Re: [PSES] Safety standards versus safety engineering

[Nyffenegger, Dave]

What kind of “safety” are you looking to learn and how much detail?  There are 
many free 1hr webinars on the web, YouTube, etc sponsored by various 
manufacturers that cover portions of various standards.  I viewed several from 
Schmersal recently on safety systems.  They are basic but can useful.  Some may 
be geared more towards facilities and others to OEM products.   The EU 
directives are free for the download, the LVD defines the essential health  and 
safety requirements for IT equipment.

-Dave

From: Adam Dixon [mailto:lanterna.viri...@gmail.com]
Sent: Monday, March 16, 2015 8:18 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

For the design engineer who wants to learn more about safety regarding both 
product design (systems using 85-264VAC sources; mostly digital logic but 
including an Ethernet physical layer interface) and production test, but is on 
a very tight budget, are there recommended references?  Soft and/or hardcopy 
are fine.  I have searched the archives using a variety of terms to locate 
recommended references but didn't locate any lists.

I've read the discussions about lowest cost sources for standards.  IEC 
60950-1:2013 is 707 Euros from what I see on the Estonian site.  The UL version 
is $493 for starters.  Purchasing any number of standards certainly is a 
moderate to significant investment for the individual.  I checked out the HBSE 
per Rich's post about how it came to be, but don't have $1050 for the two day 
workshop at this time either.

There look to be a handful of texts on Amazon.  Electrical Safety Handbook, 4th 
edition looks like the most appropriate title -- any benefit with something 
from Amazon or other publishing house/distributor compared to the actual 
standards?

If I've missed pertinent discussions in the archives or if you would consider 
sharing a recommended reading/standards list, I would appreciate any 
guidance/feedback.


Kind regards,
Adam Dixon
adam.di...@ieee.org


On Wed, Mar 4, 2015 at 9:30 PM, Richard Nute 
mailto:ri...@ieee.org>> wrote:
Many years ago, a group of R&D engineers came to
me and said:  "We want to learn about product
safety, but we don't want to read the standards."
The result was the HBSE course.

If the product safety engineer does his job, there
will be no test failures.


Best regards,
Rich


> -Original Message-
> From: Nyffenegger, Dave
> [mailto:dave.nyffeneg...@bhemail.com]
> Sent: Wednesday, March 04, 2015 12:41 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] Estonian Standards MultiUser
> License
>
> Same message I've been communicating here
internally
> as well.  Management certainly supports and
expects to
> have it right the first time but educating on
what needs to
> happen and by who to accomplish that seems to be
a
> recurring theme.
>
> -Dave
>
> -Original Message-
> From: John Woodgate
> [mailto:j...@jmwa.demon.co.uk]
> Sent: Wednesday, March 04, 2015 2:48 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] Estonian Standards MultiUser
> License
>
> In message
>  BLUPR0701MB820.namprd07.prod.out
> look.com>, dated Wed, 4 Mar 2015, Brian Ceresney
> mailto:bceres...@delta-q.com>>
> writes:
>
> > As a matter of  fact, it is very difficult to
get our
> engineers to
> >take an interest in reading and understanding
the
> standards at all,
>
> That is BAD. I forestalled it with my group by
> explaining that while the safety and EMC experts
did the
> tests, THEY were responsible for THEIR designs
> conforming. They were, of course, free to ask
advice and
> assistance from the experts, but when the
designs came to
> be tested, I said that I did not expected them
to fail.
>
> Senior managers found this arrangement seriously
> intellectually challenging. Of course, what it
does is
> eliminate almost all friction between the
designers and
> the 'testers' - they are all in the same boat,
which is as it
> should be.
> --
> OOO - Own Opinions Only. With best wishes. See
> www.jmwa.demon.co.uk When I turn my back on the
> sun, it's to look for a rainbow John Woodgate, J
M
> Woodgate and Associates, Rayleigh, Essex UK
>

-

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 
mailto:emc-p...@ieee.org>>

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Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how

Re: [PSES] Safety standards versus safety engineering

[Dan Roman]

Hi Adam,

 

Don’t know what part of the country/world you are in but the ISPCE 2015 this 
May in Chicago has a Compliance 101 track with some beginner type sessions.  
See http://www.psessymposium.org for details.

 

__
Dan Roman, N.C.E.

Senior Member

IEEE Product Safety Engineering Society

mailto:dan.ro...@ieee.org



 

 

 

From: Adam Dixon [mailto:lanterna.viri...@gmail.com] 
Sent: Monday, March 16, 2015 8:18 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Safety standards versus safety engineering

 

For the design engineer who wants to learn more about safety regarding both 
product design (systems using 85-264VAC sources; mostly digital logic but 
including an Ethernet physical layer interface) and production test, but is on 
a very tight budget, are there recommended references?  Soft and/or hardcopy 
are fine.  I have searched the archives using a variety of terms to locate 
recommended references but didn't locate any lists.

 

I've read the discussions about lowest cost sources for standards.  IEC 
60950-1:2013 is 707 Euros from what I see on the Estonian site.  The UL version 
is $493 for starters.  Purchasing any number of standards certainly is a 
moderate to significant investment for the individual.  I checked out the HBSE 
per Rich's post about how it came to be, but don't have $1050 for the two day 
workshop at this time either.  

 

There look to be a handful of texts on Amazon.  Electrical Safety Handbook, 4th 
edition looks like the most appropriate title -- any benefit with something 
from Amazon or other publishing house/distributor compared to the actual 
standards?

 

If I've missed pertinent discussions in the archives or if you would consider 
sharing a recommended reading/standards list, I would appreciate any 
guidance/feedback.

 

 

Kind regards,

Adam Dixon

adam.di...@ieee.org  

 

 

On Wed, Mar 4, 2015 at 9:30 PM, Richard Nute mailto:ri...@ieee.org> > wrote:

Many years ago, a group of R&D engineers came to
me and said:  "We want to learn about product
safety, but we don't want to read the standards."
The result was the HBSE course.

If the product safety engineer does his job, there
will be no test failures.


