Re: Product Safety: A Matter of Law or Litigation?
Well, my two cents says that it's not ONLY the voltage supply that decides safety by third parties. The safety effort we go through tests for hazards and shocks (all types): electrical, flame (really important), chemical, mechanical, ... to the end user. I would ask how and why your people are absolutely certain the testing is unnecessary? If there were some accident in the workplace with the product, God forbid, would your people be willing to have the finger pointed at them for selling untested equipment? I think a previous incident years ago with a central office in Chicago burning down is a prime example. And don't get into 1910.399 making it the only requirement for testing product because I believe it covers only that which has to get connected to the mains, i.e. that which requires an electrician to connect, if you read it to the absolute letter. Pluggable or battery powered equipment gets more sticky with 1910.399. Be careful going down that road. OTOH, there have been some cases where successful NRTL safety testing didn't make a hill of beans during litigation. But that was a case of deep pockets. No, I'm not a liberty to say which company it was but I'm willing to bet it wasn't the only one. - Doug McKean --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: Product Safety: A Matter of Law or Litigation?
Doug, When the LVD does not apply, the General Product Safety Directive (GPSD) does. Using EN 60950 to meet the requirements of the GPSD makes sense if your product falls under the scope of EN 60950. Regards, +=+ |Ronald R. Wellman|Voice : 408-345-8229 | |Agilent Technologies |FAX : 408-345-8630 | |5301 Stevens Creek Blvd.,|E-Mail: ron_well...@agilent.com| |Mailstop 54L-SQ |WWW : http://www.agilent.com | |Santa Clara, California 95052 USA| | +=+ | Common sense is the collection of prejudices acquired by age | | eighteen. - Albert Einstein | +=+ -Original Message- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 10:25 AM To: 'IEEE Forum' Subject: RE: Product Safety: A Matter of Law or Litigation? Alex, Thanks for your reply, and I agree. However, I don't need convincing. Here's the rub - EN60950 is a harmonized standard under the LVD. If the LVD does not apply to the product, then how can I argue that EN60950 applies to the product? Doug -Original Message- From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sent: Monday, June 04, 2001 12:14 PM To: 'Massey, Doug C.' Cc: 'IEEE Forum' Subject: RE: Product Safety: A Matter of Law or Litigation? Doug, As a general rule you should always have your products Safety Approved. This is showing Due Dilligence in that you have had the product safety evaluated. The latest EN60950:2000 covers ...mains powered or battery-powered ITE with a Rated Voltage not exceeding 600V i.e. there is no lower voltage limit! I hope this helps? Regards ALEX -Original Message- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 1:47 PM To: 'IEEE Forum' Subject:Product Safety: A Matter of Law or Litigation? Colleagues: I have been tasked with justifying the need for independent, third party evaluations of the safety of our company's products to applicable standards. Our company manufactures various ITE equipment, either handheld, battery powered devices, or ITE devices powered by vehicle batteries. In particular, the scope of the LVD states that it is applicable to devices rated 50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market these products in 35 countries; North America, the EU/EFTA, and others - in fact, pretty much all of the countries participating in the CB Scheme. In the US, OSHA regs justify this requirement, as our equipment is sold through direct channels solely for logistics applications - in other words, US workers will be using the equipment - it's not for general consumer use. TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to this subpart. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or ... In the EU/EFTA, the justification is not so easy. As I mentioned earlier, the products are exempt from the LVD. The General Product Safety Directive, and the Product Liability Directive, do not give me an easy justification, such as in the case of the OSHA regs stated in US Federal Code. My company has always had all products evaluated to the -950 standards, but has observed that other manufacturers of similar equipment do not have their products evaluated to applicable safety standards, and CE mark their products based on compliance to the EMC Directive, but not to the LVD. I would greatly appreciate your insights, opinions, and assistance with this question. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to:
RE: Product Safety: A Matter of Law or Litigation?
