Re: [PSES] Machinery Directive silly question?
Gentlemen - Thank you all for your help, as always it has produced balanced answers to my query, coming at it from all sides. I can argue* confidently with colleagues here now. With best grateful regards, Mark * that word should have been discuss but you know how it is... -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Machinery Directive silly question?
Nick, These conversation made me to look for the Machinery Directive (I have never read before). Having no time to read the whole I made a fast search for word 'moving' but I can't find the place the machinery is defined as anything containing moving parts as I understand from conversation here. Being under 'silly question' subject let me ask some questions. Where from it comes that moving part makes equipment the machinery? Do the minimal size or moving distance of that part is defined? In Article 1(k) I don't see telecommunication equipment. Is it excluded as information technology or not ? Do the classical phone with ring has moving parts and is covered by Machinery Directive? Do the cell-phone signalling incoming call by vibration has moving parts and is covered by Machinery Directive ? Do any device which is not excluded by Article 1, but has loudspeaker is covered by Machinery Directive? Do the device using MEMS technology (contains micro moving parts) has moving parts and is covered by Machinery Directive? Best Regards Piotr Galka MicroMade Poland - Original Message - From: Nick Williams nick.willi...@conformance.co.uk To: Peter Merguerian pmerguerian2...@yahoo.com Cc: Mark Hone mh...@wellmandefence.co.uk; EMC-PSTC@LISTSERV.IEEE.ORG Sent: Monday, April 30, 2012 10:24 PM Subject: Re: Machinery Directive silly question? 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. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] Machinery Directive silly question?
Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Machinery Directive silly question?
Not a silly question at all! Assuming none of the Machinery Directive exemptions apply, then it's a machine. The enclosure may make it a safe machine, but it doesn't make it a non-machine. This is quite logical - it could be that the enclosure isn't strong enough, for example, and doing a machinery assessment would consider this. John C -Original Message- From: Mark Hone [mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Machinery Directive silly question?
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 for this type of product. As such, it falls under the Machinery Directive. You may need to do some research to see if your product is within the scope of a product specific standard. However, if it is and if that standard is a harmonized standard under the Low Voltage Directive, the LVD would likely apply. These standards are designed to cover potential mechanical hazards specific to certain product types, but they are recognized as covering product where electrical hazards predominate. This is not just the case for the LVD. There are medical products with moving parts and toys with moving parts and those are each covered under their own directives. If your product has a radio, and it is covered by a standard harmonized under the RTTE Directive, that Directive may be the one that applies. 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. -Original Message- From: Mark Hone [mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike
Re: [PSES] 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 for this type of product. As such, it falls under the Machinery Directive. You may need to do some research to see if your product is within the scope of a product specific standard. However, if it is and if that standard is a harmonized standard under the Low Voltage Directive, the LVD would likely apply. These standards are designed to cover potential mechanical hazards specific to certain product types, but they are recognized as covering product where electrical hazards predominate. This is not just the case for the LVD. There are medical products with moving parts and toys with moving parts and those are each covered under their own directives. If your product has a radio, and it is covered by a standard harmonized under the RTTE Directive, that Directive may be the one that applies. 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. -Original Message- From: Mark Hone [mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message
Re: [PSES] Machinery Directive silly question?
Ted I disagree, for Europe: Directives apply to products. Standards may be used to demonstrate compliance with Directives - but are not mandatory for many products. If you are using Harmonised Standards to give a Presumption of Conformity you should apply a product specific standard or failing that, a standard that covers your (type of) product. Regards Charlie -Original Message- From: Ted Eckert [mailto:ted.eck...@microsoft.com] Sent: 30 April 2012 17:01 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Machinery Directive silly question? 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 for this type of product. As such, it falls under the Machinery Directive. You may need to do some research to see if your product is within the scope of a product specific standard. However, if it is and if that standard is a harmonized standard under the Low Voltage Directive, the LVD would likely apply. These standards are designed to cover potential mechanical hazards specific to certain product types, but they are recognized as covering product where electrical hazards predominate. This is not just the case for the LVD. There are medical products with moving parts and toys with moving parts and those are each covered under their own directives. If your product has a radio, and it is covered by a standard harmonized under the RTTE Directive, that Directive may be the one that applies. 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. -Original Message- From: Mark Hone [mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e
Re: [PSES] Machinery Directive silly question?
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.commailto: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 for this type of product. As such, it falls under the Machinery Directive. You may need to do some research to see if your product is within the scope of a product specific standard. However, if it is and if that standard is a harmonized standard under the Low Voltage Directive, the LVD would likely apply. These standards are designed to cover potential mechanical hazards specific to certain product types, but they are recognized as covering product where electrical hazards predominate. This is not just the case for the LVD. There are medical products with moving parts and toys with moving parts and those are each covered under their own directives. If your product has a radio, and it is covered by a standard harmonized under the RTTE Directive, that Directive may be the one that applies. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.commailto:ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -Original Message- From: Mark Hone [mailto:mh...@wellmandefence.co.uk]mailto:[mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So
Re: [PSES] Machinery Directive silly question?
