Re: [PSES] Another Machinery Directive Question

[Paul Milton]

Hi Carl,



You don’t have to apply 60204-1 to comply with the MD.  I think the only
mandatory product requirements for the MD are those of Annex I.  Your
likely OK applying 61010-1 as a reference standard for electrical hazards
and the Annex I to meet minimum requirements of the MD.  I believe this is
what Doug was eluding to in his first email, he can correct me if I’m wrong.



Good Luck,



Paul



*From:* Carl Newton [mailto:emcl...@gmail.com]
*Sent:* Thursday, July 17, 2014 9:58 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Another Machinery Directive Question



Doug,



I've reviewed the OJ list of safety standards applicable to the MD and
there is nothing there applicable to X-ray equipment (no surprise).  I view
EN 60204 as a "catch-all" fall-back standard for electrical equipment that
falls within the scope of the MD, but which has no other relevant standard
listed.

I would not apply 60204 for any reason other than to comply with the MD.



Generally, I consider the strict literal interpretation of the scope of the
MD to be excessive in many cases.  For example, a piece of industrial
equipment intended to do nothing but perform a monitoring function, but
which includes an internal cooling fan, can be considered to fall within
the scope of the MD if you apply the following definition literally:



The following definitions shall apply:
(a) ‘machinery’ means:

— an assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or
animal effort, consisting of linked parts or components,
at least one of which moves, and which are joined
together for a specific application,



If that industrial monitoring equipment doesn't fall within the scope of
any of the exclusions included within the MD, then the fact that the fan is
motor-driven should force the equipment into the scope of the MD if
interpreted literally.  In this example, EN 61010-1 should probably be
applied.  But as we all know, that doesn't provide us a path to the
standards route to compliance when applying self-declaration under the MD.



Good information on the indicator requirements.  I haven't yet studied the
latest edition of 60204 and it's been many years since I've read the
standard.



Thanks again very much to all,



Carl



On Tue, 15 Jul 2014 12:32:57 -0400, Mr. Doug Nix C.E.T. 
wrote:



Carl,



With respect to:



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.



Is EN 60204-1 the most appropriate standard for this machinery? If the
machine were covered only by the LVD, would you still choose EN 60204-1?



If the answer is YES, then I completely agree with Lauren, you can use
whatever indicator lights are normal in your industry, provided the
colours, flash rates and any other characteristics that are important
interns of understanding the indications are explained in the manuals.



The indicator colours given in EN 60204-1 are there for designs that
conform to the more general types of machinery found in industry, and not
more specialized equipment like that you describe. The key language is in
the second paragraph of Clause 10.1.1:



“*As far as is practicable*, those devices shall be elected, mounted, and
identified or coded in accordance with IEC 61310."



 I recognize that Clause 10.2.1 is worded as a SHALL clause, but this is
why I question the use of EN 60204-1 for your product.



Doug Nix

d...@ieee.org

+1 (519) 729-5704



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Re: [PSES] Another Machinery Directive Question

[Carl Newton]

Doug,

I've reviewed the OJ list of safety standards applicable to the MD and  
there is nothing there applicable to X-ray equipment (no surprise).  I  
view EN 60204 as a "catch-all" fall-back standard for electrical equipment  
that falls within the scope of the MD, but which has no other relevant  
standard listed.

I would not apply 60204 for any reason other than to comply with the MD.

Generally, I consider the strict literal interpretation of the scope of  
the MD to be excessive in many cases.  For example, a piece of industrial  
equipment intended to do nothing but perform a monitoring function, but  
which includes an internal cooling fan, can be considered to fall within  
the scope of the MD if you apply the following definition literally:


The following definitions shall apply:
(a) ‘machinery’ means:

— an assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or
animal effort, consisting of linked parts or components,
at least one of which moves, and which are joined
together for a specific application,

If that industrial monitoring equipment doesn't fall within the scope of  
any of the exclusions included within the MD, then the fact that the fan  
is motor-driven should force the equipment into the scope of the MD if  
interpreted literally.  In this example, EN 61010-1 should probably be  
applied.  But as we all know, that doesn't provide us a path to the  
standards route to compliance when applying self-declaration under the MD.


