Thanks Lauren.

 

That is what we need.  The screws on this product hold on a guard that covers 
very slowly moving parts. Lock nuts are used to ensure that they do not shake 
lose and the guard does not need to be removed for servicing or replacing parts.

 

I will look at EN 953.

 

Best regards

John McAuley
www.cei.ie
john.mcau...@cei.ie <mailto:john.mcau...@cei.ie> 

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From: lauren_cr...@amat.com [mailto:lauren_cr...@amat.com] 
Sent: 26 April 2010 17:16
To: john.mcau...@cei.ie
Cc: emc-p...@ieee.org; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: Garden Appliances, LVD v MD

 


John, 

The captive hardware criterion in the new MD does not, I think, have to be 
crippling. I've had some exchanges with Ian Fraser in the Commission on this 
point. He notes the appropriateness in applying risk assessment as part of the 
consideration. In this light, for example, the case screws on a common drill do 
not need to be captive as they are not foreseen to be used except by 
specialized service personnel. 

It is also instructive to look at the new version of EN 953 (notified to the 
new MD) related to fixed and movable guards, which has similar implications 
(i.e. if not foreseen for removal (e.g. maintenance) then captive hardware is 
not required) 


Regards, 
Lauren Crane 

Applied Materials
america - europe - asia   
Corporate Product EHS 
www.amat.com 

lauren crane (mr.) 
product regulatory analyst 
(t) +1.512.272.6540 
lauren_cr...@amat.com 

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"John McAuley" <john.mcau...@cei.ie> 
Sent by: emc-p...@ieee.org 

04/26/2010 10:55 AM 

Please respond to
<john.mcau...@cei.ie>

To

<EMC-PSTC@LISTSERV.IEEE.ORG> 

cc

        
Subject

Garden Appliances, LVD v MD

 

                
                                      




Dear Group 
  
I have a query from a client that wishes to place an appliance on the EU market 
which has a small mechanical hazard associated with it. It is battery powered 
at 12Vdc, rechargeable battery.  There is  a mains charger but it does not 
connect directly to the appliance. 
  
We have been procrastinating as to whether the LVD or Machinery Directive 
applies. There are some 60335 type products with a mainly mechanical hazard 
that have been moved from the LVD harmonised standards list to the MD standards 
list although they are mainly commercial items (floor cleaning machines, 
washing machines etc) to comply with the new thinking in this regard. 
  
This item is clearly a domestic product, however, as the LVD doesn’t strictly 
apply we feel we may have to apply the MD. 
  
Problem is that the new MD has awkward requirements regarding fixing of guards 
which does seem to be a bit of overkill for this product. 
  
I would be grateful to receive any views. 
  
Best regards 
  
John McAuley 
  
  

www.cei.ie <http://www.cei.ie/> 
john.mcau...@cei.ie <mailto:john.mcau...@cei.ie>  
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