Lauren, I've not got a great deal of time to spend on this today, and obviously the specific circumstances of any particular case can make a huge difference, but in general I think the answer to your question is that the requirement applies to all guards.
The function of guards is to reduce risks by preventing access to hazards. A hazard is a hazard, whether it is from moving parts or some other cause. Indeed, there are circumstances where moving parts (because they are visibly moving) are arguably less dangerous than other hazards which cannot be seen. If, instead of focusing on the difference between moving parts and electrical hazards, you compare the requirements for moving parts and laser hazards, and then laser hazards and electrical hazards, it becomes clear that the requirements for guards do not simply apply to moving parts and might well apply to electrical hazards. Guards are by no means always the most appropriate means of protection, but where they are, they must be used. Phil Papard of the UK HSE, who was closely involved in drafting the new Directive, told me last November that he was surprised that none of the industry groups who were consulted on the new Directive seemed to be concerned about the new requirement for retained fasteners (which is in EN 953 but is not an EHSR in the old Machinery Directive). Because there were no complaints, they left it in. I'm in regular contact with Phil on a range of issues so if you want me to ask him for further clarification, then please let me know. Regards Nick. At 16:47 -0600 4/2/09, lauren_cr...@amat.com wrote: >I am working a project to adapt our equipment for the new Machinery >Directive (2006/42/EC). Because of the revisions related to guards, >I find myself facing a fundamental question for which I can find no >direct address in the various guides available either for the new or >the old directive. > >The basic question is "Does section 1.4 apply to any guard, or only >guards provided to protect against risks arising from moving parts?" > >I see in 1.3.8 very specific instructions on how fixed guards etc... >should be used as relates to moving parts, and criteria for such >guards is given in sections of 1.4. > >I do not see anywhere else in the Annex an instruction saying guards >should be provided to protect against risks arising from other >hazard types such as electrical hazards, or thermal hazards, or >toxic material hazards. > >Nonetheless, section 1.4 sits there on its own...unqualified. So it >could be understood as applying to any guard per the rather broad >definition in 1.1.1(f). " 'guard' means a part of the machinery used >specifically to provide protection by means of a physical barrier;" > >The practical import of this is, for example, if I have a panel >covering the entrance of a hazardous voltage electrical assembly, is >it a "fixed guard" that must have attached fixing systems (captive >hardware) > >Regards, >Lauren Crane >Product Regulatory Analyst >Corporate Product EHS Lead >Applied Materials Inc. >Austin, TX 512 272-6540 [#922 26540] >--------- >- external use - > >Save paper and trees! Please consider the environment before >printing this e-mail. - 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> All emc-pstc postings are archived and searchable on the web at: 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/ Instructions: http://listserv.ieee.org/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: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
