Hello again, Brian;  It sure does sound to me like you've done your basic 
diligence;  are the ANSI compliant symbols any different from the JIT compliant 
symbols?  Even when I was with an NRTL/NB organization, I was often irked by 
standards requirements that were not requested or considered useful by actual 
customers. That being said, I've got the feeling that an informed answer would 
require a fairly detailed account of "getting dinged in Europe"  Regards, Brian 
Gregory[Colorado] 
720-450-4933

---------- Original Message ----------
From: "Kunde, Brian" <brian_ku...@lecotc.com>
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Warning Label: Disconnect from Mains
Date: Fri, 1 May 2015 18:15:40 +0000


Thanks Doug and Colorado Brian. We liked the look of the new ANSI labels so we 
switch over all the warning labels on our products to this style a few years 
ago. But now we are getting dinged in Europe and have to replace the labels 
with symbols only or with the text in the language of the country we sold in. 
This is difficult to do because sometime we ship instruments to our sales 
offices in Europe but we don&rsquo;t know what country it might be sold in 
until it is purchased. 
 
Why don&rsquo;t the EU just decide on one language like the Chinese did? (Those 
are fighting words). 
 
We do explain the meaning of our warning symbols in the User&rsquo;s Manual and 
the manuals are translated into different languages depending on the country it 
is sold and what our customers want. The users of our type of instruments are 
generally well educated (scientists, chemists, engineers, technicians, etc.) 
and most of the time they are happy with English only. But when other languages 
are requested we try to provide them translated copies fairly quickly. 
It&rsquo;s very costly , too.
 
Most of our customers send their Users for training at our facility in the US. 
Classes are in English Only. 

 The other Brian
 
From: dougp01 [mailto:doug...@gmail.com] 
 Sent: Friday, May 01, 2015 1:48 PM
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] Warning Label: Disconnect from Mains
 
I agree with Colorado Brian. It seems that more and more, IEC-based standards 
are requiring a full explanation of symbols and warnings in the user 
documentation. As it turns out, many clients of mine leave the user manuals to 
the very last and they are usually very lacking. Where possible using symbols 
only is an economical option. 
 
One exception to using just symbols might be in certain industries where using 
an ANSI/IEC compliant labeling system is required.  &lrm;In this case some 
verbiage is required. The text should simply describe the problem and how to 
avoid it. Nothing more. Proper use of the keywords Danger, Warning, and Caution 
are also essential.  Since overstating the hazard is not advisable.
 
All the best, Doug

 
 

 
 
From: Brian Gregory
Sent: Friday, May 1, 2015 11:31 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Reply To: Brian Gregory
Subject: Re: [PSES] Warning Label: Disconnect from Mains
 
 
 
---------- Original Message ----------
 From: "Kunde, Brian" <brian_ku...@lecotc.com>
 Date: Wed, 29 Apr 2015 18:54:17 +0000
Brian, thanks for your input. Can the potential hazard be addresses without 
English Text which may be misunderstood by those unfamiliar with the language? 
Wouldn&rsquo;t Symbols Only be better? 
 
[Colorado Brian here]  Symbols ON the equipment are sufficient, and often 
preferred.  John's answer is also correct, that the symbols (even fully 
JIT-compliant ones) need explained, in all the appropriate languages (as 
defined by ND's), in the supplied documentation.  Any additional needed 
information can be added at this point by the manufacturer.  
 
 
So if AHJs, NRTLs, etc. like to see some kind of warning on the outside of 
electrical equipment, then won&rsquo;t the Hazardous Voltage Warning symbol 
alone meet this requirement WITHOUT any Text?  
 
As the Machinery Directive states, &ldquo;Information and warnings on the 
machinery should preferably be provided in the form of readily understandable 
symbols or pictograms.&rdquo;
 
Bingo;  warnings on the machinery.... 
 
And in the case given in the 61010-1 standards, it doesn&rsquo;t say that you 
have to use Text, but what the warning marking should state. A symbol or 
symbols can &ldquo;state&rdquo; or have the same meaning as text without the 
concern of the User needing to be able to understand the language of the text.  
 
I advise being verbose as possible in the documentation;  this can be in 
digital format, so needn't incur much additional expense.  You, as the 
manufacturer, are now officially on record as directing the end user:  DO this, 
NOT that... etc.   Wordy labels can be expensive, and possibly confusing (esp. 
when many languages get involved);  I was always perfectly happy with symbols.
 
CYA, baby.... 
 
The Colorado Brian
 

  
 
From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
 Sent: Wednesday, April 29, 2015 10:39 AM
 To: Kunde, Brian
 Cc:  EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: RE: Warning Label: Disconnect from Mains
 
Our NRTL asks for the warning &ldquo;No User Serviceable Parts Inside&rdquo;  
when that is the case but that is relative to products complying with UL/EN 
60950-1 and EN 60204-1.   Of course that needs to be translated into all 
appropriate languages too.
 
-Dave
 
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
 Sent: Wednesday, April 29, 2015 10:21 AM
 To:  EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: [PSES] Warning Label: Disconnect from Mains
 
Greetings.
 
We make laboratory equipment designed to the requirements of the IEC/EN/UL/CSA 
61010-1 Ed. 3 standard.  
 
Most electrical equipment has at least one warning somewhere visible on the 
outside of the equipment that states something like, &ldquo;Disconnect Power 
Before Servicing&rdquo;. 
Where does this requirement come from? I see no such requirement in the 61010-1 
standard.
 
The 61010-1 does say, &ldquo;If the instructions for use state that an OPERATOR 
is permitted to gain access, using a TOOL, to a part which
in NORMAL USE may be HAZARDOUS LIVE, there shall be a warning marking which 
states that the equipment
must be isolated or disconnected from the HAZARDOUS LIVE voltage before 
access.&rdquo;
 
However, if our users do not need to gain access inside our equipment, then I 
assume such warning is unnecessary.
 
We used to have a warning label on any tool assessable panel that has hazardous 
voltages behind it. However, I do not see this as a requirement in the 61010-1. 
 In the past, we have had inspectors write us up for not having such labels on 
all panels with hazardous voltage behind it. Does this requirement come from 
somewhere else? Are the inspectors wrong?
 
The label we commonly use has the Symbol 12 (hazardous voltage warning) and 
English Text that states something like, &ldquo;Disconnect Power Before 
Servicing&rdquo;. However, when our products are sold into non-English speaking 
countries, we sometimes get dinged for the English Text; especially in French 
speaking counties.  So, if such a label truly is required, can we get away with 
only using the Symbol 12?, or can we use a label with a combination of symbols, 
such as Symbol 12 and maybe the ISO 3864-2 Disconnect Mains Plug symbol?  Is 
text of some kind required or can we just use symbols?
 
Any suggestions or recommendations? 
 
Thanks to all for your input.
 
The Other Brian
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