.  These questions would serve as an automated pre
 screening mechanism.  Questions like What does the term creepage
 distance mean? would be perfect , however the challenge that I am
 facing is finding questions that the answers are not easily found
 using Google.  If anyone has any product safety related questions that
 they would not mind sharing, I would greatly appreciate it.
 
 Kevin Robinson
 
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Re: [PSES] 120VAC in Europe?

[Nick Williams]

110V supplied from a centre tapped to earth isolating transformer is commonly 
used on construction and industrial sites in the UK. 

Nick. 



On 31 May 2012, at 11:07, Amund Westin wrote:

 Any country in EU who use 120VAC? I don’t think so, but want to check with 
 you guys ….
  
 #Amund
 


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Re: [PSES] 120VAC in Europe?

[Nick Williams]

Only for equipment intended for the industrial/construction sites where this 
voltage are used (mainly lighting and portable tools). 

Nick. 


On 31 May 2012, at 11:25, Amund Westin wrote:

 So, for CE marking, 110-120VAC should be tested in addition to 230VAC?
  
 The EUT has a switch to choose 120VAC or 230VAC supply voltage.
  
 #Amund
  
 Fra: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
 Sendt: 31. mai 2012 12:18
 Til: amund
 Kopi: EMC-PSTC@LISTSERV.IEEE.ORG
 Emne: Re: 120VAC in Europe?
  
 110V supplied from a centre tapped to earth isolating transformer is commonly 
 used on construction and industrial sites in the UK. 
  
 Nick. 
  
  
  
 On 31 May 2012, at 11:07, Amund Westin wrote:
 
 
 Any country in EU who use 120VAC? I don’t think so, but want to check with 
 you guys ….
  
 #Amund
  
  

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Re: [PSES] IEC 61010-1 - Ed 2 V Ed 3?

[Nick Williams]

John,

Do you really mean 61010, or did you mean 60601-1?

Nick. 



On 17 May 2012, at 19:57, John Allen wrote:

 Hi Folks
  
 My turn to ask a question!
  
 At the moment I am engaged on a contract where the above may have a 
 significant impact!
  
 So, can anyone provide/point to any comparisons between the 2nd  3rd 
 editions of the standard?
 (and yes, I already know about many of the significant additions to the 
 standard in Ed 3 in terms of the risk-assessment requirements  - which could 
 be quite significant in the current context, and of which I have done quite a 
 lot over the last few years)?
  
 Any pointers would be most appreciated.
  
 Many Thanks in advance.
  
 John Allen
 Compliance With Experience Ltd.
 London, UK

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Re: [PSES] Machinery Directive silly question?

[Nick Williams]

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Re: [PSES] Machinery Directive silly question?

[Nick Williams]

Ted,

I understand where you are coming from, but I am still of the view that your 
approach (as described in your e-mail) is fundamentally flawed since it implies 
that the scope of the directive is determined by the applicability or otherwise 
of one or more standards, and this is never the case. Yes, you can use the 
existence of a standard as an indicator as to what constitutes a domestic 
appliance, but it is never a conclusive factor on its own. 

It is also important to realise that there are many 'domestic appliance' 
standards (e.g. parts of the EN 60335-1 series) which are harmonised under the 
Machinery Directive instead of or as well as the LVD. Annex ZF in EN 60335-1 
attempts to address this point, but I'm far from convinced that it is 
completely successful. 

Your point about toys is valid in the context of my reply - I was in a bit of a 
hurry earlier and overlooked the fact that (as correctly pointed out by Carl 
Newton) it is article 3 of 2006/42/EC which deals with more specific 
directives, this is not part of Article 1. However, if I were to change my 
phrase to:

To put it in its simplest terms, if a product has powered moving parts then, 
irrespective of the status or otherwise of any standards, it is within the 
scope of the Machinery Directive unless it is excluded by one of the clauses in 
Article 1 or by Article 3. That's all there is to it.