Let's not overlook Article 3, Specific Directives, which states: Where, for machinery, the hazards referred to in Annex I are wholly or partly covered more specifically by other Community Directives, this Directive shall not apply, or shall cease to apply, to that machinery in respect of such hazards from the date of implementation of those other Directives. From the MD guidance document: - According to Article 3 - Specific Directives, the Machinery Directive does not apply to products listed in Article 1 (1) for the risks covered more specifically by other EU Directives. When these specific Directives cover all the risks associated with the products concerned, such products are entirely excluded from the scope of the Machinery Directive. When the specific Directives only cover certain of the risks associated with the products concerned, such products remain in the scope of the Machinery Directive for the other risks - see §89 to §91: comments on Article 3. Carl On Mon, Apr 30, 2012 at 12:21 PM, Nick Williams nick.willi...@conformance.co.uk wrote: 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 for this type of product. As such, it falls under the Machinery Directive. You may need to do some research to see if your product is within the scope of a product specific standard. However, if it is and if that standard is a harmonized standard under the Low Voltage Directive, the LVD would likely apply. These standards are designed to cover potential mechanical hazards specific to certain product types, but they are recognized as covering product where electrical hazards predominate. This is not just the case for the LVD. There are medical products with moving parts and toys with moving parts and those are each covered under their own directives. If your product has a radio, and it is covered by a standard harmonized under the RTTE Directive, that Directive may be the one that applies. 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. -Original Message- From: Mark Hone [mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W
Re: [PSES] Machinery Directive silly question?
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. Best Regards Peter Sent from my iPhone Peter S. Merguerian pe...@goglobalcompliance.com Go Global Compliance Inc. www.goglobalcompliance.com (408) 931-3303 On Apr 30, 2012, at 6:11 AM, Mark Hone mh...@wellmandefence.co.uk wrote: Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Machinery Directive silly question?
I do know that the scope exclusions of the machinery directive are small, but I disagree, that a directive such as the LVD and its standards cannot address moving part hazards. For example, a fan in a scientific product such as a 230V spectrophotometer, does not make it a machine (except in the current rewrite). Compared to an electrocution hazard a hazard from a moving interior fan is miniscule. If the primary hazard (electrocution) is covered by another directive such as LVD and the applied LVD 'standard's' (e.g. EN 61010-1:2010) comprehensive risk assessment and protection requirements 'very' thoroughly addresses a moving part hazard from a device such as a fan, then I'd say moving parts from this ISM equipment is addressed. The machinery directive used to allow this. The re-write no longer does, but moving part hazards are clearly addressed in this case by a LVD standard. MY opinion only not my company's. Gail Birdsall Hach Compliance Dept. Manager w.970.663.1377 ext 2682 Hach Company | www.hach.com gbird...@hach.com -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Charlie Blackham Sent: Monday, April 30, 2012 10:35 AM To: Ted Eckert; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Machinery Directive silly question? Ted I disagree, for Europe: Directives apply to products. Standards may be used to demonstrate compliance with Directives - but are not mandatory for many products. If you are using Harmonised Standards to give a Presumption of Conformity you should apply a product specific standard or failing that, a standard that covers your (type of) product. Regards Charlie -Original Message- From: Ted Eckert [mailto:ted.eck...@microsoft.com] Sent: 30 April 2012 17:01 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Machinery Directive silly question? 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 for this type of product. As such, it falls under the Machinery Directive. You may need to do some research to see if your product is within the scope of a product specific standard. However, if it is and if that standard is a harmonized standard under the Low Voltage Directive, the LVD would likely apply. These standards are designed to cover potential mechanical hazards specific to certain product types, but they are recognized as covering product where electrical hazards predominate. This is not just the case for the LVD. There are medical products with moving parts and toys with moving parts and those are each covered under their own directives. If your product has a radio, and it is covered by a standard harmonized under the RTTE Directive, that Directive may be the one that applies. 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. -Original Message- From: Mark Hone [mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one
Re: [PSES] Machinery Directive silly question?
for this type of product. As such, it falls under the Machinery Directive. You may need to do some research to see if your product is within the scope of a product specific standard. However, if it is and if that standard is a harmonized standard under the Low Voltage Directive, the LVD would likely apply. These standards are designed to cover potential mechanical hazards specific to certain product types, but they are recognized as covering product where electrical hazards predominate. This is not just the case for the LVD. There are medical products with moving parts and toys with moving parts and those are each covered under their own directives. If your product has a radio, and it is covered by a standard harmonized under the RTTE Directive, that Directive may be the one that applies. 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. -Original Message- From: Mark Hone [mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http
Re: [PSES] Machinery Directive silly question?
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. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Machinery Directive silly question?
. 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 for this type of product. As such, it falls under the Machinery Directive. You may need to do some research to see if your product is within the scope of a product specific standard. However, if it is and if that standard is a harmonized standard under the Low Voltage Directive, the LVD would likely apply. These standards are designed to cover potential mechanical hazards specific to certain product types, but they are recognized as covering product where electrical hazards predominate. This is not just the case for the LVD. There are medical products with moving parts and toys with moving parts and those are each covered under their own directives. If your product has a radio, and it is covered by a standard harmonized under the RTTE Directive, that Directive may be the one that applies. 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. -Original Message- From: Mark Hone [mailto:mh...@wellmandefence.co.uk] Sent: 30 April 2012 14:12 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application. So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: mh...@wellmandefence.co.uk W: www.wellmandefence.co.uk Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. Neither Wellman Defence Limited nor the sender accepts any responsibility for viruses and it is your responsibility to check the email and attachments (if any). If you received this mail in error, please destroy and delete the message from your computer. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David
Re: [PSES] Machinery Directive silly question?
Nick Thanks for the update. I have been away from the machinery world for some time now. Best Regards Sent from my iPhone Peter S. Merguerian pe...@goglobalcompliance.com Go Global Compliance Inc. www.goglobalcompliance.com (408) 931-3303 On Apr 30, 2012, at 1:24 PM, Nick Williams nick.willi...@conformance.co.uk wrote: 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. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