Doug - as Glenn stated, one of your other customers may have a requirement to obtain a third party safety approval that your device is installed in. With out an approval on your device it would make their job allot harder and the cost would probably increase. As the compliance engineer for a medical device manufacturer I have made it a requirement that items such as transformers, power supplies, motor, fuses, pc's, printers, etc. carry a third party approval. And for some components, if it goes into a device destined for Europe that it have one of the EU country approvals (or CE if applicable). I have told our engineers not to even consider bringing in such a component without an approval. It's not worth the time and dollars saved in the long run. As pointed out already - you are liable for what you sell! A third party approval may prove to very useful in such a case! -Original Message- From: Lesmeister, Glenn [mailto:glenn.lesmeis...@compaq.com] Sent: Monday, June 04, 2001 8:29 AM To: 'Massey, Doug C.'; 'IEEE Forum' Subject: RE: Product Safety: A Matter of Law or Litigation? Doug, I don't know your product line, but one thing that might be an issue is that some of your customers may use your products as part of their end products that do fall into the scope of the LVD. In order for them to meet the applicable requirements, they are going to need sufficient information and possibly test data from you to prove this. This may not provide the legal justification for your work, but it could be one heck of a customer requirement. Regards, Glenn Lesmeister Product Regulatory Compliance Compaq Computer Corp. Tel: 281-514-5163 20555 SH 249, MS60607 Fax: 281-514-8029 Houston, TX 77070-2698 Pgr: 713-786-4930 glenn.lesmeis...@compaq.com -Original Message- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 7:47 AM To: 'IEEE Forum' Subject:Product Safety: A Matter of Law or Litigation? Colleagues: I have been tasked with justifying the need for independent, third party evaluations of the safety of our company's products to applicable standards. Our company manufactures various ITE equipment, either handheld, battery powered devices, or ITE devices powered by vehicle batteries. In particular, the scope of the LVD states that it is applicable to devices rated 50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market these products in 35 countries; North America, the EU/EFTA, and others - in fact, pretty much all of the countries participating in the CB Scheme. In the US, OSHA regs justify this requirement, as our equipment is sold through direct channels solely for logistics applications - in other words, US workers will be using the equipment - it's not for general consumer use. TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to this subpart. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or ... In the EU/EFTA, the justification is not so easy. As I mentioned earlier, the products are exempt from the LVD. The General Product Safety Directive, and the Product Liability Directive, do not give me an easy justification, such as in the case of the OSHA regs stated in US Federal Code. My company has always had all products evaluated to the -950 standards, but has observed that other manufacturers of similar equipment do not have their products evaluated to applicable safety standards, and CE mark their products based on compliance to the EMC Directive, but not to the LVD. I would greatly appreciate your insights, opinions, and assistance with this question. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list
Presentation Download available
To all interested parties, The May meeting Practical Analysis of Lossy Transmission Lines is available for download from the Giga Test Labs website. http://www.gigatest.com Thank you Charles Grasso RMCEMC Vice-Chair --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: Product Safety: A Matter of Law or Litigation?
EN60950 would apply, under the general product safety directive, however, you would not be required to CE mark the item. The directive is Council Directive 92/59/EEC of 29 June 1992 on general product safety http://europa.eu.int/comm/consumers/policy/developments/prod_safe/ps02_en. html In specific... Article 4 1. Where there are no specific Community provisions governing the safety of the products in question, a product shall be deemed safe when it conforms to the specific rules of national law of the Member State in whose territory the product is in circulation, such rules being drawn up in conformity with the Treaty, and in particular Articles 30 and 36 thereof, and laying down the health and safety requirements which the product must satisfy in order to be marketed. 2. In the absence of specific rules as referred to in paragraph 1, the conformity of a product to the general safety requirement shall be assessed having regard to voluntary national standards giving effect to a European standard or, where they exist, to Community technical specifications or, failing these, to standards drawn up in the Member State in which the product is in circulation, or to the codes of good practice in respect of health and safety in the sector concerned or to the state of the art and technology and to the safety which consumers may reasonably expect. Per article 2, you are still required to conform with a European standard, or community technical specification, or member state standard, or to codes of good practice (i.e., industry standards), in that order of preference. Best regards, Frank West ---[From the computer of...]- Mr. Frank West Sr. Engineer TUV Rheinland 7853 SW Cirrus Dr. Beaverton, OR. 97008 T 503-469-8880 Ext 205 F 503-469-8881 fw...@us.tuv.com Massey, Doug C. masse...@ems-t.com To: 'IEEE Forum' emc-p...@majordomo.ieee.org Sent by: cc: owner-emc-pstc@majordomSubject: RE: Product Safety: A Matter of Law or Litigation? o.ieee.org 06/04/2001 10:24 AM Please respond to Massey, Doug C.
