Re: Servicing and Repairs
Brian, You can provide maintenance and servicing info to your customer. Just be sure your manuals are in order. To write a any kind of manual, a clear definition audience is necessary. In your case, you are considering the training and knowledge of the average laboratory user - about the hazards of performing maintenance on electrical equipment (best to assume none). Qualified as a scientist (even in an electrical field) has no relation to a qualification to perform maintenance tasks. Tasks requiring the ability to understand (and avoid) the hazards present must only be carried out by truly qualified personnel. You recognize this in the construction of your equipment. My main area of difficulty lies in that we rely on the fact that our electronic units are located behind locked doors or screwed panels to achieve our LVD compliance. You should clearly establish at least two categories of personnel who will be interacting with your equipment: 1. Skilled personnel (maintenance staff, specialists). You must define the general skills/knowledge required or the necessary qualification(s) of skilled personnel. You must also specify any specific training/knowledge these skilled personnel will require to be able to recognize and avoid any proprietary hazards in your equipment. 2. Users (operators). Assume: they cannot recognize any hazards (they only know what you've told them in the manual) they will ignore many of your warnings (which is why some designers use special screws for closing off non-user areas) You cannot assume that the user is a skilled person. EN 61010 does not assume this. Your duty as the manufacturer is to CLEARLY separate tasks which can be performed by users from those which must only be performed by skilled/trained personnel. Then, you must explain how to carry out these tasks safely. Regards, Matt PS If you want to talk about the qualifications of scientists - just browse around the internet. Or go directly here: http://www.rli.com/accident/year_lists/pre-1987.html #021: 1977: Scientist blinded by pulsed Nd:YAG laser. A scientist was partially blinded by a reflection from what was called a relatively weak Nd:YAG The exposure in the eye was approximately 6 mJ. However, 6 mJ in a 10 nsec exposure time creates enormous peak power approximately a thousand times greater than the limit allowed into the eye. Although the laser was thought to be relatively weak, in fact it was many orders of magnitude above the accepted safe exposure limit. As a result of the exposure, a vitreous hemorrhage was produced and the person went into shock. Fortunately, the hemorrhage did not produce a foveal lesion, and eventually some vision did return. The accident was due to the fact that although eye protection, was available, it was not being used. This incident could have been avoided if a laser safety program had developed a safety awareness so that people wore protective eyewear. - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
Re: Servicing and repairs
Hi Brian Harlowe, I'm not aware of a EU Legislation that says a company can't service or maintain purchased equipment. Our company is in the same situation as you are: we manufacture laboratory equipment and sell it world wide. We also test our products to EN61010 which is not as strict in these areas as consumer products would be if tested to EN60950. It is assumed that the operator has the proper training to perform the necessary tasks of their job. Many of our customers demand to service and maintain our products themselves, so we have to provide procedures, schematics, part lists, assembly diagrams, etc... This request is so common that we provide all this information with every unit now. The manufacturer of a product is not responsible for the technical level of the operator or the person who maintains or services the instrument at the customer location. The customer has the burden to make sure his people are properly trained for the tasks under their job description. As a manufacturer, you have to provide a safe product and provide instructions for safe operation, maintenance, and service. As for maintenance and service, provide the proper warnings in the documentation and on the product such as Warning: High Voltage. Remove Mains Cord prior to removing panel. Your job is to identify all hazards whether it is the operator or a service person who will be performing the task. You don't have to provide Maintenance and Service information for your customers. You can make a stand and say that these tasks can only be performed by your own people. BUT, you will still have to generate maintenance and service documentation for in-house use. This is a requirement especially if documentation is required to insure the safety of the person performing the maintenance or service. So the question is, what's wrong with providing your customer with Maintenance and Service information on your product? Nothing that I am aware of as long as you do a good job in identifying the hazards. Our company takes a similar view as our customers. We will not purchase a piece of equipment, whether a computer, a lift truck, or digital scope unless we can obtain the schematics, drawings, and service documentation. I think in this industry it is for the most part a requirement of doing business. Brian Kunde - Original Message - From: Brian Harlowe bharl...