Scott,

The New LVD as with the latest Machinery Directive requires a Risk Assessment 
of the Essential Health and Safety Requirements called out in the Directive. 
Most likely the new ISO EN 12100 Risk Assessment standard will be harmonized to 
the LVD and you can use this on your DoCs to show compliance for safety in 
additional to any other applicable safety standards.  The world of product 
safety is changing from a list of do's and don't found in product safety 
standards to a proper Risk Assessment of your products. There are several good 
articles out there on this topic.

The color image is optional. I'm curious to see how many manufacturers include 
color images and how they implement them on DoCs.  I think this was added 
because in some cases there may be items that cannot be properly identified by 
other means in which case the color image may be required. I think the only 
requirement of the image is that it must show the product in a way where it can 
be properly identified from other products if you are relying on the image for 
that purpose.

Regarding sample testing, I'm not sure. This could refer the 100% type testing 
performed in Production, which you should already be doing. Or it could refer 
to actual product audits, which I am highly in favor of but many companies do 
not bother with; except for the factory inspections performed by 3rd party 
certification houses. If and how you do sample testing of production to insure 
you are shipping compliant products will vary from company to company depending 
on many factors and can only really be determined by the manufacturer.

I hope this was helpful.

The Other Brian

-----Original Message-----
From: Scott Xe [mailto:scott...@gmail.com]
Sent: Monday, November 30, 2015 8:47 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] New LV Directive 2014/35/EU

There are 3 additional requirements as compared with existing one.

The technical documentation shall include an adequate analysis and assessment 
of the risk(s).  What is objective and scope for these?  Do these analysis and 
assessment refer to 3rd party verification of compliance with applicable 
standard(s) or are they on top of compliance with applicable safety standard(s)?

In DoC, a suitable identification of the product should be included - a colour 
image of the product could be employed.  Is there any guideline for this 
product image?  One exterior front view photo like one on front cover of 
catalogue or a series of different views of the product?

Article 6, point 4 regarding manufacturers’ obligations, to protect the health 
and safety of consumers, carry out sample testing of electrical equipment made 
available on the market.  Does it mean the sample testing, i.e.. dielectric 
strength test, earth continuity test, etc. is taken in production at factory or 
in warehouse of destined market?

Your guidance is highly appreciated!

Regards,

Scott

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