Re: Product Safety: A Matter of Law or Litigation?
FD27170820E5DD42B1D5B13DE96A775404BF80@mrl01, Massey, Doug C. masse...@ems-t.com inimitably wrote: If the LVD does not apply to the product, then how can I argue that EN60950 applies to the product? Because the scope of the standard is quite independent of the scope of the LVD. -- Regards, John Woodgate, OOO - Own Opinions Only. Phone +44 (0)1268 747839 Fax +44 (0)1268 777124. http://www.jmwa.demon.co.uk Why not call a vertically- applied manulo-pedally-operated quasi-planar chernozem-penetrating and excavating implement a SPADE? --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: Product Safety: A Matter of Law or Litigation?
Hi Doug, I believe the RTTE calls up the full requirements of the LVD but without the voltage limits. If the RTTE directive applies to your product, I think the link might be there. My opinion and not that of my employer. Regards, Kaz Gawrzyjal kazimier_gawrzy...@dell.com -Original Message- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 12:25 PM To: 'IEEE Forum' Subject: RE: Product Safety: A Matter of Law or Litigation? Alex, Thanks for your reply, and I agree. However, I don't need convincing. Here's the rub - EN60950 is a harmonized standard under the LVD. If the LVD does not apply to the product, then how can I argue that EN60950 applies to the product? Doug -Original Message- From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sent: Monday, June 04, 2001 12:14 PM To: 'Massey, Doug C.' Cc: 'IEEE Forum' Subject: RE: Product Safety: A Matter of Law or Litigation? Doug, As a general rule you should always have your products Safety Approved. This is showing Due Dilligence in that you have had the product safety evaluated. The latest EN60950:2000 covers ...mains powered or battery-powered ITE with a Rated Voltage not exceeding 600V i.e. there is no lower voltage limit! I hope this helps? Regards ALEX -Original Message- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 1:47 PM To: 'IEEE Forum' Subject:Product Safety: A Matter of Law or Litigation? Colleagues: I have been tasked with justifying the need for independent, third party evaluations of the safety of our company's products to applicable standards. Our company manufactures various ITE equipment, either handheld, battery powered devices, or ITE devices powered by vehicle batteries. In particular, the scope of the LVD states that it is applicable to devices rated 50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market these products in 35 countries; North America, the EU/EFTA, and others - in fact, pretty much all of the countries participating in the CB Scheme. In the US, OSHA regs justify this requirement, as our equipment is sold through direct channels solely for logistics applications - in other words, US workers will be using the equipment - it's not for general consumer use. TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to this subpart. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or ... In the EU/EFTA, the justification is not so easy. As I mentioned earlier, the products are exempt from the LVD. The General Product Safety Directive, and the Product Liability Directive, do not give me an easy justification, such as in the case of the OSHA regs stated in US Federal Code. My company has always had all products evaluated to the -950 standards, but has observed that other manufacturers of similar equipment do not have their products evaluated to applicable safety standards, and CE mark their products based on compliance to the EMC Directive, but not to the LVD. I would greatly appreciate your insights, opinions, and assistance with this question. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc
RE: Product Safety: A Matter of Law or Litigation?
