Hi Richard,

I disagree with you regarding your claim about these two directives only
being applicable to consumer products.

The General Product Safety Directive (GPSD) is focused towards product
where no other directives apply. The GPSD states"
                                                                            
 Article 1                                                                  
 1. The purpose of the provisions of this Directive is to ensure that       
 products placed on the market are safe.                                    
 2. The provisions of this Directive shall apply in so far as there are no  
 specific provisions in rules of Community law governing the safety of the  
 products concerned.                                                        
                                                                            
 It is agreed that as time moves on, there will be more product family      
 specific directives put into force effectively limiting the scope of the   
 GPSD.                                                                      
                                                                            
                                                                            

The Liability Directive (LD) title is focused to "... concerning liability
for defective products". And, Article 1 of the LD states "The producer
shall be liable for damage caused by a defect in his product." This
directive, in fact, deals with the liabilities of defective products
regardless of market focus.
                                                                            
                                                                            
 As can be plainly seen, neither directive is focused toward consumer       
 products. In fact, they reference to no particular product areas. However, 
 the GPSD appears to be a catchall where no other directive applies.        
                                                                            
 Well, so much for my 2 cents worth of opinions. Comments?                  
                                                                            
 Best regards,                                                              
 Ron Pickard                                                                
 rpick...@hypercom.com                                                      
                                                                            
                                                                            





                                                                                
                                     
                    WOODS@Sensormatic                                           
                                     
                    .com                     To:     
emc-p...@majordomo.ieee.org, t...@world.std.com                 
                    Sent by:                 cc:                                
                                     
                    treg-approval@wor        Subject:     General Product 
Safety and Liability Directives            
                    ld.std.com                                                  
                                     
                                                                                
                                     
                                                                                
                                     
                    06/20/00 07:58 AM                                           
                                     
                    Please respond to                                           
                                     
                    WOODS                                                       
                                     
                                                                                
                                     
                                                                                
                                     



In the following discussion, I am interested in determining the legal
aspects only.

The General Product Safety Directive and the Liability Directives apply to
consumer products and not to products used in the workplace. Consider
electrical products that would otherwise be subject to the Low Voltage
Directive but operate below the lower voltage limits of the directive. The
safety of such products intended for use in the workplace are subject only
to non-harmonized national regulations concerning worker safety. Do these
national regulations make the assumption that such equipment must comply
with the applicable essential requirements that are normally associated
with
equipment covered by the LVD?

Richard Woods



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