Best regards,
Rich


> -Original Message-
> From: Nyffenegger, Dave
> [mailto:dave.nyffeneg...@bhemail.com  ]
> Sent: Wednesday, March 04, 2015 12:41 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG  
> Subject: Re: [PSES] Estonian Standards MultiUser
> License
>
> Same message I've been communicating here
internally
> as well.  Management certainly supports and
expects to
> have it right the first time but educating on
what needs to
> happen and by who to accomplish that seems to be
a
> recurring theme.
>
> -Dave
>
> -Original Message-
> From: John Woodgate
> [mailto:j...@jmwa.demon.co.uk  ]
> Sent: Wednesday, March 04, 2015 2:48 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG  
> Subject: Re: [PSES] Estonian Standards MultiUser
> License
>
> In message
>  BLUPR0701MB820.namprd07.prod.out
> look.com  >, dated Wed, 4 Mar 2015, Brian Ceresney
> mailto:bceres...@delta-q.com> >
> writes:
>
> > As a matter of  fact, it is very difficult to
get our
> engineers to
> >take an interest in reading and understanding
the
> standards at all,
>
> That is BAD. I forestalled it with my group by
> explaining that while the safety and EMC experts
did the
> tests, THEY were responsible for THEIR designs
> conforming. They were, of course, free to ask
advice and
> assistance from the experts, but when the
designs came to
> be tested, I said that I did not expected them
to fail.
>
> Senior managers found this arrangement seriously
> intellectually challenging. Of course, what it
does is
> eliminate almost all friction between the
designers and
> the 'testers' - they are all in the same boat,
which is as it
> should be.
> --
> OOO - Own Opinions Only. With best wishes. See
> www.jmwa.demon.co.uk   When I turn my back on the
> sun, it's to look for a rainbow John Woodgate, J
M
> Woodgate and Associates, Rayleigh, Essex UK
>

-

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 
mailto:emc-p...@ieee.org> >

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List rules: http://www.ieee-pses.org/listrules.html

For help,

Re: [PSES] Nameplate and DoC requirements Machinery Directive

[Nyffenegger, Dave]

The MD Annex II states "The manufacturer of machinery or his authorised 
representative shall keep the original EC declaration of conformity for a 
period of at least 10 years from the last date of manufacture of the 
machinery.".  Don't know if this implies that every unique original with 
signature and/or serial number needs to be kept or only the original that is 
then signed for each unit or batch or whatever a manufacturer decides to do.

Annex VII states the technical file shall include "a copy of the EC declaration 
of conformity;"  Don't know if this implies a copy of every unique original 
with signature and/or serial number needs to be kept or only the original that 
is then signed for each unit or batch or whatever a manufacturer decides to do.

In any case,  we know the technical file must be kept for 10 years as well as 
the DoC, it seems to me filing as many copies of DoCs as one might have with 
the technical file (either electronically or hard copy) would logical.

-Dave

From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: Monday, March 16, 2015 3:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive

Exactly my point. Complicated. And once you put a serial number on the DoC it 
becomes a Static Document with its unique document number and it has to be 
filed somewhere so it can be recovered someday if anyone asks for it.

BTW, google searching this topic, someone wrote a paper back in 2008 what says 
for the Serial Number you can put something like, "Serial Number 3001 onward".  
Does anyone do that? Do you think that will really fly?

Another question. According to the MD 1.7.4.2 , the DoC does not have to be 
contained within the provided instructions but a "document setting out the 
contents of the EC declaration of conformity showing the particulars of the 
machinery, not necessarily including the serial number and the signature".  So 
can we make the official DoC available only upon request?  Yet, Article 5_1(e) 
states, "ensure that it [DoC] accompanies the machinery;". So I guess you 
cannot get around shipping the DoC with the product, right? Thanks.

The Other Brian

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Monday, March 16, 2015 3:08 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive


Good evening



I think that a digital one should be OK because that is how my last (contract) 
employer (a large US-based multinational) has been doing it recently.



But, in outline,:

- only specified people must be able make the insertion

- the chain of authorities from the CEO (etc.) to the person(s) actually 
inserting the digital version must be very explicitly defined, and the latter 
needs to inform the former person of exactly what is being done on each 
occasion the signature is to be used, and, possibly, will need to receive the 
authority before it is actually inserted;

- the electronic process for insertion of the signature must very carefully 
controlled, and the insertion must be permanently logged on the system in 
question.



Don't think that a scanned version would be very good because of possible 
miss-use of the image.



John Allen

W.London, UK

-



-Original Message-
From: Jim Hulbert [mailto:jim.hulb...@pb.com]
Sent: 16 March 2015 18:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive



Does the signature on a DoC need to be "original" or would an digital (or 
scanned) signature be acceptable?



Jim Hulbert



-Original Message-

From: John Woodgate [mailto:j...@jmwa.demon.co.uk]

Sent: Monday, March 16, 2015 1:40 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive



In message

<64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>,

dated Mon, 16 Mar 2015, "Kunde, Brian" 
mailto:brian_ku...@lecotc.com>> writes:



> To do what they want we would have to type up a custom DoC for every

>instrum!

> ent we build with a dedicated document number, have it signed, and

>store copies either paper or electronic file for 10 years. That's crazy.



Since you are making one at a time per customer order. I don't see it's so 
crazy to have a 'dynamic' DoC. After all, you have a different invoice for each 
unit you ship. so why is it difficult to have a

(mildly) different DoC? Of course, you store electronically.

--

OOO - Own Opinions Only. With best wishes. See 
www.jmwa.demon.co.uk When I turn my back on the 
sun, it's to look for a rainbow John Woodgate, J M Woodgate and Associates, 
Rayleigh, Essex UK



-



This message is from t

Re: [PSES] Safety standards versus safety engineering

[Adam Dixon]

For the design engineer who wants to learn more about safety regarding both
product design (systems using 85-264VAC sources; mostly digital logic but
including an Ethernet physical layer interface) and production test, but is
on a very tight budget, are there recommended references?  Soft and/or
hardcopy are fine.  I have searched the archives using a variety of terms
to locate recommended references but didn't locate any lists.

I've read the discussions about lowest cost sources for standards.  IEC
60950-1:2013 is 707 Euros from what I see on the Estonian site.  The UL
version is $493 for starters.  Purchasing any number of standards certainly
is a moderate to significant investment for the individual.  I checked out
the HBSE per Rich's post about how it came to be, but don't have $1050 for
the two day workshop at this time either.

There look to be a handful of texts on Amazon.  Electrical Safety Handbook,
4th edition looks like the most appropriate title -- any benefit with
something from Amazon or other publishing house/distributor compared to the
actual standards?