Good information on the indicator requirements.  I haven't yet studied the  
latest edition of 60204 and it's been many years since I've read the  
standard.


Thanks again very much to all,

Carl

On Tue, 15 Jul 2014 12:32:57 -0400, Mr. Doug Nix C.E.T.   
wrote:



Carl,

With respect to:

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.


Is EN 60204-1 the most appropriate standard for this machinery? If the  
machine were covered only by the LVD, would you still choose EN 60204-1?
If the answer is YES, then I completely agree with Lauren, you can use  
whatever indicator lights are normal in your industry, provided the  
colours, >flash rates and any other characteristics that are important  
interns of understanding the indications are explained in the manuals.


The indicator colours given in EN 60204-1 are there for designs that  
conform to the more general types of machinery found in industry, and  
not more >specialized equipment like that you describe. The key language  
is in the second paragraph of Clause 10.1.1:


“As far as is practicable, those devices shall be elected, mounted, and  
identified or coded in accordance with IEC 61310."


I recognize that Clause 10.2.1 is worded as a SHALL clause, but this is  
why I question the use of EN 60204-1 for your product.


Doug Nix
d...@ieee.org
+1 (519) 729-5704




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Re: [PSES] Another Machinery Directive Question

[John Woodgate]

In message <0c497189-6f38-433b-be0b-035977229...@conformance.co.uk>, 
dated Tue, 15 Jul 2014, Nick Williams  
writes:


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


It's so general that one could speculate for hours. I've always regarded 
it as referring to hazards caused by the equipment to persons or things 
outside it, not to what goes on inside it. But to avoid further 
discussion, I agree that you can interpret it as embracing internal 
goings-on as well.

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Re: [PSES] Another Machinery Directive Question

[John Woodgate]

In message <682dea2d-d7a2-4735-b506-7940d46a3...@conformance.co.uk>, 
dated Tue, 15 Jul 2014, John Cotman  
writes:


And just to add another couple of points:  the application of standards 
under both the Machinery and Low Voltage Directives is voluntary.  How 
could it possibly be the case that a voluntary standard could change 
statute law?


Did anyone claim that it could? I think this thread is getting very 
confused. The OP's product is subject to the MD, however 'like' a 
product that is not covered by the MD, not because of a standard but 
because the MD says so.


 The matter of standards arises when one considers why the MD lists the 
exemptions that it does. It say it exempts them because they are covered 
by the LVD (the reference is to an old version of the LVD). But, as I 
pointed out, the LVD itself doesn't say anything about mechanical 
hazards - but most standards notified under it do cover them.

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Re: [PSES] Another Machinery Directive Question

[Nick Williams]

On 15 Jul 2014, at 21:10, John Woodgate  wrote:

> In message <362333c8-bb29-4fd9-baba-3282cebc9...@conformance.co.uk>, dated 
> Tue, 15 Jul 2014, Nick Williams  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] Another Machinery Directive Question

[John Woodgate]

In message <362333c8-bb29-4fd9-baba-3282cebc9...@conformance.co.uk>, 
dated Tue, 15 Jul 2014, Nick Williams  
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. The LVD, whether it should or not, does not cover mechanical 
hazards due to the equipment itself. See Annex I, clause 2. (Clause 3 is 
about external mechanical hazards only.) 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).

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Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Another Machinery Directive Question

[John Cotman]

And just to add another couple of points:  the application of standards under 
both the Machinery and Low Voltage Directives is voluntary.  How could it 
possibly be the case that a voluntary standard could change statute law?

A machine with correctly guarded parts may well satisfy an essential 
requirement of the MD regarding accessibility of hazardous moving parts.  But 
determining that is part of assessing the machine; it doesn't make it "not a 
machine".  It would be unwise, however, to suppose that satisfying that one 
essential requirement constitutes a full MD risk assessment.