I would be correct since both the Toy Safety Directive and the Medical Devices 
Directive are more specific. (As it happens, the Medical Devices Directive 
actually says that for products which are machines, you also have to apply the 
EHSRs of the Machinery Directive alongside those of the Medical Devices 
Directive, but that's a topic for another day!)

Regards

Nick. 






On 30 Apr 2012, at 18:13, Ted Eckert wrote:

 I am proposing using the harmonized standards as guidance, not as an absolute 
 determination. Article 1, Clause 2(k) gives specific exemptions including 
 “household appliances intended for domestic use”. How can you be sure your 
 product is a household appliance reasonably covered by the LVD? If there is a 
 harmonized standard under the LVD, then you at least have a good argument to 
 make for declaring under the LVD. Without the narrow scope of the standard, 
 you are left to argue the overly broad scope of the LVD versus the overly 
 broad scope of the Machinery Directive.
  
 I would also state that your simplest terms are a little too simple. There 
 are plenty of electrical children’s toys that could fit within your 
 description. Lego Technic provides motors, transmissions, gears and other 
 parts for a child to make something quite resembling a machine. The Machinery 
 Directive does not exclude toys, but I have yet to see any of these toys 
 declared under anything but the Toy Directive. The Machinery Directive does 
 not exclude medical equipment, yet those products often have complex moving 
 assemblies.
  
 However, let me state that I am far from an expert in the Machinery Directive 
 and I encourage all with contrary opinions to respond to set me straight. I 
 am just another person trying to deal with the broad scopes and limited 
 guidance available.
  
 Ted Eckert
 Compliance Engineer
 Microsoft Corporation
 ted.eck...@microsoft.com
  
 The opinions expressed are my own and do not necessarily reflect those of my 
 employer.
  
 From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
 Sent: Monday, April 30, 2012 9:21 AM
 To: Ted Eckert
 Cc: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: Machinery Directive silly question?
  
 I've said this before. The status of standard DOES NOT determine whether 
 product is within the scope of a particular Directive or not. 
  
 To put it in its simplest terms, if a product has powered moving parts then, 
 irrespective of the status or otherwise of any standards, it is within the 
 scope of the Machinery Directive unless it is excluded by one of the clauses 
 in Article 1. That's all there is to it. 
  
 Nick. 
  
  
  
  
  
  
 On 30 Apr 2012, at 17:00, Ted Eckert wrote:
 
 
 The first question I would ask is whether there is a product specific 
 standard that covers your product. If so, then determine if that product 
 specific standard is a harmonized standard under one of the other directives. 
 In that case, the machinery directive would not apply.  
 
 For example, an air conditioner has plenty of moving parts. However, a small 
 portable air conditioner intended to be installed and used by general users 
 is covered by EN 60335-2-40, which is a harmonized standard under the Low 
 Voltage Directive. This air conditioner would not fall under the Machinery 
 Directive. 
 
 On the other hand, a large commercial air conditioner designed to be 
 installed on the roof of a building is not within the scope of EN 60335-2-40. 
 There are general standards covering the mechanical safety and the safety of 
 the pressurized system, but not an overarching product standard

Re: [PSES] Machinery Directive silly question?

[Nick Williams]

This is incorrect. This approach was permitted by 98/37/EC but 2006/42/EC no 
longer permits this kind of analysis.

Regards

Nick. 

On 30 Apr 2012, at 18:33, Peter Merguerian wrote:

 Mark,
 
 You need to do a comprehensive  risk assessment and determine if the risk of 
 injury to persons using or servicing the equipment  is more mechanical or 
 more electrical. You may have a moving part that is inside the equipment and 
 inaccessible. How fast is that moving part? How is it secured? Is it 
 accessible to a service person? Can the interlock of access doors be 
 defeated? Lots and lots of questions that your engineering team need to ask 
 before deciding which Directive must be applied. 
 
 

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[PSES] IATA regs for carriage of lithium batteries

[Nick Williams]

Does anyone have a copy of the 2012 version for the IATA regs/guide for the 
carriage of lithium batteries by air, which they could e-mail me please? I've 
been trying to download it from the IATA site but it seems to have crashed, and 
I need a copy for Monday morning if at all possible. 