If I've missed pertinent discussions in the archives or if you would
consider sharing a recommended reading/standards list, I would appreciate
any guidance/feedback.


Kind regards,
Adam Dixon
adam.di...@ieee.org


On Wed, Mar 4, 2015 at 9:30 PM, Richard Nute  wrote:

> Many years ago, a group of R&D engineers came to
> me and said:  "We want to learn about product
> safety, but we don't want to read the standards."
> The result was the HBSE course.
>
> If the product safety engineer does his job, there
> will be no test failures.
>
>
> Best regards,
> Rich
>
>
> > -Original Message-
> > From: Nyffenegger, Dave
> > [mailto:dave.nyffeneg...@bhemail.com]
> > Sent: Wednesday, March 04, 2015 12:41 PM
> > To: EMC-PSTC@LISTSERV.IEEE.ORG
> > Subject: Re: [PSES] Estonian Standards MultiUser
> > License
> >
> > Same message I've been communicating here
> internally
> > as well.  Management certainly supports and
> expects to
> > have it right the first time but educating on
> what needs to
> > happen and by who to accomplish that seems to be
> a
> > recurring theme.
> >
> > -Dave
> >
> > -Original Message-
> > From: John Woodgate
> > [mailto:j...@jmwa.demon.co.uk]
> > Sent: Wednesday, March 04, 2015 2:48 PM
> > To: EMC-PSTC@LISTSERV.IEEE.ORG
> > Subject: Re: [PSES] Estonian Standards MultiUser
> > License
> >
> > In message
> >  > BLUPR0701MB820.namprd07.prod.out
> > look.com>, dated Wed, 4 Mar 2015, Brian Ceresney
> > 
> > writes:
> >
> > > As a matter of  fact, it is very difficult to
> get our
> > engineers to
> > >take an interest in reading and understanding
> the
> > standards at all,
> >
> > That is BAD. I forestalled it with my group by
> > explaining that while the safety and EMC experts
> did the
> > tests, THEY were responsible for THEIR designs
> > conforming. They were, of course, free to ask
> advice and
> > assistance from the experts, but when the
> designs came to
> > be tested, I said that I did not expected them
> to fail.
> >
> > Senior managers found this arrangement seriously
> > intellectually challenging. Of course, what it
> does is
> > eliminate almost all friction between the
> designers and
> > the 'testers' - they are all in the same boat,
> which is as it
> > should be.
> > --
> > OOO - Own Opinions Only. With best wishes. See
> > www.jmwa.demon.co.uk When I turn my back on the
> > sun, it's to look for a rainbow John Woodgate, J
> M
> > Woodgate and Associates, Rayleigh, Essex UK
> >
>
> -
> 
> 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://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 
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All emc-pstc postings are archived and searchable on the web at:
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formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.i

Re: [PSES] Nameplate and DoC requirements Machinery Directive

[Mike Sherman ----- Original Message -----]

Brian -- 

I would think a model number might suffice as "designation of the machinery." 
In my way of thinking, there has to be something that ties the nameplate to the 
DoC; we use the model number, not a functional description---have never run 
into that interpretation before. 

Although the Annex describing the contents of the DoC includes a SN, the 
required markings on the machine in Annex I do *not* require a SN. My approach 
is that if it's not required to be on the machine and therefore is not on the 
machine, it doesn't exist and therefore is not required to be on the DoC. 

I think there's nothing wrong with electronic signatures and generic DoCs. How 
many of us have seen exactly that printed in owner's manuals? 

Mike Sherman 
Graco Inc. 

- Original Message -

From: "Brian Kunde"  
To: "EMC-PSTC"  
Sent: Monday, March 16, 2015 12:18:55 PM 
Subject: [PSES] Nameplate and DoC requirements Machinery Directive 

I'm getting beat up again in France for non-compliances according to the 
machinery Directive on our Nameplate and DoC. I know we have discussed these 
issues in the past but I was wondering if things have changed or become clearer 
over time. We want to do things right but some items are hard for us to 
implement and don't want to have to do unless we really have to. 

Nameplate (label) according to MD 1.7.3 "- designation of the machinery". The 
Test Lab in France wants up to put something like "Carbon and Sulfur 
Determinator" on our nameplate which we just do not have room for. Do others 
struggle with this requirement? What ways have you found to comply with this 
requirement? 

Declaration of Conformity according to MD Annex II, Serial Number. The Test Lab 
insist that the serial number must be on the DoC even though many have 
explained why this is not required. TUV:SUD has also told us that the serial 
number does not have to be on the DoC unless it is needed to determine a CE 
Compliant instrument from a non-CE compliant instrument, but we do not have 
this in writing. All of our products are CD compliant so the serial number has 
no purpose. Does anyone have a document that clearly explains when the serial 
number is and is not required on the DoC? We cannot really use the methods 
described in the Guide, such as using a Range of serial numbers because we 
built one at a time per customer order. The Test Lab wants the DoC to have the 
exact same information as the Nameplate so they say we cannot use "Series" in 
the model number or Product Name. Do others use such shortcuts? To do what they 
want we would have to type up a custom DoC for every instrum! 
ent we build with a dedicated document number, have it signed, and store copies 
either paper or electronic file for 10 years. That's crazy. 

Should I just give in or do I have any ammo in fighting this? Some of the items 
this Test Lab said was "required" six months they are now backing down saying 
things like "it would be nice . . . ". 

Thanks for the help. 

The Other Brian 




 

LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you. 

- 
 
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: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Scott Douglas  
Mike Cantwell  

For policy questions, send mail to: 
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David Heald:  


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Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Nameplate and DoC requirements Machinery Directive

[John Woodgate]

In message 
e/TaogBAA==@blueyonder.co.uk>, dated Mon, 16 Mar 2015, John Allen 
 writes:


I'm sure that the corporate legal eagles of my old US employer (they 
really are a "Big Name" in the technology sector) must have considered 
the issue of the "original" DoC when they decided that the digital 
signature is permissible, so I'm not sure that the "original" version 
does need to be signed "in ink"!


It's a legal or quasi-legal document. A lawyer could readily challenge a 
digital signature but far less easily a pen-and-ink one.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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:
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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.