John Cotman
Senior Consultant
Direct line: +44 1298 873841
Mobile: +44 7793 770730
email: john.cot...@conformance.co.uk

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On 15 Jul 2014, at 19:38, Nick Williams  wrote:

> 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  wrote:
> 
>> In message <552134b8-c906-4cf7-9ea3-e718815f9...@conformance.co.uk>, dated 
>> Tue, 15 Jul 2014, Nick Williams  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]

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  wrote:

> In message <552134b8-c906-4cf7-9ea3-e718815f9...@conformance.co.uk>, dated 
> Tue, 15 Jul 2014, Nick Williams  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

[John Woodgate]

In message <552134b8-c906-4cf7-9ea3-e718815f9...@conformance.co.uk>, 
dated Tue, 15 Jul 2014, Nick Williams  
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.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Another Machinery Directive Question

[Rick Busche]

As a point of clarification, I contacted Nick directly and yes the reference 
was from 2006/42/EC but the interpretation by the VDE appears to be an 
interruption by someone for whom English is not their primarily language. That 
said the complexity of the directives and standards never ceases to amaze me.



Rick Busche
Certification Engineer
H. +1 801 814-4006
T.  +1 801 814-4006
E.rick.bus...@qnergy.com<mailto:rick.bus...@qnergy.com>
W.  www.qnergy.com<http://www.qnergy.com/>
From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: Tuesday, July 15, 2014 11:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Another Machinery Directive Question

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 
mailto: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

[John Woodgate]

In message <7678727.354885.1405439788733.JavaMail.root@vznit170146>, 
dated Tue, 15 Jul 2014, "Dan Roman, N.C.E."  
writes:


Check the particular safety standards you intend to use to demonstrate 
compliance.  It may give you an out.  For example, some of the EN 
60335-2-* standards state in the introduction that the Machinery 
Directive is not applicable because a risk assessment in accordance 
with the Machinery Directive has shown that the risks are mainly of 
electrical origin.  Therefore the products covered by the scope of the 
standard are fully covered by the Low Voltage Directive.


That is a household appliance (utilizing motors) example, but I see 
your product as no different than a household appliance with a fan in 
it for example.

 


It isn't very different but it is not a household appliance to which any 
Section of IEC/EN 60335 can be applied.


There really is no point in trying such tortuous methods to evade a 
Directive, and regulators will be far more unfavourably impressed by 
such an attempt than by a simple failure to conform.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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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  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]

On 15 Jul 2014, at 16:34, Carl Newton  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

-

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] 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

[Rick Busche]

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


Rick Busche
Certification Engineer
H. +1 801 814-4006
T.  +1 801 814-4006
E.rick.bus...@qnergy.com
W.  www.qnergy.com



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Re: [PSES] Another Machinery Directive Question

[Dan Roman, N.C.E.]

