Re: [PSES] Nameplate and DoC requirements Machinery Directive
In message <20150317.133927.1501...@webmail08.vgs.untd.com>, dated Tue, 17 Mar 2015, Brian Gregory writes: I would not use either S/N or model numbers. Some EU Directives require each unit to be positively identifiable, for recall if necessary. I don't see how to do that without both model and serial numbers, although I suppose a long enough serial number would accommodate many different products. But if you do that logically, e.g. the first 10 digits identify the product and the rest the individual unit, that just 'model + serial' in disguise. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 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] Nameplate and DoC requirements Machinery Directive
Did not that ISO stuff was required. What is basis for requirement to indicate accreditations/certifications on the machinery directive D of C? Another member of the esteemed Brian Club. Brian From: Brian Gregory [mailto:brian_greg...@netzero.net] Sent: Tuesday, March 17, 2015 12:39 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Advice from one with mostly US experience, but with an NRTL/NB: Until otherwise prohibited by MD, best practices are: - use of company issued documentation to properly describe the products covered by a DoC. Types, application and ratings need to be crystal clear in the documentation. Use product safety reports from NRTLs as a guide. I would not use either S/N or model numbers. - Be accurate and precise about the scope (the extent) of your organization's ISO 9001 or (other relevant) certifications or accreditations, as far as both the activities and geographical locations covered by the certifications and product use applications are concerned. another Brian -- Original Message -- From: Mike Sherman - Original Message - Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Brian -- I would think a model number might suffice as "designation of the machinery." In my way of thinking, there has to be something that ties the nameplate to the DoC; we use the model number, not a functional description---have never run into that interpretation before. Although the Annex describing the contents of the DoC includes a SN, the required markings on the machine in Annex I do *not* require a SN. My approach is that if it's not required to be on the machine and therefore is not on the machine, it doesn't exist and therefore is not required to be on the DoC. I think there's nothing wrong with electronic signatures and generic DoCs. How many of us have seen exactly that printed in owner's manuals? Mike Sherman Graco Inc. From: "Brian Kunde" To: "EMC-PSTC" Sent: Monday, March 16, 2015 12:18:55 PM Subject: [PSES] Nameplate and DoC requirements Machinery Directive I'm getting beat up again in France for non-compliances according to the machinery Directive on our Nameplate and DoC. I know we have discussed these issues in the past but I was wondering if things have changed or become clearer over time. We want to do things right but some items are hard for us to implement and don't want to have to do unless we really have to. Nameplate (label) according to MD 1.7.3 "- designation of the machinery". The Test Lab in France wants up to put something like "Carbon and Sulfur Determinator" on our nameplate which we just do not have room for. Do others struggle with this requirement? What ways have you found to comply with this requirement? Declaration of Conformity according to MD Annex II, Serial Number. The Test Lab insist that the serial number must be on the DoC even though many have explained why this is not required. TUV:SUD has also told us that the serial number does not have to be on the DoC unless it is needed to determine a CE Compliant instrument from a non-CE compliant instrument, but we do not have this in writing. All of our products are CD compliant so the serial number has no purpose. Does anyone have a document that clearly explains when the serial number is and is not required on the DoC? We cannot really use the methods described in the Guide, such as using a Range of serial numbers because we built one at a time per customer order. The Test Lab wants the DoC to have the exact same information as the Nameplate so they say we cannot use "Series" in the model number or Product Name. Do others use such shortcuts? To do what they want we would have to type up a custom DoC for every instrum! ent we build with a dedicated document number, have it signed, and store copies either paper or electronic file for 10 years. That's crazy. Should I just give in or do I have any ammo in fighting this? Some of the items this Test Lab said was "required" six months they are now backing down saying things like "it would be nice . . . ". Thanks for the help. The Other Brian - 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.