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For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Nameplate and DoC requirements Machinery Directive

[John Woodgate]

In message 
MTd1qEBAA==@blueyonder.co.uk>, dated Mon, 16 Mar 2015, John Allen 
 writes:


But many companies that make "genuine" (or ?other?!) products also have 
"dubious" employees, or importers in other countries, who are ?less 
scrupulous? about the way that DoCs are produced!


What can a villain do with a fake DoC without a fake product to go with 
it? In any case, you can't stop forgery these days; you no longer need 
any skill. Give me any DoC and I'll give you a copy immediately.


(Almost) Finally, as most companies and government departments now 
routinely accept electronic documentation as part of day-to-day 
commercial transactions, then surely electronic signatures are 
absolutely part of that process ? that?s part of the hi-tech world we 
live in today! That?s why big companies, with the caveats previously 
mentioned now, may take that approach.


I didn't argue against electronic signatures at all; I juts pointed out 
that extreme security isn't necessary because a forged DoC is useless 
without a product to go with it, and it's very far more difficult to get 
the product.

 

OTOH, it?s probably not appropriate for small companies making small 
quantities, or ?on-offs?, of products because it?s more trouble than 
it?s worth!

 
I don't see why. If I were still making products to sell, I would 
certainly use digital documentation as far as possible.


--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] FW: [PSES] Nameplate and DoC requirements Machinery Directive

[Pete Perkins]

Brian et al,

Too bad you are getting beat-up by some local authorities (in
France, altho that's probably not the only place where such folks push their
authority).  Altho Rich Nute recommended getting the references for the
requirements (which is a good idea) it may not come from the complaining
authorities and might not be accepted when coming from the originators of
the requirements.  Unfortunately, there does not seem to be a good court of
last resort to sort this out.  

Perhaps I've been more fortunate than most as an independent
consultant I usually get CE marking projects that are one-off, custom
versions of a machine that are usually adapted for each customer; so it is
unique and, since the company doesn't get too many foreign orders, the
entire process is captured as a project and the final step is the signed
MDoC (a unique document for a unique machine).  

It seems that these complainers believe that machines are all unique
units and the detailed rules aren't a burden under those circumstances.  I
know that is not always the case.  

Perhaps there is some way to reposition the product so that is isn't
a machine but rather some other sort of product that is better handled
outside the MD?  I've dealt with some pretty complex process control
equipment that has never been claimed to be a machine.  You are probably
familiar with other situations that might fall into such a category.  

Not having had such a reaction (knock-on-wood) I don't have 1st hand
experience.  

Good luck in sorting it all out.  

:>) br, Pete
 
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe  97281-3427
 
503/452-1201 fone/fax
p.perk...@ieee.org
 
-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Monday, March 16, 2015 10:19 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Nameplate and DoC requirements Machinery Directive

I'm getting beat up again in France for non-compliances according to the
machinery Directive on our Nameplate and DoC. I know we have discussed these
issues in the past but I was wondering if things have changed or become
clearer over time. We want to do things right but some items are hard for us
to implement and don't want to have to do unless we really have to.

Nameplate (label) according to MD 1.7.3 "- designation of the machinery".
The Test Lab in France wants up to put something like "Carbon and Sulfur
Determinator" on our nameplate which we just do not have room for. Do others
struggle with this requirement? What ways have you found to comply with this
requirement?

Declaration of Conformity according to MD Annex II, Serial Number.  The Test
Lab insist that the serial number must be on the DoC even though many have
explained why this is not required. TUV:SUD has also told us that the serial
number does not have to be on the DoC unless it is needed to determine a CE
Compliant instrument from a non-CE compliant instrument, but we do not have
this in writing. All of our products are CD compliant so the serial number
has no purpose. Does anyone have a document that clearly explains when the
serial number is and is not required on the DoC?  We cannot really use the
methods described in the Guide, such as using a Range of serial numbers
because we built one at a time per customer order.  The Test Lab wants the
DoC to have the exact same information as the Nameplate so they say we
cannot use "Series" in the model number or Product Name.  Do others use such
shortcuts?  To do what they want we would have to type up a custom DoC for
every instrum!
 ent we build with a dedicated document number, have it signed, and store
copies either paper or electronic file for 10 years. That's crazy.

Should I just give in or do I have any ammo in fighting this?   Some of the
items this Test Lab said was "required" six months they are now backing down
saying things like "it would be nice . . . ".

Thanks for the help.

The Other Brian






LECO Corporation Notice: This communication may contain confidential
information intended for the named recipient(s) only. If you received this
by mistake, please destroy it and notify us of the error. Thank you.

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Re: [PSES] Nameplate and DoC requirements Machinery Directive

[John Allen]

John

 

But many companies that make "genuine" (or "other"!) products also have
"dubious" employees, or importers in other countries, who are "less
scrupulous" about the way that DoCs are produced!

 

(Almost) Finally, as most companies and government departments now routinely
accept electronic documentation as part of day-to-day commercial
transactions, then surely electronic signatures are absolutely part of that
process - that's part of the hi-tech world we live in today! That's why big
companies, with the caveats previously mentioned now, may take that
approach.

 

OTOH, it's probably not appropriate for small companies making small
quantities, or "on-offs", of products because it's more trouble than it's
worth!

 

John Allen

W. London, UK

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 16 March 2015 21:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive

 

In message

<
 64D32EE8B9CBDD44963ACB076A5F6ABB026D3825@Mailbox-Tech.lecotech.local>,

dated Mon, 16 Mar 2015, "Kunde, Brian" < 
brian_ku...@lecotc.com> writes:

 

>Exactly my point. Complicated. And once you put a serial number on the 

>DoC it becomes a Static Document with its unique document number and it 

>has to be filed somewhere so it can be recovered someday if anyone asks 

>for it.

 

I don't agree that the procedure outlined by John Allen is realistic. 

Normally, a company has one person who signs DoCs (well, maybe two). So for
'shipping copies' you just have a Word (or other fine word

processor) template with the signature and add the serial number
individually. I can't see that there is much scope for abuse; a fake DoC
needs a fake product to go with it and I doubt many companies make fake
products along with real ones.

 

It is hardly an onerous task for the CTO or whoever to sign the

*original* DoCs. If it is, buy him/her a facsimile writer.

 

There is, of course, no way to stop another company making fake products;
compared with the effort that takes, that of forging a DoC is quite trivial.

