Re: [PSES] Machinery Directive 1.7.1
Hi Brian, Your quotation of Directive 2006/42/EC 1.7.1 falls short of telling the whole story. 1.7.1. actually states Any written or verbal information and warnings must be expressed in an officialCommunity language or languages, which may be determined in accordance with the Treaty by the MemberState in which the machinery is placed on the market and/or put into service and may be accompanied, onrequest, by versions in any other official Community language or languages understood by the operators. So each member state is (quite rightly in my opinion) at liberty to dictate what language(s) they require safety warnings to be in for equipment destined for that country. Frankly, what else would you expect? Textual warnings applied directly to equipment must be unequivocally clear and understood by the person using that equipment. Even for French people :-) Just my two-penneth. Tony Sent:Monday, June 09, 2014 at 7:35 PM From:Kunde, Brian brian_ku...@lecotc.com To:EMC-PSTC@LISTSERV.IEEE.ORG Subject:[PSES] Machinery Directive 1.7.1 Here we go again. On and off over the last 30 years I have bumped heads over having English Text on warning labels on Worldwide marketed products shipped to non-English speaking countries. I was given the impression that Europe was ok with English Text as long as it was explained in the translated manual in an official language of the country sold. For this reason, we have been transitioning to use the new ANSI Style Warning labels which includes a pictogram, warning symbol, and English Text. But now I have been informed that a third party lab in France has found our product to be non-compliant. Here is their reason: Warnings are not written in French on the machine and generate a confusion for operators. Is the third party lab correct and we need to remove all English text from warnings which include pictograms and symbols or are they misinterpreting the requirements of 1.7.1, which says, ...warning must be expressed in an official Community language... What does expressed mean? It technically doesnt say it has to be on the product, only expressed. Can expressed mean explained in the manual? This third party lab seemed to have misinterpreted several other requirements on the Machinery Directive so we are hoping this is another. I hate having to train third party labs in something they are getting paid to know. Any help, suggestions, or advice would be most appreciated. The Other Brian PS: Here is the entire text of section 1.7.1 of the MD for your reference. 1.7.1. Information and warnings on the machinery Information and warnings on the machinery should preferably be provided in the form of readily understandable symbols or pictograms. Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators. LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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 emcp...@radiusnorth.net 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
Re: [PSES] Machinery Directive 1.7.1
What I expect is that a warning label with pictograms and warning symbols which explains the warning good enough by themselves to not have to also be accompanied by translated text if I choose to include the English text on the label for another market. It is silly to think that if I get a marker and black out the English text on the label that only then would it be compliant to the all mighty Machinery Directive. I expect requirements to be not only clear and but also reasonable. Hey, I’m easy to get alone with. If I see a picture of a hand being ground up in some gears I don’t really care what language the text next is in. I wouldn’t be confused in the least. The Other Brian From: Anthony Thomson [mailto:ton...@europe.com] Sent: Tuesday, June 10, 2014 4:09 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Machinery Directive 1.7.1 Hi Brian, Your quotation of Directive 2006/42/EC 1.7.1 falls short of telling the whole story. 1.7.1. actually states Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators. So each member state is (quite rightly in my opinion) at liberty to dictate what language(s) they require safety warnings to be in for equipment destined for that country. Frankly, what else would you expect? Textual warnings applied directly to equipment must be unequivocally clear and understood by the person using that equipment. Even for French people :-) Just my two-penneth. Tony Sent: Monday, June 09, 2014 at 7:35 PM From: Kunde, Brian brian_ku...@lecotc.commailto:brian_ku...@lecotc.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive 1.7.1 Here we go again. On and off over the last 30 years I have bumped heads over having English Text on warning labels on Worldwide marketed products shipped to non-English speaking countries. I was given the impression that Europe was ok with English Text as long as it was explained in the translated manual in an official language of the country sold. For this reason, we have been transitioning to use the new ANSI Style Warning labels which includes a pictogram, warning symbol, and English Text. But now I have been informed that a third party lab in France has found our product to be non-compliant. Here is their reason: Warnings are not written in French on the machine and generate a confusion for operators. Is the third party lab correct and we need to remove all English text from warnings which include pictograms and symbols or are they misinterpreting the requirements of 1.7.1, which says, ...warning must be expressed in an official Community language... What does expressed mean? It technically doesn't say it has to be on the product, only expressed. Can expressed mean explained in the manual? This third party lab seemed to have misinterpreted several other requirements on the Machinery Directive so we are hoping this is another. I hate having to train third party labs in something they are getting paid to know. Any help, suggestions, or advice would be most appreciated. The Other Brian PS: Here is the entire text of section 1.7.1 of the MD for your reference. 1.7.1. Information and warnings on the machinery Information and warnings on the machinery should preferably be provided in the form of readily understandable symbols or pictograms. Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators. LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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.orgmailto: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
