HI Steve, One thought that occurs to me. The method of test does not seem to mention if it is intended for final installation or during the time when the unit is mobile. By your description, I assume you intend it to be non-mobile. I did this sort of topple test once before on a telescopic construction site light tower. In that case, the topple test is unavoidable, but we had other concerns about the tilt and then the release. The concern was about the unit going over the center in the other direction after being released and whether it would topple. The solution was to add more ballast in the battery compartment below.
In this case, I would try to get clarification on whether this test is applicable to the operartional state and location only (castors up), and what the level of expertise required for mobility? My assumption is it's non-operational while mobile, if that even matters. Another possibility is to write up "*conditions of use*", in the user documents and cover this concern under Section 17 Risk Assessment since it seems possible that your concerns are not "*fully addressed*" in sections 6 thru 16, 3rd edition. Best of luck, ~ Doug Douglas E Powell Laporte, Colorado, USA doug...@gmail.com LinkedIn <https://streaklinks.com/B2gQNFh5uTDCaJcTcQbLipiI/https%3A%2F%2Fwww.linkedin.com%2Fin%2Fcoloradocomplianceguy%2F> (UTC-06:00, US-MDT) ᐧ On Mon, Feb 12, 2024 at 10:36 PM Steve Brody <sgbr...@comcast.net> wrote: > Experts: > > I need your opinions on the following. > > I am having a 'discussion' with an NRTL on a product that I can't show you > a picture of but here is a description: > > - the base of the unit is 20" w x 26" l x 29" hf > - the base of the unit is mounted on caster/leveling feet devices that > when positioned for use, the leveling feet are lowered and the casters come > off the ground, and the leveling feet are sufficiently rated for more than > 4x the load of each corner > - in the middle of the top of the base there is a robot mast for the Z > axis, and it measures roughly 4" square and is 41" tall > - the whole product weighs 220 lbs > > The stability requirements in 61010-1 are as follows, and I highlighted > the text of interest: > > Equipment and assemblies of equipment not secured to the building > structure before operation shall be physically stable. > > If means are provided to ensure that stability is maintained after the > opening of drawers, etc. by an OPERATOR, either these means shall be > automatic or there shall be a warning marking to apply the means. > > Each castor and support foot shall be RATED to support a load of at least > 4 times its normal load, or the castors and support feet shall be tested > according to d) and e), below. > > *Conformity* *is* *checked* *by* *inspection* *and* *by* *carrying* *out* > *each* *of* *the* *following* *tests,* *if* *applicable**,* *to* *ensure* > *that* *the* *equipment* *will* *not* *overbalance.* *Containers* > *contain* *the* *RATED* *amount* *of* *substance* *which* *provides* *the* > *least* *favourable* *conditions* *of* *NORMAL* *USE**.* *Castors* *are* > *in* *their* *least* *favourable* *position* *of* *NORMAL* *USE**.* > *Doors,* *drawers,* *etc.* *are* *closed* *unless* *otherwise* *specified* > *below.* > > 1. > 1. *Equipment* *other* *than* *HAND**-**HELD* *EQUIPMENT* *is* > *tilted* *in* *each* *direction* *to* *an* *angle* *of* *10**°* > *from* *its* *normal* > 2. *Equipment which has both **a height of 1 m or more and a mass > of 25 kg or more, and all floor-standing equipment, has a force applied > at > its top, or at a height of 2 m if the equipment has a height of more > than 2 > The force is 250 N, or 20 % of the weight of the equipment, whichever is > less, and is applied to all surfaces in directions which could cause the > equipment to topple. Stabilizers used in **NORMAL* *USE**,* *and* > *doors,* *drawers,* *etc.,* *intended* *to* *be* *opened* *by* *an* > *OPERATOR**,* *are* *in* *their* *least* *favourable* *positions.* > 3. *Floor-standing* *equipment* *has* *a force of 800 N applied > downwards at the point of maximum moment to:* > - *all* *horizontal** working* *surfaces;* > - *other* *surfaces* *providing* *an* *obvious* *ledge* *and* > *which* *are* *not* *more* *than* *1 m above floor * > > *Doors,* *drawers,* *etc.* *are* *closed,* *except* *that* *those* > *intended* *to* *be* *opened* *by* *an* *OPERATOR **are* *in* *their* > *least* *favourable* *positions.* > > When the force was applied at the top of the robot mast, it unit started > to topple at 38 lbs, which is less than the required 44 lb force according > to the standard. > > The case I presented why this test was not applicable was: > > - because the robot mast is located in the center of of the unit, and > not flush with the sides, that it did not represent the same situation as a > bookcase, filing cabinet, or other product which if someone were to bump > into it, they would not be contacting the robot mast to due to the location > in the center of the top. > - the robot mast is part of a component and not part of the structure > of the product, and so the test should be done at the top of the base unit, > and no higher. > - there is text in the user manual that says not to push on the robot > mast when moving the product to new location > - and, if absolutely necessary, we an add do not push labels at the > top sides of the robot mast > > The NRTL rejected my rationale so I am looking to you to get your thoughts > on this before I press on with them. > > Do you think the test is applicable? > > You can respond here publicly or privately, or at > stev...@productehsconsulting.com <stevenb@prduct> > > Thanks in advance, > > Steve Brody > sgbr...@comcast.net > C - 603 617 9116 > ------------------------------ > > 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-PSTC@LISTSERV.IEEE.ORG > All emc-pstc postings are archived and searchable on the web at: > https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ > > Website: https://ewh.ieee.org/soc/pses/ > Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to > unsubscribe) <https://ewh.ieee.org/soc/pses/list.html> > List rules: https://ewh.ieee.org/soc/pses/listrules.html > > For help, send mail to the list administrators: > Mike Sherman at: msherma...@comcast.net > Rick Linford at: linf...@ieee.org > > For policy questions, send mail to: > Jim Bacher at: j.bac...@ieee.org > ------------------------------ > > To unsubscribe from the EMC-PSTC list, click the following link: > https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1 > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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