Carl,Check the particular safety standards you intend to use to demonstrate compliance.  It may give you an out.  For example, some of the EN 60335-2-* standards state in the introduction that the Machinery Directive is not applicable because a risk assessment in accordance with the Machinery Directive has shown that the risks are mainly of electrical origin.  Therefore the products covered by the scope of the standard are fully covered by the Low Voltage Directive.That is a household appliance (utilizing motors) example, but I see your product as no different than a household appliance with a fan in it for example. -- Dan Roman, N.C.E.Senior Member, IEEEVP Communications ServicesIEEE Product Safety Engineering Societymailto:dan.ro...@ieee.orghttp://www.ieee-pses.org On 07/15/14, Carl Newton wrote: Doug,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.  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.  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.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.Thanks all for your input.  Sorry for the late reply, I've been  motorcycling in northern Michigan sans laptop for the last four days.CarlOn Fri, 11 Jul 2014 15:00:48 -0400, Douglas Nix <d...@mac.com> wrote:> Carl, Paul, List members,>> This is not gray at all. The assembly meets the fundamental definition  > of machinery from Article 2 of the Directive:>>> The following definitions shall apply:>> (a) ‘machinery’ means:>>>> — an assembly, fitted with or intended to be fitted with a>> drive system other than directly applied human or>> animal effort, consisting of linked parts or components,>> at least one of which moves, and which are joined>> together for a specific application,>>>> — an assembly referred to in the first indent, missing only>> the components to connect it on site or to sources of>> energy and motion,>> Based on this, I would see this assembly as falling into Article 13,  > “Partially Completed Machinery”. Compliance with Annex I is required,  > which will >also cover the electrical safety requirements under Annex I,  > 1.5.1 Electricity Supply. This clause requires you to apply the  > electrical safety standards >that you would use if you were applying the  > LVD.>> If you want to discuss this more, feel free to contact me offline.>> Doug Nix> d...@ieee.org> +1 (519) 729-5704>>> On 11-Jul-14, at 14:43, Paul Milton <p...@gmcompliance.com> wrote:>>> Hi Carl,>>>> Good question.  I've found this to be a very gray area myself as to what>> does or does not fall under the MD.  For your device it may not be that>> the shutter motors are specifically responsible for its inclusion under>> the MD.  It might be that the typical end use equipment these sources  >> are>> to be installed in is considered machinery, and the customers buying  >> X-ray>> sources are requesting MD of their component manufacturers.>>>> Thanks,>>>> Paul>> -Original Message->> From: Carl Newton [mailto:emcl...@gmail.com]>> Sent: Friday, July 11, 2014 5:40 AM>> To: EMC-PSTC@LISTSERV.IEEE.ORG>> Subject: [PSES] Another Machinery Directive Question>>>> Group members,>>>> I'm working with a company that manufactures an X-ray source  >> sub-assembly.>> This product includes the X-Ray source and an electronic>> interface controller.  The intended use is for the customer to>> incorporate the device into automated laboratory equipment that will be>> subject to the machinery directive.>>>> This X-ray source includes a motor-driven shutter which is under  >> computer>> control.  The shutter is  enclosed within a housing and is not operator>> accessible.>>>> This company has informed me that one of their German competitors claims>> that their very similar sub-assembly complies with the MD.>>>> Does the fact that the device includes an internal motor-driven shutter>> bring it into the scope of the MD?  That s

Re: [PSES] Another Machinery Directive Question

[Crane, Lauren]

Carl,

Is this item a finished product or a component? The MD guide suggests 
components are not in scope (though contracts might require conformance as much 
as practicable to help ensure the final finished product conforms ).

“The Machinery Directive does not apply as such to separate machinery components
such as, for example seals, ball-bearings, pulleys, elastic couplings, solenoid 
valves,
hydraulic cylinders, flange-connected gearboxes and the like, that do not have a
specific application and that are intended to be incorporated into machinery. 
The
complete machinery incorporating such components must comply with the relevant
essential health and safety requirements. The machinery manufacturer must
therefore choose components with adequate specifications and characteristics.”


60204-1 allows indicator lights to be whatever is agreed between supplier and 
user.



Regards,
Lauren Crane
KLA-Tencor

From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Tuesday, July 15, 2014 10:34 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Another Machinery Directive Question

Doug,

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.  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.  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.

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.

Thanks all for your input.  Sorry for the late reply, I've been motorcycling in 
northern Michigan sans laptop for the last four days.

Carl


On Fri, 11 Jul 2014 15:00:48 -0400, Douglas Nix 
mailto:d...@mac.com>> wrote:

Carl, Paul, List members,

This is not gray at all. The assembly meets the fundamental definition of 
machinery from Article 2 of the Directive:

The following definitions shall apply:
(a) ‘machinery’ means:

— an assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or
animal effort, consisting of linked parts or components,
at least one of which moves, and which are joined
together for a specific application,

— an assembly referred to in the first indent, missing only
the components to connect it on site or to sources of
energy and motion,

Based on this, I would see this assembly as falling into Article 13, “Partially 
Completed Machinery”. Compliance with Annex I is required, which will also 
cover the electrical safety requirements under Annex I, 1.5.1 Electricity 
Supply. This clause requires you to apply the electrical safety standards that 
you would use if you were applying the LVD.

