Hi, Doug.
The control systems are internal to the product, but it relies on
power provided by the host equipment.
Peter Tarver
ptar...@ieee.org
From: Doug Nix <d...@ieee.org>
Subject: Re: [PSES] Applicability of the Machine Directive
Date sent: Thu, 24 Sep 2020 17:05:32 -0400
Copies to: "EMC-PSTC@listserv.ieee.org" <EMC-PSTC@LISTSERV.IEEE.ORG>
To: ptar...@ieee.org
Hi Peter,
The answer to your question lies in the intended application of the
device. If it has an intended application, then it is a machine. If
it is a component that could be incorporated into many kinds of
machines, think "gearbox" for example, then it is not in the scope
of the MD, even it it is an assembly of linked parts at least one of
which moves. Also, does it include the power and control systems
necessary for it´s function, or are these provided by the
application device? If they are contained, then the device is closer
to a machine, pending the intended application. If they are external
then it is a machine part and outside the MD.
Doug Nix
d...@ieee.org
+1 (519) 729-5704
On 24-Sep-20, at 16:35, Peter Tarver <ptar...@ieee.org> wrote:
Hello.
For the following, I have (nearly) concluded that the
Machinery Directive applies, but I have some lingering
uncertainty. I'm looking for reasonable arguments to
say that it does or doesn't apply before I dive
headlong into the tasks related to supporting a
declaration against the Machinery Directive.
Consider a product that is completely sealed but
contains a rotating mass. The mass rotates as a primary
part of the product's function. In the strictest sense,
it is (or contains) a machine. However, any number of
products contain rotating masses (e.g., fans) that are
not generally subject to the Machinery Directive and
which have other standards under the Low Voltage
Directive that address the relevant safety concerns.
Among the many use cases for the product are autonomous
or robotic mail delivery and security systems, which
will move along the ground or along floor surfaces.
These pieces of motive host equipment would require
application of the Machinery Directive. For these and
other use cases,the product could serve as a safety
component, though perhaps not in any traditional sense,
but within the context of Annex V of the Machinery
Directive.
There are no specific standards in the OJ list of
harmonized standards that apply directly to the
product's primary applications function, so I assume EN
60204-1 will apply, with perhaps some peripheral
standards that are in the OJ list.
FWIW, I've performed a review of the mechanical hazards
using IEC 62368-1 and found that the product falls
squarely into MS1.
What ever arguments you can make either in favor of
applying the Machinery directive or against it are
welcomed and encouraged. I look forward to hearing from
you.
Peter
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