Re: [PSES] Nameplate and DoC requirements Machinery Directive
Brian -- I agree with your comments as they apply to one's technical file. I resist adding unnecessarily detailed information to the DoC. Mike Sherman Graco Inc. - Original Message - From: "Brian Gregory" To: "EMC-PSTC" Sent: Tuesday, March 17, 2015 2:39:27 PM Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Advice from one with mostly US experience, but with an NRTL/NB: Until otherwise prohibited by MD, best practices are: - use of company issued documentation to properly describe the products covered by a DoC. Types, application and ratings need to be crystal clear in the documentation. Use product safety reports from NRTLs as a guide. I would not use either S/N or model numbers. - Be accurate and precise about the scope (the extent) of your organization's ISO 9001 or (other relevant) certifications or accreditations, as far as both the activities and geographical locations covered by the certifications and product use applications are concerned. another Brian -- Original Message -- From: Mike Sherman - Original Message - Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Brian -- I would think a model number might suffice as "designation of the machinery." In my way of thinking, there has to be something that ties the nameplate to the DoC; we use the model number, not a functional description---have never run into that interpretation before. Although the Annex describing the contents of the DoC includes a SN, the required markings on the machine in Annex I do *not* require a SN. My approach is that if it's not required to be on the machine and therefore is not on the machine, it doesn't exist and therefore is not required to be on the DoC. I think there's nothing wrong with electronic signatures and generic DoCs. How many of us have seen exactly that printed in owner's manuals? Mike Sherman Graco Inc. - Original Message - From: "Brian Kunde" To: "EMC-PSTC" Sent: Monday, March 16, 2015 12:18:55 PM Subject: [PSES] Nameplate and DoC requirements Machinery Directive I'm getting beat up again in France for non-compliances according to the machinery Directive on our Nameplate and DoC. I know we have discussed these issues in the past but I was wondering if things have changed or become clearer over time. We want to do things right but some items are hard for us to implement and don't want to have to do unless we really have to. Nameplate (label) according to MD 1.7.3 "- designation of the machinery". The Test Lab in France wants up to put something like "Carbon and Sulfur Determinator" on our nameplate which we just do not have room for. Do others struggle with this requirement? What ways have you found to comply with this requirement? Declaration of Conformity according to MD Annex II, Serial Number. The Test Lab insist that the serial number must be on the DoC even though many have explained why this is not required. TUV:SUD has also told us that the serial number does not have to be on the DoC unless it is needed to determine a CE Compliant instrument from a non-CE compliant instrument, but we do not have this in writing. All of our products are CD compliant so the serial number has no purpose. Does anyone have a document that clearly explains when the serial number is and is not required on the DoC? We cannot really use the methods described in the Guide, such as using a Range of serial numbers because we built one at a time per customer order. The Test Lab wants the DoC to have the exact same information as the Nameplate so they say we cannot use "Series" in the model number or Product Name. Do others use such shortcuts? To do what they want we would have to type up a custom DoC for every instrum! ent we build with a dedicated document number, have it signed, and store copies either paper or electronic file for 10 years. That's crazy. Should I just give in or do I have any ammo in fighting this? Some of the items this Test Lab said was "required" six months they are now backing down saying things like "it would be nice . . . ". Thanks for the help. The Other Brian 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 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 Communit
Re: [PSES] Nameplate and DoC requirements Machinery Directive
Advice from one with mostly US experience, but with an NRTL/NB: Until otherwise prohibited by MD, best practices are: - use of company issued documentation to properly describe the products covered by a DoC. Types, application and ratings need to be crystal clear in the documentation. Use product safety reports from NRTLs as a guide. I would not use either S/N or model numbers. - Be accurate and precise about the scope (the extent) of your organization's ISO 9001 or (other relevant) certifications or accreditations, as far as both the activities and geographical locations covered by the certifications and product use applications are concerned. another Brian -- Original Message -- From: Mike Sherman - Original Message - Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Brian -- I would think a model number might suffice as "designation of the machinery." In my way of thinking, there has to be something that ties the nameplate to the DoC; we use the model number, not a functional description---have never run into that interpretation before. Although the Annex describing the contents of the DoC includes a SN, the required markings on the machine in Annex I do *not* require a SN. My approach is that if it's not required to be on the machine and therefore is not on the machine, it doesn't exist and therefore is not required to be on the DoC. I think there's nothing wrong with electronic signatures and generic DoCs. How many of us have seen exactly that printed in owner's manuals? Mike ShermanGraco Inc. From: "Brian Kunde" To: "EMC-PSTC" Sent: Monday, March 16, 2015 12:18:55 PM Subject: [PSES] Nameplate and DoC requirements Machinery Directive I'm getting beat up again in France for non-compliances according to the machinery Directive on our Nameplate and DoC. I know we have discussed these issues in the past but I was wondering if things have changed or become clearer over time. We want to do things right but some items are hard for us to implement and don't want to have to do unless we really have to. Nameplate (label) according to MD 1.7.3 "- designation of the machinery". The Test Lab in France wants up to put something like "Carbon and Sulfur Determinator" on our nameplate which we just do not have room for. Do others struggle with this requirement? What ways have you found to comply with this requirement? Declaration of Conformity according to MD Annex II, Serial Number. The Test Lab insist that the serial number must be on the DoC even though many have explained why this is not required. TUV:SUD has also told us that the serial number does not have to be on the DoC unless it is needed to determine a CE Compliant instrument from a non-CE compliant instrument, but we do not have this in writing. All of our products are CD compliant so the serial number has no purpose. Does anyone have a document that clearly explains when the serial number is and is not required on the DoC? We cannot really use the methods described in the Guide, such as using a Range of serial numbers because we built one at a time per customer order. The Test Lab wants the DoC to have the exact same information as the Nameplate so they say we cannot use "Series" in the model number or Product Name. Do others use such shortcuts? To do what they want we would have to type up a custom DoC for every instrum! ent we build with a dedicated document number, have it signed, and store copies either paper or electronic file for 10 years. That's crazy. Should I just give in or do I have any ammo in fighting this? Some of the items this Test Lab said was "required" six months they are now backing down saying things like "it would be nice . . . ". Thanks for the help. The Other Brian 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 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:
Re: [PSES] Nameplate and DoC requirements Machinery Directive
In message utlook.com>, dated Tue, 17 Mar 2015, "Nyffenegger, Dave" writes: Annex VII states the technical file shall include ?a copy of the EC declaration of conformity;? Don?t know if this implies a copy of every unique original with signature and/or serial number needs to be kept or only the original that is then signed for each unit or batch or whatever a manufacturer decides to do. I think it can be simplified to 'Save every unique DoC'. If a single DoC covers hundreds or thousands of units produced over some years (so not an MD Doc), just save one. If a serial number must be on the DoC, or each DoC is unique in some other way, then save every one. In any case, we know the technical file must be kept for 10 years as well as the DoC, it seems to me filing as many copies of DoCs as one might have with the technical file (either electronically or hard copy) would logical. Yes, that is the wisest course of action. Electronic storage, of course. You can't be criticized by Market Surveillance for preserving too much information. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 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] Nameplate and DoC requirements Machinery Directive
The MD Annex II states "The manufacturer of machinery or his authorised representative shall keep the original EC declaration of conformity for a period of at least 10 years from the last date of manufacture of the machinery.". Don't know if this implies that every unique original with signature and/or serial number needs to be kept or only the original that is then signed for each unit or batch or whatever a manufacturer decides to do. Annex VII states the technical file shall include "a copy of the EC declaration of conformity;" Don't know if this implies a copy of every unique original with signature and/or serial number needs to be kept or only the original that is then signed for each unit or batch or whatever a manufacturer decides to do. In any case, we know the technical file must be kept for 10 years as well as the DoC, it seems to me filing as many copies of DoCs as one might have with the technical file (either electronically or hard copy) would logical. -Dave From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Monday, March 16, 2015 3:37 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Exactly my point. Complicated. And once you put a serial number on the DoC it becomes a Static Document with its unique document number and it has to be filed somewhere so it can be recovered someday if anyone asks for it. BTW, google searching this topic, someone wrote a paper back in 2008 what says for the Serial Number you can put something like, "Serial Number 3001 onward". Does anyone do that? Do you think that will really fly? Another question. According to the MD 1.7.4.2 , the DoC does not have to be contained within the provided instructions but a "document setting out the contents of the EC declaration of conformity showing the particulars of the machinery, not necessarily including the serial number and the signature". So can we make the official DoC available only upon request? Yet, Article 5_1(e) states, "ensure that it [DoC] accompanies the machinery;". So I guess you cannot get around shipping the DoC with the product, right? Thanks. The Other Brian From: John Allen [mailto:john_e_al...