RE: Railway Crossing Gate

1999-11-12 Thread Alan Brewster

Rich,
Your story reminded me of a strange, but true event, that happened when
I was still in the UK. I was living near a small town called Blythe
Bridge, where the railway line crosses the main street at a very flat
angle. This meant that the length of the crossing barriers was long,
approximately 35 feet.
For some strange reason, when the barriers were down pedestrians would
walk half way across the road, wait for the train to pass, watch it
arrive in the adjacent station, then continue crossing the road. At
certain times of the day two trains would pass, one in each direction,
and great excitement would erupted. One day two seniors were stopped and
one of them looped the end of his dog's lead around the end of the
lowered barrier. The two trains duly passed and in the drama of the
moment the poor dog was overlooked for an instant. The gates lifted and
with the length of the gate the tip velocity was significant. 
Local lore has it that the dog, a small rat like terrier, was found
three counties away.
The serious point is that the only way to avoid the same thing happening
again. or to a child, was to fit remote TV cameras and revert to manual
control.   

Alan
____
_
Alan Brewster
Compliance Certification Services
1366 Bordeaux Drive
Sunnyvale, CA 94089-1005
Tel: 408-752-8166 ext. 122
Fax: 408-752-8168
e-mail: abrews...@ccsemc.com
http://www.ccsemc.com



-Original Message-
From: Rich Nute [mailto:ri...@sdd.hp.com]
Sent: Thursday, November 11, 1999 2:48 PM
To: abrews...@ccsemc.com
Cc: rl...@concentric.net; emc-p...@majordomo.ieee.org
Subject: Re: Railway Crossing Gate








>   Will a child hold on to the gate as it opens in order to=
>   "ride" it and if so what prevents injury. 

As I child, I was a paper boy.  The papers were delivered
to our town by train.  We picked up our route package at 
the train station as it was thrown from the baggage car
and then we delivered the papers.

Normally, we were at the train station before the train
arrived.  I remember one occasion when the Greyhound bus
that crosses the tracks at the station had stopped a foot
or so beyond the crossing gate (but well away from the
tracks).  The gate came down and struck the bus on its 
roof, and then rested there.  Small dent in the metal
roof.

This was exciting stuff for us paper boys!

We found that one paper boy, approximate age 10, pushing 
down on the counterweights, could easily lift the gate 
above the roof of the bus.

I'm not sure if one of us could ride the gate on its
upswing.  We'd never do it because we'd have to do it in
front of 4 lanes of stopped traffic.  I'm not at all sure 
that the gate would lift a 10-year-old.  

Anyway, it never crossed our minds.

But, I do know that once the gate was up, a 10-year-old
boy could not force the gate down by pushing on the
counterweights.  It was clearly locked in the upright
position.


Best regards,
Rich




-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes).  For help, send mail to ed.pr...@cubic.com,
jim_bac...@monarch.com, ri...@sdd.hp.com, or
roger.volgst...@compaq.com (the list administrators).


-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes).  For help, send mail to ed.pr...@cubic.com,
jim_bac...@monarch.com, ri...@sdd.hp.com, or
roger.volgst...@compaq.com (the list administrators).



RE: Railway Crossing Gate

1999-11-11 Thread Alan Brewster
Richard,
The Machinery Directive is applicable and would definitely be concerned
with the control electronics from a number of points of view. The
interesting issue with these types of products are the "Human Nature"
hazards. Will a child hold on to the gate as it opens in order to "ride"
it and if so what prevents injury. Single fault and interlock issues are
also priorities as improper actuation exposes the user group to hazards.

There is a possibility that you may actually need the involvement of a
Notified Body as under certain circumstance the equipment could be
defined as a safety device.
Maybe you could offer some more details for comment.

Alan 
____
_ 
Alan Brewster 
Compliance Certification Services 
1366 Bordeaux Drive 
Sunnyvale, CA 94089-1005 
Tel: 408-752-8166 ext. 122 
Fax: 408-752-8168 
e-mail: abrews...@ccsemc.com 
http://www.ccsemc.com 

-Original Message-
From: Richard Lanzillotto [mailto:rl...@concentric.net]
Sent: Thursday, November 11, 1999 10:24 AM
To: emc-p...@majordomo.ieee.org
Subject: Railway Crossing Gate


Is the machinery directive applicable for the such a gate
 and it's control electronics? Appreciate any comments.
 