Alex, Thanks for your reply, and I agree. However, I don't need convincing. Here's the rub - EN60950 is a harmonized standard under the LVD. If the LVD does not apply to the product, then how can I argue that EN60950 applies to the product? Doug -Original Message- From: Alex McNeil [mailto:alex.mcn...@ingenicofortronic.com] Sent: Monday, June 04, 2001 12:14 PM To: 'Massey, Doug C.' Cc: 'IEEE Forum' Subject: RE: Product Safety: A Matter of Law or Litigation? Doug, As a general rule you should always have your products Safety Approved. This is showing Due Dilligence in that you have had the product safety evaluated. The latest EN60950:2000 covers ...mains powered or battery-powered ITE with a Rated Voltage not exceeding 600V i.e. there is no lower voltage limit! I hope this helps? Regards ALEX -Original Message- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 1:47 PM To: 'IEEE Forum' Subject:Product Safety: A Matter of Law or Litigation? Colleagues: I have been tasked with justifying the need for independent, third party evaluations of the safety of our company's products to applicable standards. Our company manufactures various ITE equipment, either handheld, battery powered devices, or ITE devices powered by vehicle batteries. In particular, the scope of the LVD states that it is applicable to devices rated 50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market these products in 35 countries; North America, the EU/EFTA, and others - in fact, pretty much all of the countries participating in the CB Scheme. In the US, OSHA regs justify this requirement, as our equipment is sold through direct channels solely for logistics applications - in other words, US workers will be using the equipment - it's not for general consumer use. TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to this subpart. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or ... In the EU/EFTA, the justification is not so easy. As I mentioned earlier, the products are exempt from the LVD. The General Product Safety Directive, and the Product Liability Directive, do not give me an easy justification, such as in the case of the OSHA regs stated in US Federal Code. My company has always had all products evaluated to the -950 standards, but has observed that other manufacturers of similar equipment do not have their products evaluated to applicable safety standards, and CE mark their products based on compliance to the EMC Directive, but not to the LVD. I would greatly appreciate your insights, opinions, and assistance with this question. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher:
RE: Product Safety: A Matter of Law or Litigation?
Doug, As a general rule you should always have your products Safety Approved. This is showing Due Dilligence in that you have had the product safety evaluated. The latest EN60950:2000 covers ...mains powered or battery-powered ITE with a Rated Voltage not exceeding 600V i.e. there is no lower voltage limit! I hope this helps? Regards ALEX -Original Message- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 1:47 PM To: 'IEEE Forum' Subject:Product Safety: A Matter of Law or Litigation? Colleagues: I have been tasked with justifying the need for independent, third party evaluations of the safety of our company's products to applicable standards. Our company manufactures various ITE equipment, either handheld, battery powered devices, or ITE devices powered by vehicle batteries. In particular, the scope of the LVD states that it is applicable to devices rated 50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market these products in 35 countries; North America, the EU/EFTA, and others - in fact, pretty much all of the countries participating in the CB Scheme. In the US, OSHA regs justify this requirement, as our equipment is sold through direct channels solely for logistics applications - in other words, US workers will be using the equipment - it's not for general consumer use. TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to this subpart. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or ... In the EU/EFTA, the justification is not so easy. As I mentioned earlier, the products are exempt from the LVD. The General Product Safety Directive, and the Product Liability Directive, do not give me an easy justification, such as in the case of the OSHA regs stated in US Federal Code. My company has always had all products evaluated to the -950 standards, but has observed that other manufacturers of similar equipment do not have their products evaluated to applicable safety standards, and CE mark their products based on compliance to the EMC Directive, but not to the LVD. I would greatly appreciate your insights, opinions, and assistance with this question. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
Re: Product Safety: A Matter of Law or Litigation?
FD27170820E5DD42B1D5B13DE96A775404BF7F@mrl01, Massey, Doug C. masse...@ems-t.com inimitably wrote: In the EU/EFTA, the justification is not so easy. As I mentioned earlier, the products are exempt from the LVD. The General Product Safety Directive, and the Product Liability Directive, do not give me an easy justification, such as in the case of the OSHA regs stated in US Federal Code. My company has always had all products evaluated to the -950 standards, but has observed that other manufacturers of similar equipment do not have their products evaluated to applicable safety standards, and CE mark their products based on compliance to the EMC Directive, but not to the LVD. You can have them 3rd-party tested to EN60950 by a test-house if you want. There is nothing to stop you doing that voluntarily, even though the LVD is not applicable. If they all pass, you have a problem! You can't learn anything from passes. If you get a few failures, you can learn from them and in due course dispense with 3rd-party testing if you wish. -- Regards, John Woodgate, OOO - Own Opinions Only. Phone +44 (0)1268 747839 Fax +44 (0)1268 777124. http://www.jmwa.demon.co.uk Why not call a vertically- applied manulo-pedally-operated quasi-planar chernozem-penetrating and excavating implement a SPADE? --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall,
RE: Product Safety: A Matter of Law or Litigation?