@blueyonder.co.uk] Sent: Monday, March 16, 2015 3:08 PM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Good evening I think that a digital one should be OK because that is how my last (contract) employer (a large US-based multinational) has been doing it recently. But, in outline,: - only specified people must be able make the insertion - the chain of authorities from the CEO (etc.) to the person(s) actually inserting the digital version must be very explicitly defined, and the latter needs to inform the former person of exactly what is being done on each occasion the signature is to be used, and, possibly, will need to receive the authority before it is actually inserted; - the electronic process for insertion of the signature must very carefully controlled, and the insertion must be permanently logged on the system in question. Don't think that a scanned version would be very good because of possible miss-use of the image. John Allen W.London, UK - -Original Message- From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: 16 March 2015 18:19 To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Does the signature on a DoC need to be "original" or would an digital (or scanned) signature be acceptable? Jim Hulbert -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Monday, March 16, 2015 1:40 PM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive In message <64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local<mailto:64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>>, dated Mon, 16 Mar 2015, "Kunde, Brian" mailto:brian_ku...@lecotc.com>> writes: > To do what they want we would have to type up a custom DoC for every >instrum! > ent we build with a dedicated document number, have it signed, and >store copies either paper or electronic file for 10 years. That's crazy. Since you are making one at a time per customer order. I don't see it's so crazy to have a 'dynamic' DoC. After all, you have a different invoice for each unit you ship. so why is it difficult to have a (mildly) different DoC? Of course, you store electronically. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> When I turn my back on the sun, it's to look f
Re: [PSES] Nameplate and DoC requirements Machinery Directive
Brian -- I would think a model number might suffice as "designation of the machinery." In my way of thinking, there has to be something that ties the nameplate to the DoC; we use the model number, not a functional description---have never run into that interpretation before. Although the Annex describing the contents of the DoC includes a SN, the required markings on the machine in Annex I do *not* require a SN. My approach is that if it's not required to be on the machine and therefore is not on the machine, it doesn't exist and therefore is not required to be on the DoC. I think there's nothing wrong with electronic signatures and generic DoCs. How many of us have seen exactly that printed in owner's manuals? Mike Sherman Graco Inc. - Original Message - From: "Brian Kunde" To: "EMC-PSTC" Sent: Monday, March 16, 2015 12:18:55 PM Subject: [PSES] Nameplate and DoC requirements Machinery Directive I'm getting beat up again in France for non-compliances according to the machinery Directive on our Nameplate and DoC. I know we have discussed these issues in the past but I was wondering if things have changed or become clearer over time. We want to do things right but some items are hard for us to implement and don't want to have to do unless we really have to. Nameplate (label) according to MD 1.7.3 "- designation of the machinery". The Test Lab in France wants up to put something like "Carbon and Sulfur Determinator" on our nameplate which we just do not have room for. Do others struggle with this requirement? What ways have you found to comply with this requirement? Declaration of Conformity according to MD Annex II, Serial Number. The Test Lab insist that the serial number must be on the DoC even though many have explained why this is not required. TUV:SUD has also told us that the serial number does not have to be on the DoC unless it is needed to determine a CE Compliant instrument from a non-CE compliant instrument, but we do not have this in writing. All of our products are CD compliant so the serial number has no purpose. Does anyone have a document that clearly explains when the serial number is and is not required on the DoC? We cannot really use the methods described in the Guide, such as using a Range of serial numbers because we built one at a time per customer order. The Test Lab wants the DoC to have the exact same information as the Nameplate so they say we cannot use "Series" in the model number or Product Name. Do others use such shortcuts? To do what they want we would have to type up a custom DoC for every instrum! ent we build with a dedicated document number, have it signed, and store copies either paper or electronic file for 10 years. That's crazy. Should I just give in or do I have any ammo in fighting this? Some of the items this Test Lab said was "required" six months they are now backing down saying things like "it would be nice . . . ". Thanks for the help. The Other Brian 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 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:
Re: [PSES] Nameplate and DoC requirements Machinery Directive
In message e/TaogBAA==@blueyonder.co.uk>, dated Mon, 16 Mar 2015, John Allen writes: I'm sure that the corporate legal eagles of my old US employer (they really are a "Big Name" in the technology sector) must have considered the issue of the "original" DoC when they decided that the digital signature is permissible, so I'm not sure that the "original" version does need to be signed "in ink"! It's a legal or quasi-legal document. A lawyer could readily challenge a digital signature but far less easily a pen-and-ink one. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 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] Nameplate and DoC requirements Machinery Directive