@vgscientific.com To: emc-p...@ieee.org Sent: Tuesday, December 21, 1999 12:04 PM Subject: Servicing and repairs Traditionally my company has encouraged it's users to carry out a limited amount of servicing and repair on our Electronic units. Under the EU Safety legislation I know this is now a No No. I am a little bit of a lone voice crying in the wilderness as far as our management is concerned. Can any one out there quote me any instances or cases that I can use to drive home the point with our management A happy Christmas to you fellow compliance people and if we survive the Y2K business. Good luck in the new century and may this newsgroup continue to prosper Best Regards Brian Harlowe * opinions expressed here are personal and in no way reflect the position of VG Scientific - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: Servicing and Repairs
Brian Your comments also make interesting reading. Unfortunately I don't have time to comment in detail as I am finishing for XMAS in about 2 hrs! However, in respect of your issue about access of untrained people to potentially dangerous situation should be prevented by appropriate inter-locking, labelling and instructions. If EN61010 does not address the issue in sufficient detail then look at EN60950 Safety of Information Technology Equipment - especially Cl 2.8 Safety Interlocks - as this standard is aimed squarely at equipment for use by untrainned personnel. Additionally, you might want to look at the access and interlock requirements standards called up under the Machinery Directive 98/37/EC and the guidance information put out by authorities such as the UK Health Safety Executive. Regards John Allen. -- From: Brian Harlowe[SMTP:bharl...@vgscientific.com] Sent: 22 December 1999 11:54 To: emc-p...@ieee.org Cc: john.al...@rdel.co.uk Subject:Servicing and Repairs Hi Folks John Allen has opened my can of worms even further with his very useful comments to my e.mail. Obviously the military/defence situation is somewhat different as he states but maybe there is some guidance there. The answers to his comments are his follows:- Our products are large Scientific instruments and the EMC, LVD and Product liability directives apply The standards we have applied are EN 61326-1 and EN 61010-1 Servicing would be to a Minor level although in some instances access is required to units to carry out conditioning procedures The target customer is generally a qualified Scientist but not necessarily from an Electrical/Electronic Background. Manuals to an appropriate level could be produced but are currently only available to our service organisation. My main area of difficulty lies in that we rely on the fact that our electronic units are located behind locked doors or screwed panels to achieve our LVD compliance. It then seems at odds to encourage the user to undo these panels to carry out routine service or repair tasks. Also I am very uncomfortable on the product liability front if someone was hurt or killed because we had suggested he opened panels behind which were dangerous voltages. It has been suggested that we should obtain a declaration that the user has qualified trained staff who are capable of doing this work. Could staff be regarded as qualified if they had not been trained by us in the use of proprietry units? Many of our instruments go to academic users who usually consider themselves competant in every area. I would be interested in the groups comments in this area. Finally as John states very specific instructions would have to be given on reassembling units in order to maintain the units/systems emc signature These are the main reasons I feel these operations should only be carried out by our own Staff. Although I can understand a customers position when he has a piece of capital equipment worth up to stlg750k he is unable to use due to the failure of a simple component Regards Brian Harlowe * opinions expressed here are personal and in no way reflect the position of VG Scientific - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: Servicing and repairs
