Hi Doug, You've struck upon the same question that my company (and I assume, many others) has wrestled with. To answer your question directly (considering only the European market). Making your product safe is a matter of law. Using a third party lab to evaluate the safety is a matter of litigation. My reasons follow:
If your product runs from less than 75VDC or 50VAC, the law says that the Low Voltage Directive does not apply. I assume that you have checked to see if your product is covered by other, more specific directives such as the Machinery Directive, Medical, R&TTE ... I assume that none of these apply. If you haven't checked this, I would recommend it. Every product not covered by a is covered by the General Product Safety Directive. So here, the LAW says that you need to make a safe product. The LAW also says that the manufacturer is liable for the safety of the product. However, the LAW does not absolutely require a 3rd party lab safety evaluation to do so. You can evaluate the safety of the product yourself. You can even use EN 60950 if you technically feel that this is the most applicable standard. This is where litigation comes in. If there ever was an accident with your products, the third party safety evaluation MAY help keep the judgements against your company down. However, It is no guarantee. So, look at a bunch of factors: 1. Are you absolutely sure that you have assessed your product and found the correct directive that it is covered by? 2. Does your company feel comfortable that they can asses and mitigate all of the liability risks (electrical shock, chemical, fire, battery explosion...) of your products? Would you or one of your engineering colleagues be able to look a jury in the eye in the case of an accident? 3. What are your customers expectation? Do they expect a third party safety eval? Have they ever asked about it? 4. What are your competitors doing? 5. Do you have a cost estimate from a third party lab for the safety eval? That way, you'll have a cost to compare against the benefits. These are my opinions only and I admit that my opinions are the concoctions of one mind trying to figure out a gillion confusing (and sometimes contradictory) pages of regulatory documents. Stay compliant my man. !!!!!!!!!PLEASE NOTE THE NEW EMAIL ADDRESS!!!!!!!! Chris Maxwell Design Engineer NetTest 6 Rhoads Drive, Building 4 Utica,NY 13502 email: chris.maxw...@nettest.com phone: 315-266-5128 fax: 315-797-8024 > -----Original Message----- > From: Massey, Doug C. [SMTP:masse...@ems-t.com] > Sent: Monday, June 04, 2001 8:47 AM > To: 'IEEE Forum' > Subject: Product Safety: A Matter of Law or Litigation? > > > Colleagues: > > I have been tasked with justifying the need for independent, third party > evaluations of the safety of our company's products to applicable > standards. > Our company manufactures various ITE equipment, either handheld, battery > powered devices, or ITE devices powered by vehicle batteries. In > particular, > the scope of the LVD states that it is applicable to devices rated > 50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market > these products in 35 countries; North America, the EU/EFTA, and others - > in > fact, pretty much all of the countries participating in the CB Scheme. > > In the US, OSHA regs justify this requirement, as our equipment is sold > through direct channels solely for logistics applications - in other > words, > US workers will be using the equipment - it's not for general consumer > use. > TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table > of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to > this subpart. Acceptable. An installation or equipment is acceptable to > the > Assistant Secretary of Labor, and approved within the meaning of this > Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or > otherwise determined to be safe by a nationally recognized testing > laboratory; or (ii) With respect to an installation or equipment of a kind > which no nationally recognized testing laboratory accepts, certifies, > lists, > labels, or determines to be safe, if it is inspected or tested by another > Federal agency, or by a State, municipal, or other local authority > responsible for enforcing occupational safety provisions of the National > Electrical Code and found in compliance with the provisions of the > National > Electrical Code as applied in this subpart; or ... > > In the EU/EFTA, the justification is not so easy. As I mentioned earlier, > the products are exempt from the LVD. The General Product Safety > Directive, > and the Product Liability Directive, do not give me an easy justification, > such as in the case of the OSHA regs stated in US Federal Code. My company > has always had all products evaluated to the -950 standards, but has > observed that other manufacturers of similar equipment do not have their > products evaluated to applicable safety standards, and CE mark their > products based on compliance to the EMC Directive, but not to the LVD. > > I would greatly appreciate your insights, opinions, and assistance with > this > question. > > Doug Massey > Safety Approvals Engineer > LXE, Inc. > Norcross, GA., USA > Ph. (770) 447-4224 x3607 > FAX (770) 447-6928 > e-mail: masse...@lxe.com > > Cruise our website at: http:\\www.lxe.com > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ > > To cancel your subscription, send mail to: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Michael Garretson: pstc_ad...@garretson.org > Dave Heald davehe...@mediaone.net > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > Jim Bacher: j.bac...@ieee.org > > All emc-pstc postings are archived and searchable on the web at: > http://www.rcic.com/ click on "Virtual Conference Hall," ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson: pstc_ad...@garretson.org Dave Heald davehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on "Virtual Conference Hall,"