In message MTd1qEBAA==@blueyonder.co.uk>, dated Mon, 16 Mar 2015, John Allen writes: But many companies that make "genuine" (or ?other?!) products also have "dubious" employees, or importers in other countries, who are ?less scrupulous? about the way that DoCs are produced! What can a villain do with a fake DoC without a fake product to go with it? In any case, you can't stop forgery these days; you no longer need any skill. Give me any DoC and I'll give you a copy immediately. (Almost) Finally, as most companies and government departments now routinely accept electronic documentation as part of day-to-day commercial transactions, then surely electronic signatures are absolutely part of that process ? that?s part of the hi-tech world we live in today! That?s why big companies, with the caveats previously mentioned now, may take that approach. I didn't argue against electronic signatures at all; I juts pointed out that extreme security isn't necessary because a forged DoC is useless without a product to go with it, and it's very far more difficult to get the product. OTOH, it?s probably not appropriate for small companies making small quantities, or ?on-offs?, of products because it?s more trouble than it?s worth! I don't see why. If I were still making products to sell, I would certainly use digital documentation as far as possible. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 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] FW: [PSES] Nameplate and DoC requirements Machinery Directive
Brian et al, Too bad you are getting beat-up by some local authorities (in France, altho that's probably not the only place where such folks push their authority). Altho Rich Nute recommended getting the references for the requirements (which is a good idea) it may not come from the complaining authorities and might not be accepted when coming from the originators of the requirements. Unfortunately, there does not seem to be a good court of last resort to sort this out. Perhaps I've been more fortunate than most as an independent consultant I usually get CE marking projects that are one-off, custom versions of a machine that are usually adapted for each customer; so it is unique and, since the company doesn't get too many foreign orders, the entire process is captured as a project and the final step is the signed MDoC (a unique document for a unique machine). It seems that these complainers believe that machines are all unique units and the detailed rules aren't a burden under those circumstances. I know that is not always the case. Perhaps there is some way to reposition the product so that is isn't a machine but rather some other sort of product that is better handled outside the MD? I've dealt with some pretty complex process control equipment that has never been claimed to be a machine. You are probably familiar with other situations that might fall into such a category. Not having had such a reaction (knock-on-wood) I don't have 1st hand experience. Good luck in sorting it all out. :>) br, Pete Peter E Perkins, PE Principal Product Safety Engineer PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 fone/fax p.perk...@ieee.org -Original Message- From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Monday, March 16, 2015 10:19 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Nameplate and DoC requirements Machinery Directive I'm getting beat up again in France for non-compliances according to the machinery Directive on our Nameplate and DoC. I know we have discussed these issues in the past but I was wondering if things have changed or become clearer over time. We want to do things right but some items are hard for us to implement and don't want to have to do unless we really have to. Nameplate (label) according to MD 1.7.3 "- designation of the machinery". The Test Lab in France wants up to put something like "Carbon and Sulfur Determinator" on our nameplate which we just do not have room for. Do others struggle with this requirement? What ways have you found to comply with this requirement? Declaration of Conformity according to MD Annex II, Serial Number. The Test Lab insist that the serial number must be on the DoC even though many have explained why this is not required. TUV:SUD has also told us that the serial number does not have to be on the DoC unless it is needed to determine a CE Compliant instrument from a non-CE compliant instrument, but we do not have this in writing. All of our products are CD compliant so the serial number has no purpose. Does anyone have a document that clearly explains when the serial number is and is not required on the DoC? We cannot really use the methods described in the Guide, such as using a Range of serial numbers because we built one at a time per customer order. The Test Lab wants the DoC to have the exact same information as the Nameplate so they say we cannot use "Series" in the model number or Product Name. Do others use such shortcuts? To do what they want we would have to type up a custom DoC for every instrum! ent we build with a dedicated document number, have it signed, and store copies either paper or electronic file for 10 years. That's crazy. Should I just give in or do I have any ammo in fighting this? Some of the items this Test Lab said was "required" six months they are now backing down saying things like "it would be nice . . . ". Thanks for the help. The Other Brian 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 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) Lis
Re: [PSES] Nameplate and DoC requirements Machinery Directive