If you want to discuss this more, feel free to contact me offline.

Doug Nix
d...@ieee.org<mailto:d...@ieee.org>
+1 (519) 729-5704


On 11-Jul-14, at 14:43, Paul Milton 
mailto:p...@gmcompliance.com>> wrote:


Hi Carl,

Good question.  I've found this to be a very gray area myself as to what
does or does not fall under the MD.  For your device it may not be that
the shutter motors are specifically responsible for its inclusion under
the MD.  It might be that the typical end use equipment these sources are
to be installed in is considered machinery, and the customers buying X-ray
sources are requesting MD of their component manufacturers.

Thanks,

Paul
-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Friday, July 11, 2014 5:40 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] Another Machinery Directive Question

Group members,

I'm working with a company that manufactures an X-ray source sub-assembly.
This product includes the X-Ray source and an electronic
interface controller.  The intended use is for the customer to
incorporate the device into automated laboratory equipment that will be
subject to the machinery directive.

This X-ray source includes a motor-driven shutter which is under computer
control.  The shutter is  enclosed within a housing and is not operator
accessible.

This company has informed me that one of their German competitors claims
that their very similar sub-assembly complies with the MD.

Does the fact that the device includes an internal motor-driven shutter
bring it into the scope of the MD?  That seems to be a stretch to me.

Thanks in advance for your help,

Carl

--

-
--

Re: [PSES] Another Machinery Directive Question

[John Woodgate]

In message , dated Tue, 15 Jul 2014, Carl 
Newton  writes:


However, it appears to me that the fundamental intention of the MD is 
to provide protection against 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.


I think the reason the Directive is 'catch-all' is that it is far too 
difficult to define what might be excluded, other that the product types 
already given in the Directive. In some cases, a product type is 
excluded because it has its own safety standard that includes provisions 
about moving parts that are considered acceptable in the context of the 
MD. Another product type would not be excluded if it didn't have its own 
safety standard, or the standard that it has doesn't address hazards 
from moving parts.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Another Machinery Directive Question

[Carl Newton]

Doug,

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.  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.  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.


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.


Thanks all for your input.  Sorry for the late reply, I've been  
motorcycling in northern Michigan sans laptop for the last four days.


Carl


On Fri, 11 Jul 2014 15:00:48 -0400, Douglas Nix  wrote:


Carl, Paul, List members,

This is not gray at all. The assembly meets the fundamental definition  
of machinery from Article 2 of the Directive:



The following definitions shall apply:
(a) ‘machinery’ means:

— an assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or
animal effort, consisting of linked parts or components,
at least one of which moves, and which are joined
together for a specific application,

— an assembly referred to in the first indent, missing only
the components to connect it on site or to sources of
energy and motion,


Based on this, I would see this assembly as falling into Article 13,  
“Partially Completed Machinery”. Compliance with Annex I is required,  
which will >also cover the electrical safety requirements under Annex I,  
1.5.1 Electricity Supply. This clause requires you to apply the  
electrical safety standards >that you would use if you were applying the  
LVD.


If you want to discuss this more, feel free to contact me offline.

Doug Nix
d...@ieee.org
+1 (519) 729-5704


On 11-Jul-14, at 14:43, Paul Milton  wrote:


Hi Carl,

Good question.  I've found this to be a very gray area myself as to what
does or does not fall under the MD.  For your device it may not be that
the shutter motors are specifically responsible for its inclusion under
the MD.  It might be that the typical end use equipment these sources  
are
to be installed in is considered machinery, and the customers buying  
X-ray

sources are requesting MD of their component manufacturers.

