Would you interpret the requirements of section 1.7.1 to only apply to "information" pertaining to a "warning"? For instance, does the FCC Statement have to be translated when it does not pertain in Europe?
How about English Text near a switch that says, "Main"? Is it good enough to show in the manual what the switch is for or do we also have to translate the word? If we changed the word "Main" to "CB1" then that would be ok? Or just remove any reverence and just explain the function in the manual? How about I/O ports. I could make up some senseless squiggly lined symbol and explained its meaning in the manual and that is ok, but if I put the word "Input" near the port then I have to have it translated? Why can't I just explain in the manual what "Input" means which we do anyway? This has been a battle that has been going on for a long time. I wish we could come to some understanding. Thanks for everyone's comments. The Other Brian -----Original Message----- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Monday, June 09, 2014 4:04 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Machinery Directive 1.7.1 In message <64D32EE8B9CBDD44963ACB076A5F6ABB0269B066@Mailbox-Tech.lecotech.local>, dated Mon, 9 Jun 2014, "Kunde, Brian" <brian_ku...@lecotc.com> writes: >Here we go again. On and off over the last 30 years I have bumped heads >over having English Text on warning labels on Worldwide marketed >products shipped to non-English speaking countries. I was given the >impression that Europe was ok with English Text as long as it was >explained in the translated manual in an official language of the >country sold. > >For this reason, we have been transitioning to use the new ANSI Style >Warning labels which includes a pictogram, warning symbol, and English >Text. But now I have been informed that a third party lab in France has >found our product to be non-compliant. Here is their reason: > >"Warnings are not written in French on the machine and generate a >confusion for operators." > >Is the third party lab correct and we need to remove all English text >from warnings No, but under French law you probably do need to add the French words. This is one of those typical French laws that is enforced on the fourth Frewsday of every seventh month. >which include pictograms and symbols or are they misinterpreting the >requirements of 1.7.1, which says, "...warning must be expressed in an >official Community language..". What does "expressed" mean? 'given', 'printed', moulded-in' ,'raised on a casting', 'etched', 'stamped' ... you name it. >It technically doesn't say it has to be on the product, I think it does: the heading of 1.7.1 says '.., on the machinery'. >only expressed. Can expressed mean explained in the manual? > >This third party lab seemed to have misinterpreted several other >requirements on the Machinery Directive so we are hoping this is >another. I hate having to train third party labs in something they are >getting paid to know. > >Any help, suggestions, or advice would be most appreciated. Does you French agent know whether the test house is invoking the French language law or just being picky? If they are invoking the law, you must conform. > >The Other Brian > >PS: Here is the entire text of section 1.7.1 of the MD for your >reference. > >1.7.1. Information and warnings on the machinery >Information and warnings on the machinery should preferably be provided >in the form of readily understandable symbols or pictograms. Any >written or verbal information and warnings must be expressed in an >official Community language or languages, which may be determined in >accordance with the Treaty by the Member State in which the machinery >is placed on the market and/or put into service and may be accompanied, >on request, by versions in any other official Community language or >languages understood by the operators. >________________________________ -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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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>