John But many companies that make "genuine" (or "other"!) products also have "dubious" employees, or importers in other countries, who are "less scrupulous" about the way that DoCs are produced! (Almost) Finally, as most companies and government departments now routinely accept electronic documentation as part of day-to-day commercial transactions, then surely electronic signatures are absolutely part of that process - that's part of the hi-tech world we live in today! That's why big companies, with the caveats previously mentioned now, may take that approach. OTOH, it's probably not appropriate for small companies making small quantities, or "on-offs", of products because it's more trouble than it's worth! John Allen W. London, UK -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 16 March 2015 21:08 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive In message < <mailto:64D32EE8B9CBDD44963ACB076A5F6ABB026D3825@Mailbox-Tech.lecotech.local > 64D32EE8B9CBDD44963ACB076A5F6ABB026D3825@Mailbox-Tech.lecotech.local>, dated Mon, 16 Mar 2015, "Kunde, Brian" < <mailto:brian_ku...@lecotc.com> brian_ku...@lecotc.com> writes: >Exactly my point. Complicated. And once you put a serial number on the >DoC it becomes a Static Document with its unique document number and it >has to be filed somewhere so it can be recovered someday if anyone asks >for it. I don't agree that the procedure outlined by John Allen is realistic. Normally, a company has one person who signs DoCs (well, maybe two). So for 'shipping copies' you just have a Word (or other fine word processor) template with the signature and add the serial number individually. I can't see that there is much scope for abuse; a fake DoC needs a fake product to go with it and I doubt many companies make fake products along with real ones. It is hardly an onerous task for the CTO or whoever to sign the *original* DoCs. If it is, buy him/her a facsimile writer. There is, of course, no way to stop another company making fake products; compared with the effort that takes, that of forging a DoC is quite trivial. -- OOO - Own Opinions Only. With best wishes. See <http://www.jmwa.demon.co.uk> www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 < <mailto:emc-p...@ieee.org> emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: <http://www.ieee-pses.org/emc-pstc.html> 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/> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: <http://www.ieee-pses.org/> http://www.ieee-pses.org/ Instructions: <http://www.ieee-pses.org/list.html> http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: <http://www.ieee-pses.org/listrules.html> http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas < <mailto:sdoug...@ieee.org> sdoug...@ieee.org> Mike Cantwell < <mailto:mcantw...@ieee.org> mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: < <mailto:j.bac...@ieee.org> j.bac...@ieee.org> David Heald: < <mailto:dhe...@gmail.com> 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 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] Nameplate and DoC requirements Machinery Directive
John I'm sure that the corporate legal eagles of my old US employer (they really are a "Big Name" in the technology sector) must have considered the issue of the "original" DoC when they decided that the digital signature is permissible, so I'm not sure that the "original" version does need to be signed "in ink"! John Allen W.London, UK -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 16 March 2015 20:59 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive In message <7B9D892F88F070469771832D78B3086E284AA5F6@013-BR1MPN1-011.MGDPBI.global.p vt>, dated Mon, 16 Mar 2015, Jim Hulbert writes: >Does the signature on a DoC need to be "original" or would an digital >(or scanned) signature be acceptable? On the DoC in the Technical File, it should be original, but copies can be digital or scanned. Only the original is legally valid: the copies are informative. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 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:
Re: [PSES] Nameplate and DoC requirements Machinery Directive
In message <64D32EE8B9CBDD44963ACB076A5F6ABB026D3825@Mailbox-Tech.lecotech.local>, dated Mon, 16 Mar 2015, "Kunde, Brian" writes: Exactly my point. Complicated. And once you put a serial number on the DoC it becomes a Static Document with its unique document number and it has to be filed somewhere so it can be recovered someday if anyone asks for it. I don't agree that the procedure outlined by John Allen is realistic. Normally, a company has one person who signs DoCs (well, maybe two). So for 'shipping copies' you just have a Word (or other fine word processor) template with the signature and add the serial number individually. I can't see that there is much scope for abuse; a fake DoC needs a fake product to go with it and I doubt many companies make fake products along with real ones. It is hardly an onerous task for the CTO or whoever to sign the *original* DoCs. If it is, buy him/her a facsimile writer. There is, of course, no way to stop another company making fake products; compared with the effort that takes, that of forging a DoC is quite trivial. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 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] Nameplate and DoC requirements Machinery Directive
In message <7B9D892F88F070469771832D78B3086E284AA5F6@013-BR1MPN1-011.MGDPBI.global.p vt>, dated Mon, 16 Mar 2015, Jim Hulbert writes: Does the signature on a DoC need to be "original" or would an digital (or scanned) signature be acceptable? On the DoC in the Technical File, it should be original, but copies can be digital or scanned. Only the original is legally valid: the copies are informative. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 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] Nameplate and DoC requirements Machinery Directive