Nick. 

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Re: [PSES] IATA regs for carriage of lithium batteries

[Nick Williams]

Thanks to those who replied. I now have what I need. 

Regards

Nick. 

On 31 Mar 2012, at 11:43, Nick Williams wrote:

 Does anyone have a copy of the 2012 version for the IATA regs/guide for the 
 carriage of lithium batteries by air, which they could e-mail me please? I've 
 been trying to download it from the IATA site but it seems to have crashed, 
 and I need a copy for Monday morning if at all possible. 
 
 Nick. 
 

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Re: [PSES] ACMA labelling arrangement change announcement

[Nick Williams]

-pstc.html
 
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Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
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Re: [PSES] RTTE compliance test reports

[Nick Williams]

On 28 Feb 2012, at 17:11, Amund Westin wrote:

 My input on this issue:
  
 · Notified Body = Appointed by authorities for testing / 
 certification according to an EU directive
 · Accredited laboratory = Fulfil ISO/IEC 17025 Laboratory 
 Accreditation (criteria for laboratories to demonstrate the technical 
 competence to carry out specific test methods)

Correct. 


  
 I assume that a Notified body must also be an Accredited laboratory, but not 
 visa versa.

Not necessarily. The requirement for appointment as a Notified Body is to have 
the appropriate competence to make judgements about whether or not a product 
complies with a particular Directive's essential requirements (as well as 
certain other administrative requirements such as independence from the 
manufacturer of the products they are auditing, and appropriate indemnity 
insurance). There is no specific requirement for an NB to be accredited as a 
test lab, although they frequently are. 

Nick. 



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Re: [PSES] EU NLF directives

[Nick Williams]

Brian,

The answer to your second question is 'no'. 

With respect, you seem to have missed the point that the NLF has no direct 
bearing on manufacturers - it is a set of rules and principles for legislators, 
enforcement agencies and accreditation bodies. 

You can be forgiven for failing to understand this, others have made the same 
mistake. 

However, in practice what it means is that if you are a manufacturer, you can 
essentially ignore the NLF and focus on what is in the directives and 
regulations themselves. Competence is not legislated for in any of the New 
Approach directives, nor is any such requirement introduced in the current set 
of proposed amendments which will align several of the older Directives with 
the principles of the NLF. 

Nick. 




On 20 Feb 2012, at 22:45, Brian Oconnell wrote:

 I concur that, for now, the principle that self declaration remains the
 basis of the system remains in place. How should the requirements for
 competence and accreditation be addressed? 
 Conformity assessment requires:
 1. Internal product control
 2. Recurring product testing
 
 The presumption of conformity is based on the competence to perform these
 two activities. Will NB audits be the only acceptable way?
 
 Brian
 
 

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Re: [PSES] Digital Signatures on DofC

[Nick Williams]

This isn't addressed by any of the guidance, and it's certainly not in the 
directives themselves, so far as I aware. I think it's outside the competence 
of the Commission to determine, since it's basically a matter of admissibility 
of evidence, and this is a matter for the courts concerned. 

Also, taking a different tack entirely, any requirement for a signature to be 
'real' would surely be contrary to the Treaty articles concerned with ensuring 
equality of treatment for disabled people. 

Nick. 

On 11 Jan 2012, at 13:47, Jim Hulbert wrote:

 This question has probably been asked before, but is a digital signature on a 
 EU DofC an acceptable signature form?
 Thanks.
 Jim Hulbert
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Re: [PSES] EU Directives versus Regulations

[Nick Williams]

The key difference is that Regulations take direct effect in the member states 
of the EU and do not require national legislation to implement them.

Nick



On 10 Jan 2012, at 19:54, Peter Tarver ptar...@enphaseenergy.com wrote:

 The Construction Product Regulation (305/2011/EU) is replacing the
 Construction Product Directive (89/106/EEC).
 
 Is there a palpable difference between an EU Directive and a Regulation?
 Some fewer whereases, but the look and feel is the same.
 
