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 - external use - Save paper and trees! Please consider the environment before printing this e-mail. "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> ***************************************************************** DISCLAIMER: The information contained in this e-mail may be confidential and is intended solely for the use of the named addressee. Access, copying or re-use of the e-mail or any information contained therein by any other person is not authorised. If you are not the intended recipient please notify us immediately by returning the e-mail to the originator ________________________________ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org <mailto:emc-p...@ieee.org> > All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc <http://www.ieeecommunities.org/emc-pstc> Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ <http://www.ieee-pses.org/> Instructions: http://listserv.ieee.org/request/user-guide.html <http://listserv.ieee.org/request/user-guide.html> List rules: http://www.ieee-pses.org/listrules.html <http://www.ieee-pses.org/listrules.html> For help, send mail to the list administrators: Scott Douglas <emcp...@socal.rr.com <mailto:emcp...@socal.rr.com> > Mike Cantwell <mcantw...@ieee.org <mailto:mcantw...@ieee.org> > For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org <mailto:j.bac...@ieee.org> > David Heald <dhe...@gmail.com <mailto:dhe...@gmail.com> >