Dear All, Equipment used "at work" in the EU is - by definition "work equipment" and as such is covered by the Use of Work Equipment Directive (89/655/EEC) and the Amending Directive (95/63/EC) to the Use of Work Equipment Directive (89/655/EEC)
In outline, this requires that the equipment supplied as work equipment be safe. One of the ways that the equipment can be thought of as safe is that it should meet all the applicable Directives.... Now the Work Equipment Directive does not discriminate between a small test box with two resistors, a hammer or a large piece of custom production line equipment. If, instead of making the equipment in-house the task had been subcontracted within EU, then the "product" would need to be certified to the applicable directives. If what you have built as in-house test equipment presents no risk of harm, then you might not need to address the directives. If there is a risk of harm, then you probably need to confirm that the in-house equipment would meet those directives. Look also at the UK implementation of the work equipment directive - known as PUWER (Provision and Use of Work Equipment). A guide to these regulations is given at http://www.hse.gov.uk/pubns/indg291.pdf and the UK regulations can be found at http://www.opsi.gov.uk/cgi-bin/htm_hl.p ?DB=opsi&STEMMER=en&WORDS=work+equip+&C LOUR=Red&STYLE=s&URL=http://www.opsi.go .uk/si/si1998/19982306.htm#muscat_highlighter_first_match (sorry for the long URL - it does work if you chain it together in the URL line) I hope this is of help. Tim Haynes Electromagnetic Engineering Specialist SELEX Sensors and Airborne Systems Tel: +44 (0) 1582 886239 Fax: +44 (0) 1582 795871 Mobile: e-mail: tim.hay...@selex-sas.com Homepage www.selex-sas.com From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: 31 August 2005 07:16 To: emc-p...@ieee.org Subject: Re: In-house test equipment *** WARNING *** This mail has originated outside your organization, either from an external partner or the Global Internet. Keep this in mind if you answer this message. Doug Beckwith <dougbeckw...@yahoo.ca> wrote (in <20050831024102.32663.qm...@web30505.mail.mud.yahoo.com>) about 'In-house test equipment', on Tue, 30 Aug 2005: >My previous employers all had subsidiaries/factories in Europe, and the >transfer of custom built test equipment across the pond was >commonplace. The key with the EU legislation is the words "offered for >sale". If the equipment is not going to be sold then as long as the >shipping papaerwork indicates that it is from xyz company to the same >xyz company (UK) then there is no issue at customs. We certainly never >had any issues. It's actually not 'offered for sale' that is the critical issue, because even if it's not offered for sale, it IS 'taken into service'. The weasel phrase here that was probably invoked to allow your equipment into the EU is 'This equipment is not for free circulation within the EU.' This phrase should appear on the shipping documents but there is no guarantee that customs in all EU countries will accept it. In particular, **once the equipment has entered the EU, it is not allowed to cross an internal national border, because that would be 'free circulation'**. This is a very grey area, which has arisen because there was no proper provision for unique special-purpose products, like factory test equipment, in the Directive. The new Directive is a bit better in this respect. > >One thing you should be careful of is the fact that the local power >utility may require evidence of compliance to the relevant safety >standard for the equipment, or may require some kind of inspection >before you plug it in. It's not the power utility (at least in UK) but Health and Safety officials. -- Regards, John Woodgate, OOO - Own Opinions Only. Deadlines are 90% of deadliness. http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org 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.ieeecommunities.org/emc-pstc ******************************************************************** This email and any attachments are confidential to the intended recipient and may also be privileged. If you are not the intended recipient please delete it from your system and notify the sender. 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