Exactly my point. Complicated. And once you put a serial number on the DoC it becomes a Static Document with its unique document number and it has to be filed somewhere so it can be recovered someday if anyone asks for it. BTW, google searching this topic, someone wrote a paper back in 2008 what says for the Serial Number you can put something like, "Serial Number 3001 onward". Does anyone do that? Do you think that will really fly? Another question. According to the MD 1.7.4.2 , the DoC does not have to be contained within the provided instructions but a "document setting out the contents of the EC declaration of conformity showing the particulars of the machinery, not necessarily including the serial number and the signature". So can we make the official DoC available only upon request? Yet, Article 5_1(e) states, "ensure that it [DoC] accompanies the machinery;". So I guess you cannot get around shipping the DoC with the product, right? Thanks. The Other Brian From: John Allen [mailto:john_e_al...@blueyonder.co.uk] Sent: Monday, March 16, 2015 3:08 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Good evening I think that a digital one should be OK because that is how my last (contract) employer (a large US-based multinational) has been doing it recently. But, in outline,: - only specified people must be able make the insertion - the chain of authorities from the CEO (etc.) to the person(s) actually inserting the digital version must be very explicitly defined, and the latter needs to inform the former person of exactly what is being done on each occasion the signature is to be used, and, possibly, will need to receive the authority before it is actually inserted; - the electronic process for insertion of the signature must very carefully controlled, and the insertion must be permanently logged on the system in question. Don't think that a scanned version would be very good because of possible miss-use of the image. John Allen W.London, UK - -Original Message- From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: 16 March 2015 18:19 To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Does the signature on a DoC need to be "original" or would an digital (or scanned) signature be acceptable? Jim Hulbert -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Monday, March 16, 2015 1:40 PM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive In message <64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local<mailto:64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>>, dated Mon, 16 Mar 2015, "Kunde, Brian" mailto:brian_ku...@lecotc.com>> writes: > To do what they want we would have to type up a custom DoC for every >instrum! > ent we build with a dedicated document number, have it signed, and >store copies either paper or electronic file for 10 years. That's crazy. Since you are making one at a time per customer order. I don't see it's so crazy to have a 'dynamic' DoC. After all, you have a different invoice for each unit you ship. so why is it difficult to have a (mildly) different DoC? Of course, you store electronically. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> When I turn my back on the sun, it's to look for a rainbow 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 mailto: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 mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher: mailto:j.bac...@ieee.org>> David Heald: mailto:dhe...@gmail.com>> - This message is from the IEEE Product Safety Engineering Society emc-pstc discus
Re: [PSES] Nameplate and DoC requirements Machinery Directive
Good evening I think that a digital one should be OK because that is how my last (contract) employer (a large US-based multinational) has been doing it recently. But, in outline,: - only specified people must be able make the insertion - the chain of authorities from the CEO (etc.) to the person(s) actually inserting the digital version must be very explicitly defined, and the latter needs to inform the former person of exactly what is being done on each occasion the signature is to be used, and, possibly, will need to receive the authority before it is actually inserted; - the electronic process for insertion of the signature must very carefully controlled, and the insertion must be permanently logged on the system in question. Don't think that a scanned version would be very good because of possible miss-use of the image. John Allen W.London, UK - -Original Message- From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: 16 March 2015 18:19 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive Does the signature on a DoC need to be "original" or would an digital (or scanned) signature be acceptable? Jim Hulbert -Original Message- From: John Woodgate [ <mailto:j...@jmwa.demon.co.uk> mailto:j...@jmwa.demon.co.uk] Sent: Monday, March 16, 2015 1:40 PM To: <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive In message < <mailto:64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local > 64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>, dated Mon, 16 Mar 2015, "Kunde, Brian" < <mailto:brian_ku...@lecotc.com> brian_ku...@lecotc.com> writes: > To do what they want we would have to type up a custom DoC for every >instrum! > ent we build with a dedicated document number, have it signed, and >store copies either paper or electronic file for 10 years. That's crazy. Since you are making one at a time per customer order. I don't see it's so crazy to have a 'dynamic' DoC. After all, you have a different invoice for each unit you ship. so why is it difficult to have a (mildly) different DoC? Of course, you store electronically. -- OOO - Own Opinions Only. With best wishes. See <http://www.jmwa.demon.co.uk> www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 < <mailto:emc-p...