Alex, Thanks for your reply, and I agree. However, I don't need convincing. Here's the rub - EN60950 is a harmonized standard under the LVD. If the LVD does not apply to the product, then how can I argue that EN60950 applies to the product?
Doug -----Original Message----- From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sent: Monday, June 04, 2001 12:14 PM To: 'Massey, Doug C.' Cc: 'IEEE Forum' Subject: RE: Product Safety: A Matter of Law or Litigation? Doug, As a general rule you should always have your products "Safety Approved". This is showing Due Dilligence in that you have had the product safety evaluated. The latest EN60950:2000 covers ..."mains powered or battery-powered ITE ....with a Rated Voltage not exceeding 600V" i.e. there is no lower voltage limit! I hope this helps? Regards ALEX -----Original Message----- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 1:47 PM 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,"