--

OOO - Own Opinions Only. With best wishes. See
 www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

 

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Re: [PSES] Nameplate and DoC requirements Machinery Directive

[John Allen]

John

I'm sure that the corporate legal eagles of my old US employer (they really
are a "Big Name" in the technology sector) must have considered the issue of
the "original" DoC when they decided that the digital signature is
permissible, so I'm not sure that the "original" version does need to be
signed "in ink"!

John Allen
W.London, UK

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 16 March 2015 20:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive

In message 
<7B9D892F88F070469771832D78B3086E284AA5F6@013-BR1MPN1-011.MGDPBI.global.p
vt>, dated Mon, 16 Mar 2015, Jim Hulbert  writes:

>Does the signature on a DoC need to be "original" or would an digital 
>(or scanned) signature be acceptable?

On the DoC in the Technical File, it should be original, but copies can 
be digital or scanned. Only the original is legally valid: the copies 
are informative.
-- 
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Nameplate and DoC requirements Machinery Directive

[John Woodgate]

In message 
<64D32EE8B9CBDD44963ACB076A5F6ABB026D3825@Mailbox-Tech.lecotech.local>, 
dated Mon, 16 Mar 2015, "Kunde, Brian"  writes:


Exactly my point. Complicated. And once you put a serial number on the 
DoC it becomes a Static Document with its unique document number and it 
has to be filed somewhere so it can be recovered someday if anyone asks 
for it.


I don't agree that the procedure outlined by John Allen is realistic. 
Normally, a company has one person who signs DoCs (well, maybe two). So 
for 'shipping copies' you just have a Word (or other fine word 
processor) template with the signature and add the serial number 
individually. I can't see that there is much scope for abuse; a fake DoC 
needs a fake product to go with it and I doubt many companies make fake 
products along with real ones.


It is hardly an onerous task for the CTO or whoever to sign the 
*original* DoCs. If it is, buy him/her a facsimile writer.


There is, of course, no way to stop another company making fake 
products; compared with the effort that takes, that of forging a DoC is 
quite trivial.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU

[John Woodgate]

In message 
<64D32EE8B9CBDD44963ACB076A5F6ABB026D385D@Mailbox-Tech.lecotech.local>, 
dated Mon, 16 Mar 2015, "Kunde, Brian"  writes:


“4. Object of the declaration (identification of apparatus allowing 
traceability; it may include a colour image of sufficient clarity where 
necessary for the identification of the apparatus):”


 

Does this mean we have to include a color picture of the product on the 
DoC? 


No, it quite clearly says 'may', which gives permission.


What would be an acceptable alternative?


For most products, the other data the Directive requires is sufficient, 
but for some products it might be inconvenient or impossible to add all 
the marking, so a picture would make things clear.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Nameplate and DoC requirements Machinery Directive

[John Woodgate]

In message 
<7B9D892F88F070469771832D78B3086E284AA5F6@013-BR1MPN1-011.MGDPBI.global.p

vt>, dated Mon, 16 Mar 2015, Jim Hulbert  writes:

Does the signature on a DoC need to be "original" or would an digital 
(or scanned) signature be acceptable?


On the DoC in the Technical File, it should be original, but copies can 
be digital or scanned. Only the original is legally valid: the copies 
are informative.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU

[Charlie Blackham]

Brian

I’d wait until the guidance comes out as no one will be signing DoCs until 20 
April 2016

Regards
Charlie

From: Kunde, Brian [mailto:brian_ku...@lecotc.com]
Sent: 16 March 2015 19:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low 
Voltage Directive 2014/35/EU

I’m sorry to be bringing this topic back, but looking at the DoC requirements 
for the new EMC Directive, what does this mean?

“4. Object of the declaration (identification of apparatus allowing 
traceability; it may include a colour image of sufficient clarity where 
necessary for the identification of the apparatus):”

Does this mean we have to include a color picture of the product on the DoC?  
What would be an acceptable alternative?

Thanks,
The Other Brian


From: Ron Pickard (RPQ) [mailto:rpick...@rpqconsulting.com]
Sent: Tuesday, March 03, 2015 1:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low 
Voltage Directive 2014/35/EU


As an outsider to the EU process, all I can do is hope it all gets completed on 
time. But, I am skeptical that all the member states and ETSI can get that all 
done by the 2016 dates. I think the EU put the cart before the horse on this 
one, metaphorically speaking.



I look forward to you reply.



Best regards,

Ron Pickard

Sent from my smartphone



-- Original message--

From: John Woodgate

Date: Tue, Mar 3, 2015 11:19 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG;

Subject:Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low 
Voltage Directive 2014/35/EU



In message 
<000f424e.66f2bca822817...@rpqconsulting.com>,
 dated Tue, 3 Mar 2015, "Ron Pickard (RPQ)"  writes:>For your question, I guess 
we'll have to wait and see if the member >states and ETSI meet the 2016 dates 
in those directives.I meant a bit more than that. What chance is there of all 
the work being done in time? 1 picochance?-- OOO - Own Opinions Only. With best 
wishes. See www.jmwa.demon.co.ukWhen I turn my 
back on the sun, it's to look for a rainbowJohn Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex 
UK-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.htmlAttachments 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: 
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administrators:Scott Douglas Mike Cantwell For policy questions, send mail 
to:Jim Bacher:  David Heald:
-


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LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you.
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unsubscribe)

Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU

[Kunde, Brian]

I’m sorry to be bringing this topic back, but looking at the DoC requirements 
for the new EMC Directive, what does this mean?

“4. Object of the declaration (identification of apparatus allowing 
traceability; it may include a colour image of sufficient clarity where 
necessary for the identification of the apparatus):”

Does this mean we have to include a color picture of the product on the DoC?  
What would be an acceptable alternative?

Thanks,
The Other Brian


From: Ron Pickard (RPQ) [mailto:rpick...@rpqconsulting.com]
Sent: Tuesday, March 03, 2015 1:32 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low 
Voltage Directive 2014/35/EU


As an outsider to the EU process, all I can do is hope it all gets completed on 
time. But, I am skeptical that all the member states and ETSI can get that all 
done by the 2016 dates. I think the EU put the cart before the horse on this 
one, metaphorically speaking.



I look forward to you reply.



