Regan, “So, a European must compile it but he can store it somewhere in i.e. Timbuktu......... strange.”
I don’t take ‘compile” too literally, they are looking for a contact in the EU, one that can be easily contacted who can provide a copy of the technical file on request. How the person gets it or where they get it from is not of concern. This individual is distinctly different than one who signs the DoC and different than authorized representative, although it could be the same person as you have pointed out. The Blue Guide probably has some words on this, it’s been a while since I’ve looked at it. Technical file requirements vary across directives. -Dave From: Regan Arndt [mailto:reganar...@gmail.com] Sent: Tuesday, December 18, 2018 1:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] MD clarification of the DoC Hello folks. Hope you are all enjoying the festive season thus far! I was wondering if any of you knew the rationale behind requirement #2 in the Machinery Directive and why the other directives do not have this? (as you can see, this is over & above the authorized rep (#10) signing the DoC). Excerpt below: A. EC DECLARATION OF CONFORMITY OF THE MACHINERY 2. name and address of the person authorised to compile the technical file, who must be established in the Community; 10. the identity and signature of the person empowered to draw up the declaration on behalf of the manufacturer or his authorised representative. It's odd because in Annex VII, in section 2, it states: The technical file does not have to be located in the territory of the Community, nor does it have to be permanently available in material form. However, it must be capable of being assembled and made available within a period of time commensurate with its complexity by the person designated in the EC declaration of conformity. So, a European must compile it but he can store it somewhere in i.e. Timbuktu......... strange. - ---------------------------------------------------------------- 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<mailto: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<mailto:sdoug...@ieee.org>> Mike Cantwell <mcantw...@ieee.org<mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org<mailto:j.bac...@ieee.org>> David Heald <dhe...@gmail.com<mailto: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>