 Regards,
 
 Peter L. Tarver
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Re: [PSES] Machinery Directive DOC Questions

[Nick Williams]

On 4 Jan 2012, at 19:04, Kunde, Brian wrote:

 all of our products have fans.
 

In which case, according to the letter of the law, they are machinery if they 
are not one of the six categories excluded by article 1 item 2k. 


 But, some say fans don't count.

Ask them to provide documentary evidence to support that contention. I'm 
prepared to bet they won't be able to. 


 But do they? Some of our products have huge fans, blowers, vacuum pumps, 
 solenoids, contactors, and other such moving parts, so where do you draw the 
 line?

There is no line. Why are you making life difficult for yourself by trying to 
find one?

Nick. 

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Re: [PSES] Machinery Directive DOC Questions

[Nick Williams]

Brian,

I'm in a bit of a rush this evening so I can't spend as much time on this as 
perhaps it deserves, but maybe the following questions/observations will help 
to carry this forward:


On 4 Jan 2012, at 17:38, Kunde, Brian wrote:

  
 Our company makes laboratory equipment (the red-headed step child) which has 
 no defined category of its own so it generally falls under the LVD unless it 
 has a moving part to which it is now subject to the machinery directive 
 (which is a new nightmare for me). But like many products produced these 
 days, our products are built-to-order with dozens of variations and possibly 
 hundreds of different combinations. We evaluate each model family in its 
 maximum configuration with all possible variations installed for EMC and 
 Safety which generally includes a sample loader or autoloader (moving parts). 
 So we evaluate, test, and declare compliance to the Machinery Directive and 
 generate a DOC for that product family.
  
 Question #1
  
 When a customer orders a configuration that does not include the sample 
 loader (moving part), can we still declare compliance to the MD or in these 
 cases do we have to generate a different DOC declaring to the LVD? In this 
 case, would we have to establish a system to produce custom DOCs for each 
 device produced depending on the options ordered by the customer?

Can you not perhaps issue separate Declarations for each part of the system, 
plus one over-arching Declaration for a system which consists of all the 
possible options/permutations (which deals with the Machinery Directive 
'co-ordinated machinery' aspect)?

  
 Question #2
  
 Because the MD requires an accompanying unique signed DOC for each such 
 device built and to include the specific model number (based on options 
 ordered) and serial number, how do most companies logistically handle this? I 
 don’t imagine that each company has a “Managing Director” sitting at the end 
 of the product line signing, copying, packing, and filing the DOC for each 
 product built. So how can this be reasonably done and still meet the intent 
 of the Directive? 
  
 

There is no requirement for there to be a serial number, and even where there 
is, one Declaration can cover a range of serial numbers. Here is what the 
Machinery Guide says:

As a general rule, the serial number of the machinery covered by the EC
Declaration of Conformity shall be indicated. In the case of machinery
produced in large series, it is possible to draw up a single EC Declaration of
Conformity covering a range of serial numbers or batches, in which case the
range covered by the declaration must be specified and a new EC Declaration
of Conformity must be issued for each new range of serial numbers or batches.
In any case, the necessary identification must be provided to ensure the link
between each item of machinery and the EC Declaration of Conformity that
applies to it.


I think you need to consider what is practical as well as the exact letter of 
the law. It is sometimes helpful to consider this from the angle of what the 
Technical File says - if you do a separate risk assessment for every model 
built then a unique, signed, individual DofC for each unit is probably 
appropriate, but if you use a risk assessment which covers a range of models 
and serial numbers then it is probably appropriate to issue a Declaration which 
covers the same range. 

Happy to continue this correspondence privately if you wish!

Nick. 


Nick Williams
email: nick.willi...@conformance.co.uk

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Re: [PSES] Orgalime: UL an effective barrier to trade

[Nick Williams]

One quick point for our non-EU friends is to point out that Orgalime are a 
trade body who, in theory at least, represent European manufacturers. They have 
no official legal status as arbiters of trade agreements (or anything else for 
that matter).

That's not to say they do not have a point in this case, but they should only 
be seen as once voice in the discussion, and a partial one at that. 

Nick. 


Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

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Re: [PSES] CE Requirements for Parts Washers Sand Blast Cabinets

[Nick Williams]

Brian,

EMC will likely be the least of your problems. 

Parts washers may well be in the scope of the Machinery Directive rather than 
the LVD. Additionally, if the manufacturer does not prohibit their use with 
flammable solvents then they will be ATEX equipment (and will probably require 
Notified Body approval).

Sand blast cabinets may be none, one or several of machinery, pressure 
equipment or simple pressure vessels, and there could also be a PPE (personal 
protective equipment) angle. 

Feel free to contact me directly if you need more detailed help. 

Nick. 



On 18 Nov 2011, at 13:54, Kunde, Brian wrote:

 In Europe for self declaration for the application of the CE marking, what 
 Safety and EMC tests/standards/directives are required for Parts Washers and 
 Sand Blast Cabinets, most typically used in shops and garages to clean auto, 
 farm, and machinery parts and the like?
 
 Is there a family standard or just use the generic EMC requirements?
 
 Since these are commercial/industrial motor driven devices with no RF 
 circuitry, what EMC tests have to be performed, if any?
 
 I assume the IEC/EN 61010-1 would apply for safety. Do the AC Motor(s) have 
 to be approved by a European Safety Agency or is UL/CSA good enough? Are 
 there other more specific safety standards regarding these type of devices? I 
 assume the Parts Washers may have a flammability hazard if flammable solvent 
 is used. And Sand Blasting has its own safety issues, but these are just the 
 cabinets/enclosures with some kind of abrasive reclaim system.
 
 Sorry I'm asking this kind of question, but this is for a US company that 
 would like to get into the European market and this is a category of product 
 I'm not at all familiar with.
 
 Thanks to all for any information provided.
 
 The Other Brian
 

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Re: [PSES] CE marking of deep-fat fryer

[Nick Williams]

Hi Pete,

By commercial, do you mean for use in a restaurant or retail (take away) 
environment or in a food factory?

Is it gas heated or electric?

Any powered moving parts?

Nick. 


On 14 Nov 2011, at 21:00, Pete Perkins wrote:

 PSNet,
 
   Looking for input on requirements for CE marking of a commercial
 deep-fat fryer.  
 
   What's the latest?  
 
 :) br, Pete
 
 

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Re: [PSES] CE marking of deep-fat fryer

[Nick Williams]

60335-2-37 is for commercial appliances but isn't much use for gas fired or 
food factory type equipment. 

Nick. 





On 14 Nov 2011, at 22:14, John Woodgate wrote:

 In message AB6009628A08455FAACB848DCB89BA9E@Pete97219Compaq, dated Mon, 14 
 Nov 2011, Pete Perkins peperkin...@cs.com writes:
 
  Looking for input on requirements for CE marking of a commercial
 deep-fat fryer.
 
  What's the latest?
 
 IEC 60335-2-13
 Edition 6.0 (2009-12-14)
 Household and similar electrical appliances - Safety - Part 2-13: Particular 
 requirements for deep fat fryers, frying pans and similar appliances
 
 This is mainly aimed at household appliances, but SC61E hasn't got round to 
 making a separate standard for commercial appliances.
 -- 

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Re: Certification Standards for terminal block accessories?

[Nick Williams]

Have you looked at the -7-x parts of the EN 60947 series of standards 
(e.g. EN 60947-7-1)?

Nick.


At 16:12 -0600 15/1/09, lauren_cr...@amat.com wrote:
All,

Does anyone know of a certification standard (e.g., UL, EN) that may 
exist for terminal block accessories. I am specifically curious 
about jumper bars used to bridge the continuity of adjacent 
terminals.

I've gotten a few hits on Google related to ATEX considerations, but 
my focus is just on basic shock and fire issues.

Regards,
Lauren Crane
Product Regulatory Analyst
Corporate Product EHS Lead
Applied Materials Inc.
Austin, TX 512 272-6540 [#922 26540]
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