Rich Lanzillotto
rl...@concentric.net



RE: Hot Surface. Hot air.

1999-10-07 Thread Alan Brewster

Israel, 
There are only three temperatures to worry about: Hot, Damn Hot and
Ouch. For something approaching a definition look in BS 4086
Recommendations for Maximum Surface Temperatures of Heated Domestic
Equipment. The other excellent standard for defining the issue is EN
563:1994 Safety of machinery - Temperatures of touchable surfaces -
Ergonomics data to establish temperature limit values for hot surfaces. 
The former standard has been used for many years in the UK by
enforcement officers to pursue prosecutions, which is where I came
across it. The latter standard is listed as a Machinery Directive
document and it contains some really useful graphs of exposure time vs.
temp. I refer to these regularly when testing equipment in-situ,
especially laboratory and semiconductor manufacturing systems as many
standards do not leave room for non-specified applications, or are
vague.
Your point about hot air streams is interesting and you may want to
refer to the EN 60335 family of standards for guidance. As an ex-cooking
product designer, the temperature of an air stream was not a regulatory
requirement. It is difficult to measure accurately and hence was not
called up in standards. It was an issue with respect to users, however. 

Alan

_
Alan Brewster
Compliance Certification Services
1366 Bordeaux Drive
Sunnyvale, CA 94089-1005
Tel: 408-752-8166 ext. 122
Fax: 408-752-8168
e-mail: abrews...@ccsemc.com
http://www.ccsemc.com


> -Original Message-
> From: Israel Yeshurun [SMTP:israel_yeshu...@stcl.scitex.com]
> Sent: Thursday, October 07, 1999 3:43 AM
> To:   'emc-p...@ieee.org'
> Subject:  Hot  Surface. Hot air.
> 
> 
> 
>  Dear Group Fellows
> 
>  I would like to raise the following two issues:
> 
>1)   UL1950 / EN60950  Safety standards, Subclause 5.1 - Heating,
> Table
> 16 part 2, specify permissible temperature rise for external
> surfaces of
> equipment in Operator Access Area.. 
> For external surfaces, made of metal which may be touched, it
> allows
> temperature rise of 45 degrees Kelvin, assuming ambient temperature of
> 25
> degrees Celsius it allows  surface temperature of  70 degrees Celsius
> = 158
> degrees Fahrenheit !
>Note (4) in this table applies to external surfaces that are not
> likely
> to be touched in normal use and measure less than 50 mm, in this case
> it
> allows a temperature rise of  75 degrees K, that under 25 degrees C
> ambient
> allows 
> 100 degrees C = 212 degrees F !!
>  
> Now, 70 degrees C for external equipment surface that may be
> touched
> seems pretty high to me. 100 degrees C metal surface will, I believe,
> cause
> a burn to that part of the human body that touched it.  
> So maybe my interpretation  is not true ??and,  can someone
> point
> another regulatory source for Hot surface permissible temperature ? 
> 
>   2)   Regarding Hot air flowing out of equipment, in UL1950 / EN60950
> I
> could not find a requirement or limit for the maximum permissible
> temperature for it,  Can someone point another regulatory source for
> Hot air
> permissible temperature ?
> 
> Note: The equipment I relate to is  ITE or Office,  but
> information from
> Machinery standards or other sources is welcome !
> 
>  
> Many Thanks 
> Israel Yeshurun
> 
> -
> This message is coming from the emc-pstc discussion list.
> To cancel your subscription, send mail to majord...@ieee.org
> with the single line: "unsubscribe emc-pstc" (without the
> quotes).  For help, send mail to ed.pr...@cubic.com,
> jim_bac...@monarch.com, ri...@sdd.hp.com, or
> roger.volgst...@compaq.com (the list administrators).
> 

-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes).  For help, send mail to ed.pr...@cubic.com,
jim_bac...@monarch.com, ri...@sdd.hp.com, or
roger.volgst...@compaq.com (the list administrators).