Re: [PSES] Machinery Directive 1.7.1
Thanks John. I kind of understand their point. In the US it is getting where the Spanish text on packaging is larger and bolder than the English. Sometimes you have to check all 6 sizes of a box to find the English. And the manuals are often large than the item you purchased with all the translation. Are kids used to learn French and German in schools, now they learn Spanish and Chinese. The Other Brian -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Monday, June 09, 2014 6:18 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Machinery Directive 1.7.1 In message 64D32EE8B9CBDD44963ACB076A5F6ABB0269B12B@Mailbox-Tech.lecotech.local, dated Mon, 9 Jun 2014, Kunde, Brian brian_ku...@lecotc.com writes: This has been a battle that has been going on for a long time. I wish we could come to some understanding. France is a special case. The Academie Française exists to protect the French language and has pressed for the protection to be embodied in a very powerful French law. But it is often not enforced, so when it is, it comes as a big surprise. The law is particularly aimed at keeping foreign words, especially English words, out of use in France. It's a losing battle, but it hasn't lost yet. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Machinery Directive 1.7.1
In message 64D32EE8B9CBDD44963ACB076A5F6ABB0269B30B@Mailbox-Tech.lecotech.local, dated Tue, 10 Jun 2014, Kunde, Brian brian_ku...@lecotc.com writes: It is silly to think that if I get a marker and black out the English text on the label that only then would it be compliant to the all mighty Machinery Directive. Not the MD but the French language law. You would indeed need to conceal the English; that's what the law is all about. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Machinery Directive 1.7.1
This is a conundrum that regularly leads to different labels for different markets. An approach that uses pictograms and symbols only that might well be acceptable in the EU might well be judged to be legally insufficient for the USA market because it lacks warning text. Then once you put text on a warning label, it is natural for users to want to understand that text in order to protect themselves, and so will reflexively want it translated---and I can't blame them. Mike Sherman Product Safety and Compliance Engineer Graco Inc. - Original Message - From: Brian Kunde brian_ku...@lecotc.com To: EMC-PSTC EMC-PSTC@LISTSERV.IEEE.ORG Sent: Tuesday, June 10, 2014 8:08:54 AM Subject: Re: [PSES] Machinery Directive 1.7.1 What I expect is that a warning label with pictograms and warning symbols which explains the warning good enough by themselves to not have to also be accompanied by translated text if I choose to include the English text on the label for another market. It is silly to think that if I get a marker and black out the English text on the label that only then would it be compliant to the all mighty Machinery Directive. I expect requirements to be not only clear and but also reasonable. Hey, I’m easy to get alone with. If I see a picture of a hand being ground up in some gears I don’t really care what language the text next is in. I wouldn’t be confused in the least. The Other Brian From: Anthony Thomson [mailto:ton...@europe.com] Sent: Tuesday, June 10, 2014 4:09 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Machinery Directive 1.7.1 Hi Brian, Your quotation of Directive 2006/42/EC 1.7.1 falls short of telling the whole story. 1.7.1. actually states Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators. So each member state is (quite rightly in my opinion) at liberty to dictate what language(s) they require safety warnings to be in for equipment destined for that country. Frankly, what else would you expect? Textual warnings applied directly to equipment must be unequivocally clear and understood by the person using that equipment. Even for French people :-) Just my two-penneth. Tony Sent: Monday, June 09, 2014 at 7:35 PM From: Kunde, Brian brian_ku...@lecotc.com To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Machinery Directive 1.7.1 Here we go again. On and off over the last 30 years I have bumped heads over having English Text on warning labels on Worldwide marketed products shipped to non-English speaking countries. I was given the impression that Europe was ok with English Text as long as it was explained in the translated manual in an official language of the country sold. For this reason, we have been transitioning to use the new ANSI Style Warning labels which includes a pictogram, warning symbol, and English Text. But now I have been informed that a third party lab in France has found our product to be non-compliant. Here is their reason: Warnings are not written in French on the machine and generate a confusion for operators. Is the third party lab correct and we need to remove all English text from warnings which include pictograms and symbols or are they misinterpreting the requirements of 1.7.1, which says, ...warning must be expressed in an official Community language... What does expressed mean? It technically doesn't say it has to be on the product, only expressed. Can expressed mean explained in the manual? This third party lab seemed to have misinterpreted several other requirements on the Machinery Directive so we are hoping this is another. I hate having to train third party labs in something they are getting paid to know. Any help, suggestions, or advice would be most appreciated. The Other Brian PS: Here is the entire text of section 1.7.1 of the MD for your reference. 1.7.1. Information and warnings on the machinery Information and warnings on the machinery should preferably be provided in the form of readily understandable symbols or pictograms. Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators. LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s
Re: [PSES] Machinery Directive 1.7.1