Best regards,

Ron Pickard

Sent from my smartphone



-- Original message--

From: John Woodgate

Date: Tue, Mar 3, 2015 11:19 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG;

Subject:Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low 
Voltage Directive 2014/35/EU



In message 
<000f424e.66f2bca822817...@rpqconsulting.com>,
 dated Tue, 3 Mar 2015, "Ron Pickard (RPQ)"  writes:>For your question, I guess 
we'll have to wait and see if the member >states and ETSI meet the 2016 dates 
in those directives.I meant a bit more than that. What chance is there of all 
the work being done in time? 1 picochance?-- OOO - Own Opinions Only. With best 
wishes. See www.jmwa.demon.co.ukWhen I turn my 
back on the sun, it's to look for a rainbowJohn Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex 
UK-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.htmlAttachments 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.htmlFor help, send mail to the list 
administrators:Scott Douglas Mike Cantwell For policy questions, send mail 
to:Jim Bacher:  David Heald:
-


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Re: [PSES] Nameplate and DoC requirements Machinery Directive

[Kunde, Brian]

Exactly my point. Complicated. And once you put a serial number on the DoC it 
becomes a Static Document with its unique document number and it has to be 
filed somewhere so it can be recovered someday if anyone asks for it.

BTW, google searching this topic, someone wrote a paper back in 2008 what says 
for the Serial Number you can put something like, "Serial Number 3001 onward".  
Does anyone do that? Do you think that will really fly?

Another question. According to the MD 1.7.4.2 , the DoC does not have to be 
contained within the provided instructions but a "document setting out the 
contents of the EC declaration of conformity showing the particulars of the 
machinery, not necessarily including the serial number and the signature".  So 
can we make the official DoC available only upon request?  Yet, Article 5_1(e) 
states, "ensure that it [DoC] accompanies the machinery;". So I guess you 
cannot get around shipping the DoC with the product, right? Thanks.

The Other Brian

From: John Allen [mailto:john_e_al...@blueyonder.co.uk]
Sent: Monday, March 16, 2015 3:08 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive


Good evening



I think that a digital one should be OK because that is how my last (contract) 
employer (a large US-based multinational) has been doing it recently.



But, in outline,:

- only specified people must be able make the insertion

- the chain of authorities from the CEO (etc.) to the person(s) actually 
inserting the digital version must be very explicitly defined, and the latter 
needs to inform the former person of exactly what is being done on each 
occasion the signature is to be used, and, possibly, will need to receive the 
authority before it is actually inserted;

- the electronic process for insertion of the signature must very carefully 
controlled, and the insertion must be permanently logged on the system in 
question.



Don't think that a scanned version would be very good because of possible 
miss-use of the image.



John Allen

W.London, UK

-



-Original Message-
From: Jim Hulbert [mailto:jim.hulb...@pb.com]
Sent: 16 March 2015 18:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive



Does the signature on a DoC need to be "original" or would an digital (or 
scanned) signature be acceptable?



Jim Hulbert



-Original Message-

From: John Woodgate [mailto:j...@jmwa.demon.co.uk]

Sent: Monday, March 16, 2015 1:40 PM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive



In message

<64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>,

dated Mon, 16 Mar 2015, "Kunde, Brian" 
mailto:brian_ku...@lecotc.com>> writes:



> To do what they want we would have to type up a custom DoC for every

>instrum!

> ent we build with a dedicated document number, have it signed, and

>store copies either paper or electronic file for 10 years. That's crazy.



Since you are making one at a time per customer order. I don't see it's so 
crazy to have a 'dynamic' DoC. After all, you have a different invoice for each 
unit you ship. so why is it difficult to have a

(mildly) different DoC? Of course, you store electronically.

--

OOO - Own Opinions Only. With best wishes. See 
www.jmwa.demon.co.uk When I turn my back on the 
sun, it's to look for a rainbow John Woodgate, J M Woodgate and Associates, 
Rayleigh, Essex UK



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Re: [PSES] Nameplate and DoC requirements Machinery Directive

[John Allen]

Good evening

 

I think that a digital one should be OK because that is how my last
(contract) employer (a large US-based multinational) has been doing it
recently.

 

But, in outline,:

- only specified people must be able make the insertion

- the chain of authorities from the CEO (etc.) to the person(s) actually
inserting the digital version must be very explicitly defined, and the
latter needs to inform the former person of exactly what is being done on
each occasion the signature is to be used, and, possibly, will need to
receive the authority before it is actually inserted;

- the electronic process for insertion of the signature must very carefully
controlled, and the insertion must be permanently logged on the system in
question.

 

Don't think that a scanned version would be very good because of possible
miss-use of the image.

 

John Allen

W.London, UK

-

 

-Original Message-
From: Jim Hulbert [mailto:jim.hulb...@pb.com] 
Sent: 16 March 2015 18:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive

 

Does the signature on a DoC need to be "original" or would an digital (or
scanned) signature be acceptable?

 

Jim Hulbert

 

-Original Message-

From: John Woodgate [ 
mailto:j...@jmwa.demon.co.uk]

Sent: Monday, March 16, 2015 1:40 PM

To:   EMC-PSTC@LISTSERV.IEEE.ORG

Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive

 

In message

<
 64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>,

dated Mon, 16 Mar 2015, "Kunde, Brian" < 
brian_ku...@lecotc.com> writes:

 

> To do what they want we would have to type up a custom DoC for every 

>instrum!

> ent we build with a dedicated document number, have it signed, and 

>store copies either paper or electronic file for 10 years. That's crazy.

 

Since you are making one at a time per customer order. I don't see it's so
crazy to have a 'dynamic' DoC. After all, you have a different invoice for
each unit you ship. so why is it difficult to have a

(mildly) different DoC? Of course, you store electronically.

--

OOO - Own Opinions Only. With best wishes. See
 www.jmwa.demon.co.uk When I turn my back on
the sun, it's to look for a rainbow John Woodgate, J M Woodgate and
Associates, Rayleigh, Essex UK

 

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 emc-p...@ieee.org>

 

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Re: [PSES] Nameplate and DoC requirements Machinery Directive

[Jim Hulbert]

Does the signature on a DoC need to be "original" or would an digital (or 
scanned) signature be acceptable?

Jim Hulbert

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Monday, March 16, 2015 1:40 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive

In message
<64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>,
dated Mon, 16 Mar 2015, "Kunde, Brian"  writes:

> To do what they want we would have to type up a custom DoC for every
>instrum!
> ent we build with a dedicated document number, have it signed, and
>store copies either paper or electronic file for 10 years. That's crazy.

