Hi Carl,


You don’t have to apply 60204-1 to comply with the MD.  I think the only
mandatory product requirements for the MD are those of Annex I.  Your
likely OK applying 61010-1 as a reference standard for electrical hazards
and the Annex I to meet minimum requirements of the MD.  I believe this is
what Doug was eluding to in his first email, he can correct me if I’m wrong.



Good Luck,



Paul



*From:* Carl Newton [mailto:emcl...@gmail.com]
*Sent:* Thursday, July 17, 2014 9:58 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Another Machinery Directive Question



Doug,



I've reviewed the OJ list of safety standards applicable to the MD and
there is nothing there applicable to X-ray equipment (no surprise).  I view
EN 60204 as a "catch-all" fall-back standard for electrical equipment that
falls within the scope of the MD, but which has no other relevant standard
listed.

I would not apply 60204 for any reason other than to comply with the MD.



Generally, I consider the strict literal interpretation of the scope of the
MD to be excessive in many cases.  For example, a piece of industrial
equipment intended to do nothing but perform a monitoring function, but
which includes an internal cooling fan, can be considered to fall within
the scope of the MD if you apply the following definition literally:



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,



If that industrial monitoring equipment doesn't fall within the scope of
any of the exclusions included within the MD, then the fact that the fan is
motor-driven should force the equipment into the scope of the MD if
interpreted literally.  In this example, EN 61010-1 should probably be
applied.  But as we all know, that doesn't provide us a path to the
standards route to compliance when applying self-declaration under the MD.



Good information on the indicator requirements.  I haven't yet studied the
latest edition of 60204 and it's been many years since I've read the
standard.



Thanks again very much to all,



Carl



On Tue, 15 Jul 2014 12:32:57 -0400, Mr. Doug Nix C.E.T. <d...@ieee.org>
wrote:



Carl,



With respect to:



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.



Is EN 60204-1 the most appropriate standard for this machinery? If the
machine were covered only by the LVD, would you still choose EN 60204-1?



If the answer is YES, then I completely agree with Lauren, you can use
whatever indicator lights are normal in your industry, provided the
colours, flash rates and any other characteristics that are important
interns of understanding the indications are explained in the manuals.



The indicator colours given in EN 60204-1 are there for designs that
conform to the more general types of machinery found in industry, and not
more specialized equipment like that you describe. The key language is in
the second paragraph of Clause 10.1.1:



“*As far as is practicable*, those devices shall be elected, mounted, and
identified or coded in accordance with IEC 61310."



 I recognize that Clause 10.2.1 is worded as a SHALL clause, but this is
why I question the use of EN 60204-1 for your product.



Doug Nix

d...@ieee.org

+1 (519) 729-5704



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