RE: "Kill" Switch Requirements

1999-09-20 Thread Alan Brewster

The Machinery Directive has a number of requirements for applying an
Emergency Stop Button, which is what I think you are referring to. This
device is a latching red "mushroom" or "palm" style button that removes
power to equipment or appropriate actuators. It will also have a yellow
background. 
This requirement is referenced in EN 61010-1:1993 under clause 6.12.2.3
and is pertinent to equipment with moving parts. 
The criteria for making a decision for fitting an Emergency Stop Button
will be based upon your Hazard Analysis and Risk Assessment that is
required for equipment under the Machinery Directive. A good standard to
follow is EN 1050:1996 Safety of machinery - Principles for risk
assessment. In essence if there is any risk of injury to an operator or
maintenance technician, a person excluded from the scope of EN 61010-1,
from equipment an Emergency Stop Button, or Buttons, should be fitted.
Interestingly enough, as this is a transport device it implies that
linking the E-Stop to up-stream and down-stream equipment may be
required.

Alan
____
_
Alan Brewster
Compliance Certification Services
1366 Bordeaux Drive
Sunnyvale, CA 94089-1005
Tel: 408-752-8166 ext. 122
Fax: 408-752-8168
e-mail: abrews...@ccsemc.com
http://www.ccsemc.com



> -Original Message-
> From: marti...@pebio.com [SMTP:marti...@pebio.com]
> Sent: Friday, September 17, 1999 1:27 PM
> To:   emc-p...@majordomo.ieee.org
> Subject:  "Kill" Switch Requirements
> 
> 
> 
> 
> Is anyone aware of any requirements anywhere in the world stating that
> a device
> that is considered a "transport mechanism" must have a red kill switch
> or button
> on the unit.
> 
> This question came from an associate of mine while talking with
> potential
> customers in Scotland.
> We certify our product to the Low Voltage Directive using EN 61010.  I
> am not
> familiar with such a requirement for the LVD.  Does the Machinery
> Directive have
> such a requirement??
> 
> Any comments are appreciated.
> 
> Regards
> 
> Joe Martin
> EMC/Product Safety Engineer
> P.E. Biosystems
> marti...@pebio.com
> 
> 
> 
> -
> This message is coming from the emc-pstc discussion list.
> To cancel your subscription, send mail to majord...@ieee.org
> with the single line: "unsubscribe emc-pstc" (without the
> quotes).  For help, send mail to ed.pr...@cubic.com,
> jim_bac...@monarch.com, ri...@sdd.hp.com, or
> roger.volgst...@compaq.com (the list administrators).
> 

-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes).  For help, send mail to ed.pr...@cubic.com,
jim_bac...@monarch.com, ri...@sdd.hp.com, or
roger.volgst...@compaq.com (the list administrators).



RE: LVD and notified bodies

1999-09-04 Thread Alan Brewster

The Low Voltage Directive Notified Bodies do not have a collective
forum, unlike the Machinery or EMC folks. The only way of sorting out
differences is in court and a judge will decide. I have had the
interesting experience where an unscrupulous client had a product tested
in a Notified Body lab, that I was the signatory for, after having had a
failure in the other Notified Body Lab that I was responsible for. This
was as a result of a Trading Standards complaint. The sample submitted
by the client was given a different name to prevent our internal systems
picking up the impending conflict. It was done to deliberately discredit
the Notified Body process. The interesting thing is that the product had
originally been tested by another Notified Body and he had commented on
the subsequent failure point but had not pursued it.

Alan

_
Alan Brewster
Compliance Certification Services
1366 Bordeaux Drive
Sunnyvale, CA 94089-1005
Tel: 408-752-8166 ext. 122
Fax: 408-752-8168
e-mail: abrews...@ccsemc.com
http://www.ccsemc.com



> -Original Message-
> From: Kevin Harris [SMTP:harr...@dscltd.com]
> Sent: Thursday, September 02, 1999 1:24 PM
> To:   EMC-PSTC (E-mail)
> Subject:  LVD and notified bodies
> 
> 
> Hello Group,
> 
> Here are some LVD protocol issues for you. If you had a product type
> tested
> by one notified body then at some later time a second notified body
> (doing
> market surveillance) determines that they feel the product does not
> meet the
> LVD ( We are assuming the type tested product was the same as the one
> examined by the second notified body i.e. This is an interpretation
> issue
> only) Who rules here? Can the second notified body deny the first's
> interpretation? Who could give an "official" interpretation? (the
> Commission?)
> 
> Thanks
>  
> 
> Best Regards,
> 
> 
> Kevin Harris
> Manager, Approval Services
> Digital Security Controls
> 1645 Flint Road
> Downsview, Ontario
> CANADA
> M3J 2J6
> 
> Tel   416 665 8460 Ext. 2378
> Fax 416 665 7753 
> 
> 
> -
> This message is coming from the emc-pstc discussion list.
> To cancel your subscription, send mail to majord...@ieee.org
> with the single line: "unsubscribe emc-pstc" (without the
> quotes).  For help, send mail to ed.pr...@cubic.com,
> jim_bac...@monarch.com, ri...@sdd.hp.com, or
> roger.volgst...@compaq.com (the list administrators).
> 

-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes).  For help, send mail to ed.pr...@cubic.com,
jim_bac...@monarch.com, ri...@sdd.hp.com, or
roger.volgst...@compaq.com (the list administrators).



RE: Equipment designed and manufactured for use in-house

1999-08-13 Thread Alan Brewster

Carlos,

As you are in the UK you might want to talk to your Home Authority
Trading Standards Officer. Many of them can carry out screen test level
assessments at almost no cost. They will also give advice on
interpreting areas like this for free. A word of caution, however, get
their feedback in writing. You can then use this as part of your defence
if ever necessary.

It is two years since I left the UK, do the Duckworths still run the
Rovers Return?

Alan

_
Alan Brewster
Compliance Certification Services
1366 Bordeaux Drive
Sunnyvale, CA 94089-1005
Tel: 408-752-8166 ext. 122
Fax: 408-752-8168
e-mail: abrews...@ccsemc.com
http://www.ccsemc.com



> -Original Message-
> From: carlos.perk...@eu.effem.com [SMTP:carlos.perk...@eu.effem.com]
> Sent: Thursday, August 12, 1999 11:22 PM
> To:   emc-p...@majordomo.ieee.org
> Subject:  Equipment designed and manufactured for use in-house
> 
> 
> Dear All,
> 
> A question from UK:
> 
> Does anyone have a strategy for handling the Low Voltage and EMC
> Directive
> requirements relating to equipment made for use in-house?
> 
> By this, I mean test boxes, power supplies, break-out boxes, etc.
> 
> These products are not meant to be offered for sale (ie not 'placed on
> the
> market'), but have been 'taken into service' by being switched on and
> used.
> I think, therefore, that the protection requirements of the Directives
> must
> be met, but CE marking is not necessary.
> 
> In terms of Safety, I think EN 60950 and EN 61010-1 are relevant.
> 
> Does anyone have a view on this?
> 
> Cheers,
> 
> Carlos Perkins
> 
> 
> 
> -
> This message is coming from the emc-pstc discussion list.
> To cancel your subscription, send mail to majord...@ieee.org
> with the single line: "unsubscribe emc-pstc" (without the
> quotes).  For help, send mail to ed.pr...@cubic.com,
> jim_bac...@monarch.com, ri...@sdd.hp.com, or
> roger.volgst...@compaq.com (the list administrators).
> 

-
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes).  For help, send mail to ed.pr...@cubic.com,
jim_bac...@monarch.com, ri...@sdd.hp.com, or
roger.volgst...@compaq.com (the list administrators).