Thanks,

Paul
-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Friday, July 11, 2014 5:40 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Another Machinery Directive Question

Group members,

I'm working with a company that manufactures an X-ray source  
sub-assembly.

This product includes the X-Ray source and an electronic
interface controller.  The intended use is for the customer to
incorporate the device into automated laboratory equipment that will be
subject to the machinery directive.

This X-ray source includes a motor-driven shutter which is under  
computer

control.  The shutter is  enclosed within a housing and is not operator
accessible.

This company has informed me that one of their German competitors claims
that their very similar sub-assembly complies with the MD.

Does the fact that the device includes an internal motor-driven shutter
bring it into the scope of the MD?  That seems to be a stretch to me.

Thanks in advance for your help,

Carl

--

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emc-pstc

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Re: [PSES] Another Machinery Directive Question

[John Woodgate]

In message <53c04201.70...@ieee.org>, dated Fri, 11 Jul 2014, Richard 
Nute  writes:



The definition you quote would mean that all CD and DVD
drives would be subject to the MD?  Fans in computers?


No. Article 1 clause 2 excludes (inter alia):

(k) electrical and electronic products falling within the
following areas, insofar as they are covered by Council
Directive 73/23/EEC of 19 February 1973 on the harmonisation
of the laws of Member States relating to electrical
equipment designed for use within certain voltage limits (3):
— household appliances intended for domestic use,
— audio and video equipment,
— information technology equipment,
— ordinary office machinery,
— low-voltage switchgear and control gear,
— electric motors;

Of course, the reference to 73/23/EEC has to be interpreted as referring 
to 2014/35/EU.


It's much easier now to get the Directives from the Eur-Lex web site 
(until they re-design it again, probably). A web search for the 
directive name should show the relevant Eur-Lex web page. Don't bother 
with any other site, especially if it wants to charge you $$$ for what 
is a free download.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Another Machinery Directive Question

[Charlie Blackham]

Rich

Taken literally, they would be included, but items such as computers are 
explicitly excluded in article 2(k).

The LVD Guidance document also provides guidance on whether a number of product 
fall under LVD vs MD.

Anecdotal evidence gathered from some clients suggests that, when in doubt, a 
number of German companies err towards MD.

Regards
Charlie

From: Richard Nute [mailto:ri...@ieee.org]
Sent: 11 July 2014 20:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Another Machinery Directive Question



Hi Doug:


The definition you quote would mean that all CD and DVD
drives would be subject to the MD?  Fans in computers?


Best regards,
Rich


On 7/11/2014 12:00 PM, Douglas Nix wrote:
Carl, Paul, List members,

This is not gray at all. The assembly meets the fundamental definition of 
machinery from Article 2 of the Directive:

The following definitions shall apply:
(a) 'machinery' means:

- an assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or
animal effort, consisting of linked parts or components,
at least one of which moves, and which are joined
together for a specific application,

- an assembly referred to in the first indent, missing only
the components to connect it on site or to sources of
energy and motion,

Based on this, I would see this assembly as falling into Article 13, "Partially 
Completed Machinery". Compliance with Annex I is required, which will also 
cover the electrical safety requirements under Annex I, 1.5.1 Electricity 
Supply. This clause requires you to apply the electrical safety standards that 
you would use if you were applying the LVD.

If you want to discuss this more, feel free to contact me offline.

Doug Nix
d...@ieee.org<mailto:d...@ieee.org>
+1 (519) 729-5704
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Re: [PSES] Another Machinery Directive Question

[Richard Nute]

Hi Doug:


The definition you quote would mean that all CD and DVD
drives would be subject to the MD?  Fans in computers?


