I agree with you and I am in favor of providing the DoC to the customer (preferably before purchase); however, it is an unnecessary burden on the manufacturer to have to put the DoC in the "Instruction Manual" as the MD states. Let me provide the DoC to my customer in a way that is best for me and my customer. Instruction Manuals are printed and packed months in advance and built in quantity. If the DoC information changes, I'm shipping old DoCs with my product or I have to rework my Manual Packs with the new DoC which is costly. So I would prefer not having to include this information in the Manual.
So how we do it is simply publish the "content of the DoC" in our manuals (as the MD allows), making the information as generic as possible and leaving out any dates or numbers or signatures that are likely to change, and provide our customers with the official DoC through our Sales/Marketing channels if requested. I think this is the approach a lot of companies are taking. As we hear about proposed future requirement of other Directives wanting to make the DoC more unique for each product built and sold, it would make providing the DoC in a bound manual completely impossible and impractical. Thanks for the information and references. The Other Brian From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Tuesday, December 03, 2013 10:47 AM To: Kunde, Brian Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Declaration of Conformity The reason for this is that the workplace safety requirements introduced under Article 137 of the TFEU require an employer to ensure that equipment which they supply for the use of their employees complies with the applicable essential requirements. The Declaration is a useful piece of paper to assist an employer in this task. Nick. On 3 Dec 2013, at 00:11, Kunde, Brian <brian_ku...@lecotc.com<mailto:brian_ku...@lecotc.com>> wrote: The MD requires the DoC (not DoI) or a document calling out the content of the DoC to be provided in the Instruction Manual. The purpose of this requirement is not clear to me but it says it so you have to do it. ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- 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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