RE: year in which the CE mark was affixed" marked on Declaration of Conformity

1999-08-06 Thread Alan Brewster

Paul,
Thank you for your observation. The situation in many sectors is as you
say. There are exceptions and the requirements are stated to cover those
times when there is a lag between declaring the product compliant and
taking it to market.
The other reason why you should not mix the use of 'dates and digits' is
more pragmatic. If you do not separately identify the last two digits
then you are in breach of the requirements of the Directive. This then
means that you could be prosecuted, although, it is unlikely that much
of a case could be made out of this. The enforcement person could,
however, use this to start an investigation into your other
documentation and ultimately your equipment on the basis of 'reasonable
doubt'. This then involves a significant amount of activity and in most
cases cost. The enforcement officer could, as a precautionary measure,
prevent all shipments of your products to Europe until the issues is
resolved.
My experience working for many enforcement agencies in the UK is that
this is a people business. The career prospects for junior Trading
Standards and Health and Safety Executive officers only improve if they
can demonstrate a keen interest in obtaining cautions or prosecutions.
The advice that I have always passed on, and which I received from a
senior Trading Standards Officer, is never invite investigation unless
you have a reason to do so.

> -Original Message-
> From: Paul J Smith [SMTP:paul_j_sm...@notes.teradyne.com]
> Sent: Thursday, August 05, 1999 6:10 AM
> To:   Alan Brewster
> Cc:   'Chuck Seyboldt'; EMC-PSTC Discussion Group
> Subject:  RE: year in which the CE mark was affixed" marked on
> Declaration of Conformity
> 
> Alan,
> 
> Why not use the dated signature of the authorized senior personnel on
> the D of C
> meet this year code specification on the document?It would seem
> correct to
> use that date since it generally is the first time that the product is
> CE marked
> to be placed on the EU market.  Please comment
> 
> Paul J. Smith
> Compliance Engineer
> Teradyne, Inc.
> Boston
> 
> 
> 
> 
> Alan Brewster  on 08/04/99 05:51:38 PM
> 
> Please respond to Alan Brewster 
> 
> To:   "'Chuck Seyboldt'" , EMC-PSTC Discussion Group
>   
> cc:(bcc: Paul J Smith/Bos/Teradyne)
> Subject:  RE: The meaning of "Affixed"
> 
> 
> 
> 
> 
> Greetings,
> 
> The need to have "the last two digits of the year in which the CE mark
> was affixed" marked on the Declaration of Conformity is simply to make
> the job of enforcement officers simpler. It is bourne out of the very
> nature and application of the LVD in that there are many electrical
> products that have been in serial production since the introduction of
> the Directive in the early seventies. During my four years as a
> Notified
> Body signatory in the UK, I saw many products that also followed a
> fashion cycle. It is not unusual for items such as lighting products
> to
> lie dormant for a number of years e.g.: the Lava Lamp.
> There is some confusion about the format of the use of the last two
> digits. my advice has always been to find space in the middle of the
> page and put "99". Whilst this looks odd it follows, to the letter,
> the
> requirement and again it is worth remembering that the intended
> audience
> for D of C's are the enforcement folks.
> The D of C should not be changed from year to year. The only reason
> for
> doing this would be if the product was revised, or the source of
> manufacture was changed to sufficiently need the re-definition of the
> product. This might be the case for a retailer who was sourcing an
> item
> from a new factory each season.
> I hope that this is of interest.
> 
> 
> Alan
> __
> __
> _
> Alan Brewster
> Compliance Certification Services
> 1366 Bordeaux Drive
> Sunnyvale, CA 94089-1005
> Tel: 408-752-8166 ext. 122
> Fax: 408-752-8168
> e-mail: abrews...@ccsemc.com
> http://www.ccsemc.com
> 
> 
> 
> > -Original Message-
> > From:   Chuck Seyboldt [SMTP:cbo...@nlis.net]
> > Sent:   Tuesday, August 03, 1999 10:54 AM
> > To: EMC-PSTC Discussion Group
> > Subject: The meaning of "Affixed"
> >
> >
> >
> >The requirements for the contents of a Declaration of
> > Conformity under the Low Voltage Directive were amended by
> > Directive 93/68/EEC.
> >
> >Directive 73/23/EEC is hereby amended as follows:
> >. . .
> >ANNEX III
> > CE CONFORMITY MARKING AND EC DECLARATION OF CONFORMITY
> >. . .
&

RE: The meaning of "Affixed"