Best regards,
Rich



On 7/11/2014 12:00 PM, Douglas Nix wrote:

Carl, Paul, List members,

This is not gray at all. The assembly meets the fundamental definition 
of machinery from Article 2 of the Directive:



The following definitions shall apply:
(a) ‘machinery’ means:

— an assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or
animal effort, consisting of linked parts or components,
at least one of which moves, and which are joined
together for a specific application,

— an assembly referred to in the first indent, missing only
the components to connect it on site or to sources of
energy and motion,


Based on this, I would see this assembly as falling into Article 13, 
“Partially Completed Machinery”. Compliance with Annex I is required, 
which will also cover the electrical safety requirements under Annex 
I, 1.5.1 Electricity Supply. This clause requires you to apply the 
electrical safety standards that you would use if you were applying 
the LVD.


If you want to discuss this more, feel free to contact me offline.

Doug Nix
d...@ieee.org 
+1 (519) 729-5704


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Re: [PSES] Another Machinery Directive Question

[Douglas Nix]

Carl, Paul, List members,

This is not gray at all. The assembly meets the fundamental definition of 
machinery from Article 2 of the Directive:

> The following definitions shall apply:
> (a) ‘machinery’ means:
> 
> — an assembly, fitted with or intended to be fitted with a
> drive system other than directly applied human or
> animal effort, consisting of linked parts or components,
> at least one of which moves, and which are joined
> together for a specific application,
> 
> — an assembly referred to in the first indent, missing only
> the components to connect it on site or to sources of
> energy and motion,

Based on this, I would see this assembly as falling into Article 13, “Partially 
Completed Machinery”. Compliance with Annex I is required, which will also 
cover the electrical safety requirements under Annex I, 1.5.1 Electricity 
Supply. This clause requires you to apply the electrical safety standards that 
you would use if you were applying the LVD.

If you want to discuss this more, feel free to contact me offline.

Doug Nix
d...@ieee.org
+1 (519) 729-5704


On 11-Jul-14, at 14:43, Paul Milton  wrote:

> Hi Carl,
> 
> Good question.  I've found this to be a very gray area myself as to what
> does or does not fall under the MD.  For your device it may not be that
> the shutter motors are specifically responsible for its inclusion under
> the MD.  It might be that the typical end use equipment these sources are
> to be installed in is considered machinery, and the customers buying X-ray
> sources are requesting MD of their component manufacturers.
> 
> Thanks,
> 
> Paul
> -Original Message-
> From: Carl Newton [mailto:emcl...@gmail.com]
> Sent: Friday, July 11, 2014 5:40 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] Another Machinery Directive Question
> 
> Group members,
> 
> I'm working with a company that manufactures an X-ray source sub-assembly.
> This product includes the X-Ray source and an electronic
> interface controller.  The intended use is for the customer to
> incorporate the device into automated laboratory equipment that will be
> subject to the machinery directive.
> 
> This X-ray source includes a motor-driven shutter which is under computer
> control.  The shutter is  enclosed within a housing and is not operator
> accessible.
> 
> This company has informed me that one of their German competitors claims
> that their very similar sub-assembly complies with the MD.
> 
> Does the fact that the device includes an internal motor-driven shutter
> bring it into the scope of the MD?  That seems to be a stretch to me.
> 
> Thanks in advance for your help,
> 
> Carl
> 
> --
> 
> -
> 
> 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
> 
> 
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
> 
> Website:  http://www.ieee-pses.org/
> Instructions:  http://www.ieee-pses.org/list.html (including how to
> unsubscribe) List rules: http://www.ieee-pses.org/listrules.html
> 
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 
> 
> For policy questions, send mail to:
> Jim Bacher:  
> David Heald: 
> 
> -
> 
> 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 
> 
> 
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at 
> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
> formats), large files, etc.
> 
> Website:  http://www.ieee-pses.org/
> Instructions:  http://www.ieee-pses.org/list.html (including how to 
> unsubscribe)
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Re: [PSES] Another Machinery Directive Question

[Paul Milton]

Hi Carl,

Good question.  I've found this to be a very gray area myself as to what
does or does not fall under the MD.  For your device it may not be that
the shutter motors are specifically responsible for its inclusion under
the MD.  It might be that the typical end use equipment these sources are
to be installed in is considered machinery, and the customers buying X-ray
sources are requesting MD of their component manufacturers.

Thanks,

Paul
-Original Message-
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Friday, July 11, 2014 5:40 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Another Machinery Directive Question

Group members,

I'm working with a company that manufactures an X-ray source sub-assembly.
This product includes the X-Ray source and an electronic
interface controller.  The intended use is for the customer to
incorporate the device into automated laboratory equipment that will be
subject to the machinery directive.

This X-ray source includes a motor-driven shutter which is under computer
control.  The shutter is  enclosed within a housing and is not operator
accessible.

This company has informed me that one of their German competitors claims
that their very similar sub-assembly complies with the MD.

Does the fact that the device includes an internal motor-driven shutter
bring it into the scope of the MD?  That seems to be a stretch to me.

Thanks in advance for your help,

Carl

--

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Re: [PSES] Another Machinery Directive Question

[John Woodgate]

In message , dated Fri, 11 Jul 2014, Carl 
Newton  writes:


This X-ray source includes a motor-driven shutter which is under 
computer  control.  The shutter is  enclosed within a housing and is 
not operator  accessible.


This company has informed me that one of their German competitors 
claims  that their very similar sub-assembly complies with the MD.


Does the fact that the device includes an internal motor-driven shutter 
bring it into the scope of the MD?  That seems to be a stretch to me.


It may be easier overall to assume it does rather than strive against 
it. The Directives are much easier to find now on Eur-Lex (but that may 
be 'improved' negatively at any time):


http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:157:0024:
0086:en:PDF

Mind the word-wrap!

'Whereas' 16:

(16) Although the requirements of this Directive do not
apply to partly completed machinery in their entirety, it
is nevertheless important that the free movement of
such machinery be guaranteed by means of a specific
procedure.

Article 2 a) says, in part:

(a) ‘machinery’ means:
— an assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or
animal effort, consisting of linked parts or components,
at least one of which moves, and which are joined
together for a specific application,

I think that means that your product is 'caught' but your appraisal will 
show that it is very low-hazard. You can self-certify; you do not need 
to go to a Notified Body.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Another Machinery Directive Question

[Anthony Thomson]

Hi Carl,

 


The Machinery Directive includes provisions for maintenance and servicing undertaken by specialised personnel accessing parts regular operators cannot. Perhaps their competitors are claiming compliance on this basis. Seems like a reasonable ‘stretch’ to me.

 

Just my thoughts…
Tony


 

Sent: Friday, July 11, 2014 at 1:40 PM
From: "Carl Newton" 
To: EMC-PSTC@listserv.ieee.org
Subject: [PSES] Another Machinery Directive Question

Group members,

I'm working with a company that manufactures an X-ray source
sub-assembly. This product includes the X-Ray source and an electronic
interface controller. The intended use is for the customer to
incorporate the device into automated laboratory equipment that will be
subject to the machinery directive.

This X-ray source includes a motor-driven shutter which is under computer
control. The shutter is enclosed within a housing and is not operator
accessible.

This company has informed me that one of their German competitors claims
that their very similar sub-assembly complies with the MD.

Does the fact that the device includes an internal motor-driven shutter
bring it into the scope of the MD? That seems to be a stretch to me.

Thanks in advance for your help,

Carl

--

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[PSES] Another Machinery Directive Question

[Carl Newton]

Group members,

I'm working with a company that manufactures an X-ray source  
sub-assembly.  This product includes the X-Ray source and an electronic  
interface controller.  The intended use is for the customer to   
incorporate the device into automated laboratory equipment that will be  
subject to the machinery directive.


This X-ray source includes a motor-driven shutter which is under computer  
control.  The shutter is  enclosed within a housing and is not operator  
accessible.


This company has informed me that one of their German competitors claims  
that their very similar sub-assembly complies with the MD.


Does the fact that the device includes an internal motor-driven shutter  
bring it into the scope of the MD?  That seems to be a stretch to me.


Thanks in advance for your help,

Carl

--

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