I’m with you here, Dave. Just because a product contains a cooling fan should not mean the MD applies. But then, the products you cite are explicitly excluded from the scope of the MD (I’m sure you know this, since it appears you took the text directly form the MD).
However, in Article 2 of the MD, where the text Doug mentions is located, goes on to say that they’re, “intended for lifting loads and whose only power source is directly applied human effort.” This encompasses: • automotive lifts and jacks • come-alongs • block and tackle sets (if sold as a unit) Peter Tarver From: Nyffenegger, Dave Sent: Thursday, March 30, 2017 17:40 But there are products meeting that definition of machine that are covered by the LVD and specifically excluded from the MD: — household appliances intended for domestic use, — information technology equipment, — ordinary office machinery, -Dave From: Douglas Nix Sent: Thursday, March 30, 2017 5:20 PM I concur with Michael Loerzer. IMO, the test labs didn’t feel comfortable doing MD evaluations, so they used the “out” that was in the text of the previous MD (98/37/EC) that said that if the hazards were ‘predominantly electrical in nature” then the MD needn’t apply. Many machines were “slid-past” based on this misuse of the text of the MD, which is why the text was changed in the 2006 edition. If the device is “an assembly of linked parts, at least one of which moves” it’s a machine. -- Doug Nix d...@mac.com<mailto:d...@mac.com> The information contained in this message may be privileged and confidential. It is intended to be read only by the individual or entity to whom it is addressed or by their designee. If the reader of this message is not the intended recipient, you are on notice that any distribution of this message, in any form, is strictly prohibited. If you have received this message in error, please immediately notify the sender and delete or destroy any copy of this message! - ---------------------------------------------------------------- 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>
