Many consumer items that fall under the LVD are dealt with under the GPSD are
reported on RAPEX
Many machines don’t “freely move” about the EU and the Machinery Directive is
enforced under national legislation – for example in the UK, the Health and
Safety Executive enforce and prosecute using
I think we have to be realistic. It is very costly to carry out
technical assessments for EMC, which are the only way to detect
violations. Safety is a bit different; violations can often simply be
seen (or at least strongly suspected) by visual inspection, and
laboratory testing may not be
Here are a few more resources that attempt to compare rates of compliance
between SDoC and 3rd party conformity assessment.
http://www.ifia-federation.org/content/wp-content/uploads/IFIA_CIPC_239_2014-2016_Market_survey_report.pdf
https://www.regulations.gov/document?D=OSHA-2008-0032-0099
Most of the end users of our machinery in the EU have or hire their own
consultant to do conformity assessment (MD/LVD) of new purchases as part of the
procurement and acceptance process. That sometimes gets interesting.
-Dave
From: Charlie Blackham [mailto:char...@sulisconsultants.com]
Sent:
John,
I love your example of the Power Supply. In this case, a “standard” says one
thing, but the manufacturer did it a different way. The use of Standards to
show compliance to a Directive is only voluntary. In a Hazard Driven approach
to safety, such a drop-dead requirement in a Standard
Your first paragraph states the problem, and 'technical violation - no
action' is the way it's resolved.
In a DoC, I wouldn't mention 'relevant' at all, particularly now the
legal profession has got its hooks into the European compliance system.
It really does look like a 'loophole creator',
There's more. The recommended format for EU DoCs, at least for
electrical safety and EMC asserts conformity with Directives, not
standards, and says it 'applies' standards, not conforms to them:
/The object of the declaration described above is in conformity with the
relevant Union
Ok, I’ll pile on.
I have never been involved in a market surveillance inspection so I really have
no right to comment, but I am trying to understand what constitutes itself as a
Technical Non-Compliance.
Many of my products get inspected post-sale at our customer sites by
third-party labs or
A typical technical non-compliance is incorrect marking of power supply
data. Different standards have different requirements, and it's easy to
mistakenly state, for example, the supply current when the standard
requires the input power to be stated. Yes, the majority of reported
violations
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