Re: [PSES] Another Machinery Directive Question

Tue, 15 Jul 2014 08:38:50 -0700 

Doug,
I understand the literal definition that you're applying, and when applied literally I agree. However, it appears to me that the fundamental intention of the MD is to provide protection against moving parts. With that view in mind, it's difficult to see the need for application of the MD to equipment such as this where there are no exposed moving parts. I was hoping to find a list member that has had some specific experience with an AHJ or notified body concerning internal motorized parts and the MD. Without another interpretation or other precedent of some kind I believe that the literal interpretation will have to be applied. 


One of the problems is that there are specific colors for operator  
indicator lights that are X-ray industry standards in both N.A. and EU for  
this type of equipment.  Those colors don't line-up with EN 60204 and I'm  
not seeing any other MD safety standard that can apply.



Thanks all for your input.  Sorry for the late reply, I've been  
motorcycling in northern Michigan sans laptop for the last four days.


Carl


On Fri, 11 Jul 2014 15:00:48 -0400, Douglas Nix <d...@mac.com> wrote:


Carl, Paul, List members,


This is not gray at all. The assembly meets the fundamental definition  
of machinery from Article 2 of the Directive:



The following definitions shall apply:
(a) ‘machinery’ means:

— an assembly, fitted with or intended to be fitted with a
drive system other than directly applied human or
animal effort, consisting of linked parts or components,
at least one of which moves, and which are joined
together for a specific application,

— an assembly referred to in the first indent, missing only
the components to connect it on site or to sources of
energy and motion,



Based on this, I would see this assembly as falling into Article 13,  
“Partially Completed Machinery”. Compliance with Annex I is required,  
which will >also cover the electrical safety requirements under Annex I,  
1.5.1 Electricity Supply. This clause requires you to apply the  
electrical safety standards >that you would use if you were applying the  
LVD.


If you want to discuss this more, feel free to contact me offline.

Doug Nix
d...@ieee.org
+1 (519) 729-5704


On 11-Jul-14, at 14:43, Paul Milton <p...@gmcompliance.com> wrote:


Hi Carl,

Good question.  I've found this to be a very gray area myself as to what
does or does not fall under the MD.  For your device it may not be that
the shutter motors are specifically responsible for its inclusion under

the MD.  It might be that the typical end use equipment these sources  
are
to be installed in is considered machinery, and the customers buying  
X-ray

sources are requesting MD of their component manufacturers.

Thanks,

Paul
-----Original Message-----
From: Carl Newton [mailto:emcl...@gmail.com]
Sent: Friday, July 11, 2014 5:40 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Another Machinery Directive Question

Group members,


I'm working with a company that manufactures an X-ray source  
sub-assembly.

This product includes the X-Ray source and an electronic
interface controller.  The intended use is for the customer to
incorporate the device into automated laboratory equipment that will be
subject to the machinery directive.


This X-ray source includes a motor-driven shutter which is under  
computer

control.  The shutter is  enclosed within a housing and is not operator
accessible.

This company has informed me that one of their German competitors claims
that their very similar sub-assembly complies with the MD.

Does the fact that the device includes an internal motor-driven shutter
bring it into the scope of the MD?  That seems to be a stretch to me.

Thanks in advance for your help,

Carl

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