When I lived in Spain, we bought a new washing machine. It had a multi-language manual with the English buried towards the end. And, it only used pictograms on the machine. The pictograms were not understandable to us, and they were not well-explained in the manual. We had to experiment to know how to run it. So, have some compassion the local country's point of view. Rich - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] Machinery Directive 1.7.1
Here we go again. On and off over the last 30 years I have bumped heads over having English Text on warning labels on Worldwide marketed products shipped to non-English speaking countries. I was given the impression that Europe was ok with English Text as long as it was explained in the translated manual in an official language of the country sold. For this reason, we have been transitioning to use the new ANSI Style Warning labels which includes a pictogram, warning symbol, and English Text. But now I have been informed that a third party lab in France has found our product to be non-compliant. Here is their reason: Warnings are not written in French on the machine and generate a confusion for operators. Is the third party lab correct and we need to remove all English text from warnings which include pictograms and symbols or are they misinterpreting the requirements of 1.7.1, which says, ...warning must be expressed in an official Community language... What does expressed mean? It technically doesn't say it has to be on the product, only expressed. Can expressed mean explained in the manual? This third party lab seemed to have misinterpreted several other requirements on the Machinery Directive so we are hoping this is another. I hate having to train third party labs in something they are getting paid to know. Any help, suggestions, or advice would be most appreciated. The Other Brian PS: Here is the entire text of section 1.7.1 of the MD for your reference. 1.7.1. Information and warnings on the machinery Information and warnings on the machinery should preferably be provided in the form of readily understandable symbols or pictograms. Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators. LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Machinery Directive 1.7.1
In message 64D32EE8B9CBDD44963ACB076A5F6ABB0269B066@Mailbox-Tech.lecotech.local, dated Mon, 9 Jun 2014, Kunde, Brian brian_ku...@lecotc.com writes: Here we go again. On and off over the last 30 years I have bumped heads over having English Text on warning labels on Worldwide marketed products shipped to non-English speaking countries. I was given the impression that Europe was ok with English Text as long as it was explained in the translated manual in an official language of the country sold. For this reason, we have been transitioning to use the new ANSI Style Warning labels which includes a pictogram, warning symbol, and English Text. But now I have been informed that a third party lab in France has found our product to be non-compliant. Here is their reason: Warnings are not written in French on the machine and generate a confusion for operators. Is the third party lab correct and we need to remove all English text from warnings No, but under French law you probably do need to add the French words. This is one of those typical French laws that is enforced on the fourth Frewsday of every seventh month. which include pictograms and symbols or are they misinterpreting the requirements of 1.7.1, which says, ...warning must be expressed in an official Community language... What does expressed mean? 'given', 'printed', moulded-in' ,'raised on a casting', 'etched', 'stamped' ... you name it. It technically doesn't say it has to be on the product, I think it does: the heading of 1.7.1 says '.., on the machinery'. only expressed. Can expressed mean explained in the manual? This third party lab seemed to have misinterpreted several other requirements on the Machinery Directive so we are hoping this is another. I hate having to train third party labs in something they are getting paid to know. Any help, suggestions, or advice would be most appreciated. Does you French agent know whether the test house is invoking the French language law or just being picky? If they are invoking the law, you must conform. The Other Brian PS: Here is the entire text of section 1.7.1 of the MD for your reference. 1.7.1. Information and warnings on the machinery Information and warnings on the machinery should preferably be provided in the form of readily understandable symbols or pictograms. Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Machinery Directive 1.7.1
Brian, In this instance, the lab is correct. You’ve only partially quoted EHSR 1.7.1; in full it reads: Information and warnings on the machinery Information and warnings on the machinery should preferably be provided in the form of readily understandable symbols or pictograms. Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators.” The key words are which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market”. France will say it all has to be in French. The Commission Guide to the Directive says: The second sentence of section 1.7.1 applies when information is provided in the form of written words or text on the machinery, on a monitor screen or in the form of oral text provided, for example, by means of voice synthesiser. In such cases the information and warnings must be provided in the official language or languages of the Member States in which the machinery is placed on the market and/or put into service.“ You could have pictograms only, with the meaning explained in French (and other languages) in the manual, but you cannot have an explanation in English if it is not also provided in the local language. This may be a strict interpretation, and in practice, you may be able to ‘get away’ with a more relaxed approach, but the lab are correct in what they are saying. Bearing in mind that the French authorities may well take the same view, it would be wrong of them to take a more relaxed approach. Not the news you wanted, I’m afraid! Nick. On 9 Jun 2014, at 19:35, Kunde, Brian brian_ku...