Doug, my recommendation is to obtain approval marks for the US and Canada due to the potential of litigation. You will have shown due diligence which may assist in limiting any liability issues. In the EU, however, they have no-fault liability - if someone is hurt by a defect in your equipment, you are at fault no matter what approvals you have. A safety approval in Europe is for useful for marketing purposes only. Richard Woods -- From: Massey, Doug C. [SMTP:masse...@ems-t.com] Sent: Monday, June 04, 2001 8:47 AM To: 'IEEE Forum' Subject: Product Safety: A Matter of Law or Litigation? Colleagues: I have been tasked with justifying the need for independent, third party evaluations of the safety of our company's products to applicable standards. Our company manufactures various ITE equipment, either handheld, battery powered devices, or ITE devices powered by vehicle batteries. In particular, the scope of the LVD states that it is applicable to devices rated 50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market these products in 35 countries; North America, the EU/EFTA, and others - in fact, pretty much all of the countries participating in the CB Scheme. In the US, OSHA regs justify this requirement, as our equipment is sold through direct channels solely for logistics applications - in other words, US workers will be using the equipment - it's not for general consumer use. TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to this subpart. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or ... In the EU/EFTA, the justification is not so easy. As I mentioned earlier, the products are exempt from the LVD. The General Product Safety Directive, and the Product Liability Directive, do not give me an easy justification, such as in the case of the OSHA regs stated in US Federal Code. My company has always had all products evaluated to the -950 standards, but has observed that other manufacturers of similar equipment do not have their products evaluated to applicable safety standards, and CE mark their products based on compliance to the EMC Directive, but not to the LVD. I would greatly appreciate your insights, opinions, and assistance with this question. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send
RE: Product Safety: A Matter of Law or Litigation?
Doug, I don't know your product line, but one thing that might be an issue is that some of your customers may use your products as part of their end products that do fall into the scope of the LVD. In order for them to meet the applicable requirements, they are going to need sufficient information and possibly test data from you to prove this. This may not provide the legal justification for your work, but it could be one heck of a customer requirement. Regards, Glenn Lesmeister Product Regulatory Compliance Compaq Computer Corp. Tel: 281-514-5163 20555 SH 249, MS60607 Fax: 281-514-8029 Houston, TX 77070-2698 Pgr: 713-786-4930 glenn.lesmeis...@compaq.com -Original Message- From: Massey, Doug C. [mailto:masse...@ems-t.com] Sent: Monday, June 04, 2001 7:47 AM To: 'IEEE Forum' Subject:Product Safety: A Matter of Law or Litigation? Colleagues: I have been tasked with justifying the need for independent, third party evaluations of the safety of our company's products to applicable standards. Our company manufactures various ITE equipment, either handheld, battery powered devices, or ITE devices powered by vehicle batteries. In particular, the scope of the LVD states that it is applicable to devices rated 50-1000Vac or 75-1500Vdc; most of our products are below 75Vdc. We market these products in 35 countries; North America, the EU/EFTA, and others - in fact, pretty much all of the countries participating in the CB Scheme. In the US, OSHA regs justify this requirement, as our equipment is sold through direct channels solely for logistics applications - in other words, US workers will be using the equipment - it's not for general consumer use. TITLE 29--LABOR PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS--Table of Contents Subpart S--Electrical Sec. 1910.399 Definitions applicable to this subpart. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory; or (ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or ... In the EU/EFTA, the justification is not so easy. As I mentioned earlier, the products are exempt from the LVD. The General Product Safety Directive, and the Product Liability Directive, do not give me an easy justification, such as in the case of the OSHA regs stated in US Federal Code. My company has always had all products evaluated to the -950 standards, but has observed that other manufacturers of similar equipment do not have their products evaluated to applicable safety standards, and CE mark their products based on compliance to the EMC Directive, but not to the LVD. I would greatly appreciate your insights, opinions, and assistance with this question. Doug Massey Safety Approvals Engineer LXE, Inc. Norcross, GA., USA Ph. (770) 447-4224 x3607 FAX (770) 447-6928 e-mail: masse...@lxe.com Cruise our website at: http:\\www.lxe.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual Conference Hall, --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on Virtual