Hi folks Brian raises an interesting issue - but I would be grateful if he or someone else can identify the EU legislation to which he refers. His comments are particularly to companies like ours who supply mainly to a military market which almost demands to do its own servicing because it locates and uses the equipment in places where normal manufacturer's service cover is unavailable (certainly we don't have a service department in Bosnia or Kosovo!!). However, the customers' requirements' of this nature are stated in contract and typically includes full maintenance and repair training and documentation. I think our situation digresses from the issue raised, but it does have a bearing on my comments, notably that each case should be considered on its merits, Notably, the following appear to be relevant: a) The specific items of EU legislation which apply to the product. b) The type of product and the safety/EMC/telecomms standards to which it has been assessed will be relevant. c) The level of servicing which will/could be required. d) The typical target customer market, as it will affect the level of skill required to correctly maintain/repair the product'. e) The availability to the customer of the maintenance and repair instructions, the depth of detail included, and the warnings/cautions provided on what must - and must not be - done, including any tests to be applied at the end of repair/maintenance. f) The availability and assembly level of the correct routine spares, and of replacement or re-conditioned exchange units. Frankly - whilst I fully sympathise with Brian's viewpoint - I think it is very difficult to make a blanket statement that Mr Customer, thou shalt not service/repair this equipment, particularly in respect of routine maintenance functions, e.g. changing filters, topping up fluids, cleaning, etc. Many of us do these tasks on our own cars - and would object violently to having to go back to the manufacturer (not an agent, according to Brian) to get these tasks done at the cost of a lot of time and money. However, when it get to more complex functions, then the definition of what can/cannot be done is more difficult. Nevertheless, that is what you should do in detail, and you should then clearly specify: - The maintenance documentation (by reference number etc.) in the operating instructions. - Which tasks can/cannot be done, how often, and what the required skill levels are. - All the Warnings and Cautions for the safety of both the repairer and the user, and to prevent the equipment going out of compliance with the safety/emc/etc., standards to which it was designed and manufactured. - Which spares shall be used. - What checks and tests must be performed at the end of the tasks. - What records should be kept of the maintenance and repairs performed (what, when, by whom). If you - the manufacturer - do the above, then I can see no real reason for not permitting professional customers to service their equipment. However, finally, I do accept that if you supply equipment intended for use by the general public - particularly in their own homes - you may have to clearly specify on both the equipment and in the operating instructions that no-user servicing is permitted. You might even have to make access inside the equipment very difficult by sealing the construction or by using special security fixings that cannot be opened with normal handtools. Regards Happy Xmas John Allen Racal Defence Electronics Ltd -- From: Brian Harlowe[SMTP:bharl...@vgscientific.com] Sent: 21 December 1999 17:04 To: emc-p...@ieee.org Subject:Servicing and repairs Traditionally my company has encouraged it's users to carry out a limited amount of servicing and repair on our Electronic units. Under the EU Safety legislation I know this is now a No No. I am a little bit of a lone voice crying in the wilderness as far as our management is concerned. Can any one out there quote me any instances or cases that I can use to drive home the point with our management A happy Christmas to you fellow compliance people and if we survive the Y2K business. Good luck in the new century and may this newsgroup continue to prosper Best Regards Brian Harlowe * opinions expressed here are personal and in no way reflect the position of VG Scientific - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com,
Re: Servicing and repairs
Brian: As a comment I would say that the liability to meet EU approval ends when the product is sold and ownership is transferred. That's the way it happens with consumer goods in Canada, in spite of the fact there is CSA approval required on the original product. Compliments of the Season Ralph Cameron EMC Consultant and Suppression of Consumer Electronic Equipment (After Sale). - Original Message - From: Brian Harlowe bharl...@vgscientific.com To: emc-p...@ieee.org Sent: Tuesday, December 21, 1999 9:04 AM Subject: Servicing and repairs Traditionally my company has encouraged it's users to carry out a limited amount of servicing and repair on our Electronic units. Under the EU Safety legislation I know this is now a No No. I am a little bit of a lone voice crying in the wilderness as far as our management is concerned. Can any one out there quote me any instances or cases that I can use to drive home the point with our management A happy Christmas to you fellow compliance people and if we survive the Y2K business. Good luck in the new century and may this newsgroup continue to prosper Best Regards Brian Harlowe * opinions expressed here are personal and in no way reflect the position of VG Scientific - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