@lecotc.com wrote: Here we go again. On and off over the last 30 years I have bumped heads over having English Text on warning labels on Worldwide marketed products shipped to non-English speaking countries. I was given the impression that Europe was ok with English Text as long as it was explained in the translated manual in an official language of the country sold. For this reason, we have been transitioning to use the new ANSI Style Warning labels which includes a pictogram, warning symbol, and English Text. But now I have been informed that a third party lab in France has found our product to be non-compliant. Here is their reason: Warnings are not written in French on the machine and generate a confusion for operators. Is the third party lab correct and we need to remove all English text from warnings which include pictograms and symbols or are they misinterpreting the requirements of 1.7.1, which says, ...warning must be expressed in an official Community language... What does expressed mean? It technically doesn't say it has to be on the product, only expressed. Can expressed mean explained in the manual? This third party lab seemed to have misinterpreted several other requirements on the Machinery Directive so we are hoping this is another. I hate having to train third party labs in something they are getting paid to know. Any help, suggestions, or advice would be most appreciated. The Other Brian PS: Here is the entire text of section 1.7.1 of the MD for your reference. 1.7.1. Information and warnings on the machinery Information and warnings on the machinery should preferably be provided in the form of readily understandable symbols or pictograms. Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators. LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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
Re: [PSES] Machinery Directive 1.7.1
Would you interpret the requirements of section 1.7.1 to only apply to information pertaining to a warning? For instance, does the FCC Statement have to be translated when it does not pertain in Europe? How about English Text near a switch that says, Main? Is it good enough to show in the manual what the switch is for or do we also have to translate the word? If we changed the word Main to CB1 then that would be ok? Or just remove any reverence and just explain the function in the manual? How about I/O ports. I could make up some senseless squiggly lined symbol and explained its meaning in the manual and that is ok, but if I put the word Input near the port then I have to have it translated? Why can't I just explain in the manual what Input means which we do anyway? This has been a battle that has been going on for a long time. I wish we could come to some understanding. Thanks for everyone's comments. The Other Brian -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Monday, June 09, 2014 4:04 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Machinery Directive 1.7.1 In message 64D32EE8B9CBDD44963ACB076A5F6ABB0269B066@Mailbox-Tech.lecotech.local, dated Mon, 9 Jun 2014, Kunde, Brian brian_ku...@lecotc.com writes: Here we go again. On and off over the last 30 years I have bumped heads over having English Text on warning labels on Worldwide marketed products shipped to non-English speaking countries. I was given the impression that Europe was ok with English Text as long as it was explained in the translated manual in an official language of the country sold. For this reason, we have been transitioning to use the new ANSI Style Warning labels which includes a pictogram, warning symbol, and English Text. But now I have been informed that a third party lab in France has found our product to be non-compliant. Here is their reason: Warnings are not written in French on the machine and generate a confusion for operators. Is the third party lab correct and we need to remove all English text from warnings No, but under French law you probably do need to add the French words. This is one of those typical French laws that is enforced on the fourth Frewsday of every seventh month. which include pictograms and symbols or are they misinterpreting the requirements of 1.7.1, which says, ...warning must be expressed in an official Community language... What does expressed mean? 'given', 'printed', moulded-in' ,'raised on a casting', 'etched', 'stamped' ... you name it. It technically doesn't say it has to be on the product, I think it does: the heading of 1.7.1 says '.., on the machinery'. only expressed. Can expressed mean explained in the manual? This third party lab seemed to have misinterpreted several other requirements on the Machinery Directive so we are hoping this is another. I hate having to train third party labs in something they are getting paid to know. Any help, suggestions, or advice would be most appreciated. Does you French agent know whether the test house is invoking the French language law or just being picky? If they are invoking the law, you must conform. The Other Brian PS: Here is the entire text of section 1.7.1 of the MD for your reference. 1.7.1. Information and warnings on the machinery Information and warnings on the machinery should preferably be provided in the form of readily understandable symbols or pictograms. Any written or verbal information and warnings must be expressed in an official Community language or languages, which may be determined in accordance with the Treaty by the Member State in which the machinery is placed on the market and/or put into service and may be accompanied, on request, by versions in any other official Community language or languages understood by the operators. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com LECO
Re: [PSES] Machinery Directive 1.7.1
In message 64D32EE8B9CBDD44963ACB076A5F6ABB0269B12B@Mailbox-Tech.lecotech.local, dated Mon, 9 Jun 2014, Kunde, Brian brian_ku...@lecotc.com writes: This has been a battle that has been going on for a long time. I wish we could come to some understanding. France is a special case. The Academie Française exists to protect the French language and has pressed for the protection to be embodied in a very powerful French law. But it is often not enforced, so when it is, it comes as a big surprise. The law is particularly aimed at keeping foreign words, especially English words, out of use in France. It's a losing battle, but it hasn't lost yet. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid faciamus nisi sit? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