1999-08-04 Thread Alan Brewster

Greetings,

The need to have "the last two digits of the year in which the CE mark
was affixed" marked on the Declaration of Conformity is simply to make
the job of enforcement officers simpler. It is bourne out of the very
nature and application of the LVD in that there are many electrical
products that have been in serial production since the introduction of
the Directive in the early seventies. During my four years as a Notified
Body signatory in the UK, I saw many products that also followed a
fashion cycle. It is not unusual for items such as lighting products to
lie dormant for a number of years e.g.: the Lava Lamp.
There is some confusion about the format of the use of the last two
digits. my advice has always been to find space in the middle of the
page and put "99". Whilst this looks odd it follows, to the letter, the
requirement and again it is worth remembering that the intended audience
for D of C's are the enforcement folks.
The D of C should not be changed from year to year. The only reason for
doing this would be if the product was revised, or the source of
manufacture was changed to sufficiently need the re-definition of the
product. This might be the case for a retailer who was sourcing an item
from a new factory each season. 
I hope that this is of interest.


Alan
____
_
Alan Brewster
Compliance Certification Services
1366 Bordeaux Drive
Sunnyvale, CA 94089-1005
Tel: 408-752-8166 ext. 122
Fax: 408-752-8168
e-mail: abrews...@ccsemc.com
http://www.ccsemc.com



> -Original Message-
> From: Chuck Seyboldt [SMTP:cbo...@nlis.net]
> Sent: Tuesday, August 03, 1999 10:54 AM
> To:   EMC-PSTC Discussion Group
> Subject:  The meaning of "Affixed"
> 
> 
> 
>   The requirements for the contents of a Declaration of
> Conformity under the Low Voltage Directive were amended by
> Directive 93/68/EEC.
> 
>   Directive 73/23/EEC is hereby amended as follows:
>   . . .
>   ANNEX III
>   CE CONFORMITY MARKING AND EC DECLARATION OF CONFORMITY
>   . . .
>   B. EC declaration of conformity
>   The EC declaration of conformity must contain the following
> elements:
>   . . .
>   - the last two digits of the year in which the CE marking was
> affixed.
> 
> 
>   I recognize that this requirement is a "formality" but I
> am interested in understanding how to comply, particularly when
> the goods are produced substantially unchanged, year after year. 
> 
>   One could argue that "affixing of the CE mark" means
> affixing the CE mark to the goods, and that a new declaration is
> to be prepared at least once per year, in order that the proper
> year is recited on the declaration.
> 
>   But, I have seen DofC's that clearly are not done in this
> fashion.  For example, Allen Bradley keeps a series of DofC's
> online - and for currently produced goods, the latest year
> appearing on one DofC is 1995.
> 
>   Obviously, it is easier to NOT revisit the DofC in the
> case of series production.  Naturally, a freshly prepared and
> dated DofC can be expected when a new model is introduced, or a
> change in an existing model is made that requires a technical
> re-evaluation (e.g. a design change that warrants updating the
> design justification in the Technical File), but is it the
> intent of the subject 93/68/EEC amendments to create an
> obligation to create annually dated DofC's for each year that
> series production is undertaken?
> 
>   It is interesting that the Low Voltage Directive has this
> requirement, and Directive 93/68/EEC also likewise amended these
> Directives . . .
> 
> Directive 87/404/EEC (relating to simple pressure vessels)
> Directive 89/686/EEC (relating to Personal Protective Equipment)
> Directive 90/384/EEC (relating to non-automatic weighing instruments)
> Directive 90/396/EEC (relating to appliances burning gaseous fuels)
> Directive 92/42/EEC (relating to Boilers)
> 
>   . . . but the recent Pressure Equipment Directive,
> 97/23/EC, does not have a requirement to include "the last two
> digits of the year in which the CE mark was affixed" on the DofC. 
> 
>   Does anybody here know the original intended purpose for
> including the "year of affixing" requirement?
> 
>   Thanks in advance for your insights - on this decidedly
> non-technical matter.
> 
> Regards,
> Chuck Seyboldt
> 
> 
> -
> This message is coming from the emc-pstc discussion list.
> To cancel your subscription, send mail to majord...@ieee.org
> with the single line: "unsubscribe emc-pstc" (without the
> quotes).  For help, send mail to ed.p