@ieee.org> emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: <http://www.ieee-pses.org/emc-pstc.html> 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/> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: <http://www.ieee-pses.org/> http://www.ieee-pses.org/ Instructions: <http://www.ieee-pses.org/list.html> http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: <http://www.ieee-pses.org/listrules.html> http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas < <mailto:sdoug...@ieee.org> sdoug...@ieee.org> Mike Cantwell < <mailto:mcantw...@ieee.org> mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: < <mailto:j.bac...@ieee.org> j.bac...@ieee.org> David Heald: < <mailto:dhe...@gmail.com> 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 < <mailto:emc-p...@ieee.org> emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: <http://www.ieee-pses.org/emc-pstc.html> 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/> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: <http://www.ieee-pses.org/> http://www.ieee-pses.org/ Instructions: <http://www.ieee-pses.org/list.html> http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: <http://www.ieee-pses.org/listrules.html> http://www.ieee-pses.org/listrules.html For
Re: [PSES] Nameplate and DoC requirements Machinery Directive
Does the signature on a DoC need to be "original" or would an digital (or scanned) signature be acceptable? Jim Hulbert -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Monday, March 16, 2015 1:40 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Nameplate and DoC requirements Machinery Directive In message <64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>, dated Mon, 16 Mar 2015, "Kunde, Brian" writes: > To do what they want we would have to type up a custom DoC for every >instrum! > ent we build with a dedicated document number, have it signed, and >store copies either paper or electronic file for 10 years. That's crazy. Since you are making one at a time per customer order. I don't see it's so crazy to have a 'dynamic' DoC. After all, you have a different invoice for each unit you ship. so why is it difficult to have a (mildly) different DoC? Of course, you store electronically. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 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:
Re: [PSES] Nameplate and DoC requirements Machinery Directive
In message <64D32EE8B9CBDD44963ACB076A5F6ABB026D3725@Mailbox-Tech.lecotech.local>, dated Mon, 16 Mar 2015, "Kunde, Brian" writes: To do what they want we would have to type up a custom DoC for every instrum! ent we build with a dedicated document number, have it signed, and store copies either paper or electronic file for 10 years. That's crazy. Since you are making one at a time per customer order. I don't see it's so crazy to have a 'dynamic' DoC. After all, you have a different invoice for each unit you ship. so why is it difficult to have a (mildly) different DoC? Of course, you store electronically. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn my back on the sun, it's to look for a rainbow 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 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] Nameplate and DoC requirements Machinery Directive
Hi Brian: Ask the test lab to provide you with the documents that specify what they want. After all, you want to do what is right! Good luck, 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 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] Nameplate and DoC requirements Machinery Directive
I'm getting beat up again in France for non-compliances according to the machinery Directive on our Nameplate and DoC. I know we have discussed these issues in the past but I was wondering if things have changed or become clearer over time. We want to do things right but some items are hard for us to implement and don't want to have to do unless we really have to. Nameplate (label) according to MD 1.7.3 "- designation of the machinery". The Test Lab in France wants up to put something like "Carbon and Sulfur Determinator" on our nameplate which we just do not have room for. Do others struggle with this requirement? What ways have you found to comply with this requirement? Declaration of Conformity according to MD Annex II, Serial Number. The Test Lab insist that the serial number must be on the DoC even though many have explained why this is not required. TUV:SUD has also told us that the serial number does not have to be on the DoC unless it is needed to determine a CE Compliant instrument from a non-CE compliant instrument, but we do not have this in writing. All of our products are CD compliant so the serial number has no purpose. Does anyone have a document that clearly explains when the serial number is and is not required on the DoC? We cannot really use the methods described in the Guide, such as using a Range of serial numbers because we built one at a time per customer order. The Test Lab wants the DoC to have the exact same information as the Nameplate so they say we cannot use "Series" in the model number or Product Name. Do others use such shortcuts? To do what they want we would have to type up a custom DoC for every instrum! ent we build with a dedicated document number, have it signed, and store copies either paper or electronic file for 10 years. That's crazy. Should I just give in or do I have any ammo in fighting this? Some of the items this Test Lab said was "required" six months they are now backing down saying things like "it would be nice . . . ". Thanks for the help. The Other Brian 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 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:
