Re: [PSES] Applicability of the Machine Directive
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 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" 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 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 - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald: Peter Tarver, PE ptar...@ieee.org - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
Re: [PSES] Applicability of the Machine Directive
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 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 > > - > > 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 > > > 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 > Mike Cantwell > > For policy questions, send mail to: > Jim Bacher: > David Heald: - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
[PSES] Applicability of the Machine Directive
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 - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
[PSES] Wifi user settings
Dear colleagues. I understand that this may not be the correct forum to discuss this issue but I'm hoping someone may be able to answer my question or refer me to someone who can. We have a product with a built in Wi-Fi/Bluetooth module. For the USA, it is not permitted for the user to be able to select any other country Wi-Fi settings and any alterations must only be those permitted for the USA. e.g. channels & power settings. For other countries & territories we will have a country selector GUI for the user to control. Does anyone know if there are any other countries that necessitate the Wi-Fi settings to be fixed and not permit the user to select another country? Many thanks in advance. Ian McBurney Lead Compliance Engineer Allen & Heath Ltd. Kernick Industrial estate, Penryn, Cornwall. TR10 9LU. UK. Tel: 01326 372070 Email: ian.mcbur...@allen-heath.com Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. Any views expressed in this email are those of the individual and not necessarily those of the company. - 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 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 Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
