Ian, The revised MD (2006/42/EC mandatory dec 30, 2009) says the machine must be "accompanied" by the instructions (ref Annex 1, 1.7.4).
In the printed (pdf file) commentary on the current/old version of the MD from the Commission you can find this advice "A document must be physically transmitted to each buyer of the machine." But on-line, the Commission provides an updated (greener) interpretation. On-line - Ref http://ec.europa.eu/enter rise/mechan_equipment/machinery/guide/annex1-17.htm "Proof of transmission It is generally considered up to the customer who did not receive the instructions to prove that they were not transmitted and not the reverse. Some manufacturers, however, take the trouble to prove transmission of the instructions. Others have the delivery note countersigned by the customer as proof that he has received the instructions. The latter are sometimes attached to this note. The institution by the manufacturer of a formal procedure for the inclusion of the instructions (quality assurance) can make it safe to assume that the instructions have been transmitted. Electronic data interchange is now well established between professionals. The "machinery" Directive is not opposed to instructions being transmitted in this form, but this should be covered by a specific clause in the contract so as to avoid any dispute. Compatibility must be guaranteed between the software used by the manufacturer or his representative and the software used by the buyer. It is the responsibility of the buyer to ensure the physical availability of the instructions for the end-user. The manufacturer can draw the attention of his customer to this responsibility." 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. "Gordon,Ian" <ian.gor...@edwardsvacuum.com> Sent by: emc-p...@ieee.org 02/04/2009 05:26 AM To "IEEE EMC & SAFETY PSTC" <emc-p...@ieee.org> cc Subject All Is there a legal requirement to provide a paper copy of product instructions rather than supply these on CD? Ian Gordon The contents of this email and any attachments are confidential and are provided solely for the use of the intended recipient(s). If you are not the intended recipient, you are hereby notified that any copying, disclosure, distribution, or use of this e-mail, its attachments or any information contained therein is unauthorised and strictly prohibited and you should please contact the sender immediately and delete this e-mail and any attachments from your system. No responsibility is accepted for any virus or defect that might arise from opening this e-mail or attachments, whether or not it has been checked by anti-virus software. - 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> - 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>