Since you are making one at a time per customer order. I don't see it's so 
crazy to have a 'dynamic' DoC. After all, you have a different invoice for each 
unit you ship. so why is it difficult to have a
(mildly) different DoC? Of course, you store electronically.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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Re: [PSES] Nameplate and DoC requirements Machinery Directive

[John Woodgate]

In message 
<64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>, 
dated Mon, 16 Mar 2015, "Kunde, Brian"  writes:


To do what they want we would have to type up a custom DoC for every 
instrum!
ent we build with a dedicated document number, have it signed, and 
store copies either paper or electronic file for 10 years. That's crazy.


Since you are making one at a time per customer order. I don't see it's 
so crazy to have a 'dynamic' DoC. After all, you have a different 
invoice for each unit you ship. so why is it difficult to have a 
(mildly) different DoC? Of course, you store electronically.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Nameplate and DoC requirements Machinery Directive

[Richard Nute]

Hi Brian:


Ask the test lab to provide you with the documents
that specify what they want.  After all, you want
to do what is right!


Good luck,
Rich

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Re: [PSES] USB Mains Outlet sockets

[Charlie Blackham]

Dave

You can, but the (electric wood) saw requires an NB opinion under the Machinery 
Directive and the weighing instrument may require one under the Measuring 
Instruments directive - neither require one for the LVD.

Regards
Charlie


-Original Message-
From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: 16 March 2015 16:36
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

But there are some products that require a certification? from an NB like saws 
and weighing instruments in addition to the manufacturer claiming compliance.

-Dave

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Monday, March 16, 2015 10:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

In message <9d43ffa0de684727ac4a5d218504c...@sehste15d1be4.hs20.net>,
dated Mon, 16 Mar 2015, Charlie Blackham 
writes:

>I don't think they can - Notified Bodies don't appear work like that 
>under the LVD
>
>Annex IV is the only route to compliance and that is solely the 
>responsibility of the manufacturer - Notified Bodies are only involved 
>in the event of a challenge or prohibition under Articles 8 or 9.

There is nothing that *prohibits* a manufacturer consulting a notified body. 
But the NB can only advise; the claim of compliance must come from the 
manufacturer alone.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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[PSES] Nameplate and DoC requirements Machinery Directive

[Kunde, Brian]

I'm getting beat up again in France for non-compliances according to the 
machinery Directive on our Nameplate and DoC. I know we have discussed these 
issues in the past but I was wondering if things have changed or become clearer 
over time. We want to do things right but some items are hard for us to 
implement and don't want to have to do unless we really have to.

Nameplate (label) according to MD 1.7.3 "- designation of the machinery".  The 
Test Lab in France wants up to put something like "Carbon and Sulfur 
Determinator" on our nameplate which we just do not have room for. Do others 
struggle with this requirement? What ways have you found to comply with this 
requirement?

Declaration of Conformity according to MD Annex II, Serial Number.  The Test 
Lab insist that the serial number must be on the DoC even though many have 
explained why this is not required. TUV:SUD has also told us that the serial 
number does not have to be on the DoC unless it is needed to determine a CE 
Compliant instrument from a non-CE compliant instrument, but we do not have 
this in writing. All of our products are CD compliant so the serial number has 
no purpose. Does anyone have a document that clearly explains when the serial 
number is and is not required on the DoC?  We cannot really use the methods 
described in the Guide, such as using a Range of serial numbers because we 
built one at a time per customer order.  The Test Lab wants the DoC to have the 
exact same information as the Nameplate so they say we cannot use "Series" in 
the model number or Product Name.  Do others use such shortcuts?  To do what 
they want we would have to type up a custom DoC for every instrum!
 ent we build with a dedicated document number, have it signed, and store 
copies either paper or electronic file for 10 years. That's crazy.

Should I just give in or do I have any ammo in fighting this?   Some of the 
items this Test Lab said was "required" six months they are now backing down 
saying things like "it would be nice . . . ".

Thanks for the help.

The Other Brian






LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you.

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Re: [PSES] USB Mains Outlet sockets

[John Woodgate]

In message 
utlook.com>, dated Mon, 16 Mar 2015, "Nyffenegger, Dave" 
 writes:


But there are some products that require a certification? from an NB 
like saws and weighing instruments in addition to the manufacturer 
claiming compliance.


I don't think anyone denied that. The claim is still the sole 
responsibility of the manufacturer.


Article 8 2) of the LVD says that if challenged, a manufacturer can 
submit a report from an NB. Clearly, the manufacturer can, and prudently 
should if no standard is applicable, obtain such a report before any 
challenge is made.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] USB Mains Outlet sockets

[Nyffenegger, Dave]

But there are some products that require a certification? from an NB like saws 
and weighing instruments in addition to the manufacturer claiming compliance.

-Dave

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Monday, March 16, 2015 10:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

In message <9d43ffa0de684727ac4a5d218504c...@sehste15d1be4.hs20.net>,
dated Mon, 16 Mar 2015, Charlie Blackham 
writes:

>I don't think they can - Notified Bodies don't appear work like that 
>under the LVD
>
>Annex IV is the only route to compliance and that is solely the 
>responsibility of the manufacturer - Notified Bodies are only involved 
>in the event of a challenge or prohibition under Articles 8 or 9.

There is nothing that *prohibits* a manufacturer consulting a notified body. 
But the NB can only advise; the claim of compliance must come from the 
manufacturer alone.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] USB Mains Outlet sockets

[John Woodgate]

In message <6ddfdc3ce0c04e769788eda36ea90...@sehste15d1be4.hs20.net>, 
dated Mon, 16 Mar 2015, Charlie Blackham  
writes:


Indeed - but then they're not acting as a Notified Body, and they're 
not going to get an "opinion" - so what are they getting for their 
money?


I don't understand. Any consultant can give a report on whether a 
product is safe or not. But the manufacturer won't necessarily have a 
trusted consultant already, so going to an NB is a way to get one. The 
NB, of course, is paid for its report and any advice given.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] USB Mains Outlet sockets

[Charlie Blackham]

Indeed - but then they're not acting as a Notified Body, and they're not going 
to get an "opinion" - so what are they getting for their money?


