Dave, et al,
This discussion has brought about a wider ranging comment than
originally expected - including the invocation of 62368 - which shall be
discussed.
But first, some additional background info should be given. For
those of us who jumped into CE marking at the beginning the path forward was
not fully evident. Some of us determined that 60204 was not the best
standard to use when machinery was built around electronic equipment (rather
than electrical equipment). We commonly used 60950 or 61010 to show
compliance with the LVD requirements as part of the TF for the machines. As
time went on the EU further clarified that they wanted to use 60204 for
machinery and let these other electrical standards focus on the LVD
requirements themselves. This has not been fully satisfactional as the
control systems for machines are becoming more electronic rather than
electric and traditional electronic equipment capabilities have spread into
larger, more powerful equipment - which should be considered machines.
On the 61010 Process Control Equipment side, TC66 asked to
specifically be included in the list of MD standards showing proof of
conformity; this was rejected within the EU and now TC66 is developing a -2
set of MD requirements to guide their mfgrs thru meeting the needed
requirements for their equipment nee machines. This is a good approach;
even tho 61010 is not accepted for the proof of conformity list the
manufacturers get the guidance they need to develop a proper TF to ensure
that their products are safe for use in the market, and accepted by the
users because they can identify how certain expected hazards are treated in
a traditional way.
On the 60950 ITEq side, A similar problem exists as this equipment
grows into a machine. Envision a 3D printer the size of an automobile
capable of putting out large parts in this class. Unfortunately, 60950 is
coming to the end of its life. It is being replaced by 62368 which has been
under development for more than a decade and is now be accepted in Europe
and North America (and will spread to the rest of the world over the next
few years). There is a transition period which is just getting underway
however, TC108 is no longer working to keep 60950 up to date and putting all
the present resources into the replacement 62368. Among other things there
is interest in developing a -2 extension that will work similarly to the
TC66 machinery extension. It will be at least a couple of years before this
comes to fruition unless manufacturers see the need for it sooner and are
willing to apply more resources to speed this up.
From my point of view this is all going in the right direction. In
either case manufacturers will have some direction to dig out additional
requirements that are not usually included for smaller equipment and
properly apply it to provide the needed protection for the user.
Perhaps this long-winded explanation provides a broader view of the
landscape and helps you in determining your path forward.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201 fone/fax
p.perk...@ieee.org
_ _ _ _ _
Thanks for the input folks. The original questions were specifically
regarding the construction of the guards to meet the MD requirements, robust
construction, securely held in place, not give rise to any additional
hazard. The assumption was the need for any applicable guards was
determined by risk assessment (and common sense). I should also have
included my interest wasn't specifically to "guards" but also cosmetic
covers. My interpretation of " not give rise to any additional hazard " is
that it also includes hazard from fire which then includes flammability of
said guards, protective devices, and covers. And the failure of cosmetic
covers that don't provide a guard function could result in a new hazard.
For example someone leans their hand on a cosmetic cover, shatters it, and
then gets cut up from the shards. Therefore one should make sure the
guards and covers meet minimum strength and flammability requirements to
prevent those issues.
Since EN 60950-1 (as an example) includes very specific, objective, and
measurable requirements for mechanical strength and flammability I was
questioning whether similar detailed requirements existed for MD harmonized
standards. Apparently the answer is no. I've received some feedback
regarding EN 953 and although I haven't purchased it yet I agree is sounds
like common sense and also no more specific then what's in the MD itself.
So if we use the requirements in EN 60950-1 for strength and flammability in
addition to the basic MD requirements and said common sense I'm thinking we
should have no issue substantiating compliance to the MD guard requirements.
I didn't intend to imply EN 60950-1 was a starting point in general for
meeting the MD requirements or for that matter EN 60204-1 by itself. There
is a lot of overlap between the two but guard construction requirements
isn't one of the overlaps. Our products are light machinery, some barely
meeting the requirement of machinery for the MD so applying EN 60950-1 to
the products (in addition to all the others applicable) is a reasonable fit
but wasn't really the point of the questions. The US NRTLs use UL 60950-1
as the primary standard when certifying our products for their listing
marks.
So anyway this is the first I've heard of EN 60950-1 being superseded by
IEC/EN 62368-1 and I'm not familiar with EN 62368-1 at all. When is that
expected to happen? Will that apply to the harmonized standards for the
LVD? Is there a plan for a UL 62368-1 like there UL 60950-1 or maybe UL
will succumb and just use the IEC/EN 62368-1 as is?
Thanks
-Dave
-
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