John,
In the EU Application Guide 2006-42-ec, 2nd Edition, Recital 35, which is in reference to and an explanation of the first indent of Article2(a), of the Directive says: The Machinery Directive does not apply as such to separate machinery components such as, for example seals, ball-bearings, pulleys, elastic couplings, solenoid valves, hydraulic cylinders, flange-connected gearboxes and the like, that do not have a specific application and that are intended to be incorporated into machinery. The complete machinery incorporating such components must comply with the relevant essential health and safety requirements. The machinery manufacturer must therefore choose components with adequate specifications and characteristics. So the product under discussion is clearly not within the scope of the Machinery Directive. Doug Nix was correct when he said you need to read the Directive's scope. If you need a copy of the Application Guide it is available online or contact me privately and I will send it to you. Thanks, Steve Brody sgbr...@comcast.net Product EHS Consulting LLC From: John Allen [mailto:jral...@productsafetyinc.com] Sent: Wednesday, April 13, 2016 6:32 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Partly Completed Machinery...or not??? Thanks Dave. The product is sold to the end user without the rope. The rope is the only missing element. The rope is specified as Max Working Load, Max Diameter and Min Rope Break Load. In some instances they do sell to integrators, etc. In that case I can see why it's considered Partly Completed Machinery. Thank you! _____ From: Nyffenegger, Dave <dave.nyffeneg...@bhemail.com> Sent: Wednesday, April 13, 2016 5:15 PM To: John Allen; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Partly Completed Machinery...or not??? Well for sure Partly Completed machinery is not to bear the CE mark and is to have a Declaration of Incorporation. I think that is made clear in the Blue Guide as well. The question is if your product qualifies as Partly Completed Machinery. Is the end user expected to supply the rope, is the rope the only missing element? Is the product sold to the end user? If so, then I would think the product is not partly completed machinery. Or is the product really not useable as is and intended to be incorporated into a larger machine by another manufacturer or integrator? -Dave From: John Allen [mailto:jral...@productsafetyinc.com] Sent: Wednesday, April 13, 2016 6:05 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Partly Completed Machinery...or not??? Hi guys, I'm hoping to feedback and clarification if I'm reading the Machinery Directive correctly. The product is a Pulley Block with a brake/ratchet mechanism. It is not supplied with the rope. It is used for lifting machinery, not people. We believe this to be partly completed machinery and should not bear the CE mark and be supplied with a Declaration of Incorporation. We have heard different opinions and some believe because it has a brake/ratchet it should be marked CE and supplied with a Declaration of Conformity. Your thoughts and opinions would be appreciated. Best Regards, John - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