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 16 March 2015 14:33
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

In message <9d43ffa0de684727ac4a5d218504c...@sehste15d1be4.hs20.net>,
dated Mon, 16 Mar 2015, Charlie Blackham 
writes:

>I don't think they can - Notified Bodies don't appear work like that 
>under the LVD
>
>Annex IV is the only route to compliance and that is solely the 
>responsibility of the manufacturer - Notified Bodies are only involved 
>in the event of a challenge or prohibition under Articles 8 or 9.

There is nothing that *prohibits* a manufacturer consulting a notified body. 
But the NB can only advise; the claim of compliance must come from the 
manufacturer alone.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] USB Mains Outlet sockets

[John Woodgate]

In message <9d43ffa0de684727ac4a5d218504c...@sehste15d1be4.hs20.net>, 
dated Mon, 16 Mar 2015, Charlie Blackham  
writes:


I don't think they can - Notified Bodies don't appear work like that 
under the LVD


Annex IV is the only route to compliance and that is solely the 
responsibility of the manufacturer - Notified Bodies are only involved 
in the event of a challenge or prohibition under Articles 8 or 9.


There is nothing that *prohibits* a manufacturer consulting a notified 
body. But the NB can only advise; the claim of compliance must come from 
the manufacturer alone.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] USB Mains Outlet sockets

[John Woodgate]

In message 
<810f9e795c77564592f2355a6b5c3fa21a813...@g4w3218.americas.hpqcorp.net>, 
dated Mon, 16 Mar 2015, "Allen, Chris"  writes:


I have recently bought an outlet socket / USB charger module from Ikea 
which connects in to their under cupboard lighting system.


Tow things:

1. Sweden is very 'hot' on electrical safety, so what claims of 
compliance, if any, are made for the product?


2. The lighting system may conform to a standard, which may or may not 
admit of 'auxiliary' devices being connected.


When my iPhone 5 is plugged in to it the touch screen is very erratic 
and "jumps" when I use it.


Probably due to capacitance to the high-frequency 'fog' on the mains. I 
wouldn't use it while it's charging, just in case the battery 
deflagrates.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] USB Mains Outlet sockets

[Charlie Blackham]

> But in the absence of any applicable standard, a manufacturer would be 
> well-advised to get a notified body opinion.

I don't think they can - Notified Bodies don't appear work like that under the 
LVD

Annex IV is the only route to compliance and that is solely the responsibility 
of the manufacturer - Notified Bodies are only involved in the event of a 
challenge or prohibition under Articles 8 or 9.

Regards
Charlie


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 16 March 2015 13:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

In message
<04cab9802ba27a409548dd47de1da7ef8d8c128...@slomailprd01.polycom.com>,
dated Mon, 16 Mar 2015, "Pearson, John" 
writes:

>Where does that leave a potential supplier?

In an unchanged position. The exclusion from the SI doesn't make the product 
illegal.

In Europe, compliance with the LVD (and EMCD) is by self-certification. 
But in the absence of any applicable standard, a manufacturer would be 
well-advised to get a notified body opinion.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] USB Mains Outlet sockets

[Allen, Chris]

I have recently bought an outlet socket / USB charger module from Ikea which 
connects in to their under cupboard lighting system.

When my iPhone 5 is plugged in to it the touch screen is very erratic and 
"jumps" when I use it. 

Chris.

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 14 March 2015 11:23
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

In message
, dated Sat, 14 Mar 2015, John Allen 
 writes:

>Leaving aside the LVD "in/out" issues, since a small USB charger is 
>almost inherently not "EMC benign", then surely it must be subject to 
>the EMCD - unless you firmly play the "installations" card - ?

I agree up to a point. As you say, once you invoke 'fixed installation' 
you raise the subject of EMC assessing the whole house.
>
>If it IS subject to the EMCD, then the "essential requirements" of that 
>apply - regardless of whether there are directly-applicable harmonised 
>Standards - , CE marking is required and the overall CE marking 
>requirements apply, and that would then throw the RoHS II requirements 
>into play as well.

The CE mark can't be applied because it's prohibited on mains plugs and 
sockets. It's an unresolvable paradox, due to the absence of relevant standards.
>
>So, I think the "installations" issue could probably be the critical 
>one.

See above; it just raises further unresolvable issues.

What we should be pressing for is an applicable standard, not trying to hammer 
existing standards into applicability.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] USB Mains Outlet sockets

[John Woodgate]

In message 
<04cab9802ba27a409548dd47de1da7ef8d8c128...@slomailprd01.polycom.com>, 
dated Mon, 16 Mar 2015, "Pearson, John"  
writes:



Where does that leave a potential supplier?


In an unchanged position. The exclusion from the SI doesn't make the 
product illegal.


In Europe, compliance with the LVD (and EMCD) is by self-certification. 
But in the absence of any applicable standard, a manufacturer would be 
well-advised to get a notified body opinion.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] USB Mains Outlet sockets

[Pearson, John]

Hello 

Been doing some more reading

SI 1994 No 1768 is the Plug and Socket safety regs for the UK.  In this it 
appears that this product falls outside the scope of this regulation. 

It seems to be only classifiable under the SI as a Part 1 product, quote " any 
plug, socket or adaptor ordinarily intended for domestic use at a voltage of 
not less than 200 volts, to any fuse link which is suitable for use in any such 
plug being a standard plug and to any cartridge fuse link which is suitable for 
use in any other plugs and adaptors but does not apply to any electrical device 
specified in Schedule 1 to these Regulations. ".  

However Schedule 1 specifically excludes "Any plug, socket or adaptor which 
incorporates any other electrical device (other than a F fuse link, switch or 
indicator light)".  As the product includes a PSU it appears not to be covered 
by this legislation.  

Where does that leave a potential supplier?
 
John

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 14 March 2015 18:21
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] USB Mains Outlet sockets

In message <004401d05e7c$d87423b0$895c6b10$@btinternet.com>, dated Sat,
14 Mar 2015, Richard Marshall 
writes:

>All I can add is that it appears to be unclear whether a roof-top 
>photovoltaic array on domestic premises is a "fixed installation"
>within the EC EMC Directive definition. The UK authorities say it is 
>not - presumably for the common-sense view of John Allen that it is 
>unreasonable to make a homeowner a "Responsible Person".

That ruling may pre-date the BS7671 amendment, which makes the classification 
as a fixed installation very much less onerous than it might have been 
previously.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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