Machinery vs LVD (was CE (LVD) for Fruit Juicers)
Glenn, I've replied on the point about EN60335-2-14 elsewhere, but I'll throw another pebble in the pond if I may. The Machinery Directive EHSRs quite specifically require the provision of emergency stops on equipment except in some limited and particular circumstances. EN 60335, EN 60950 and the other LVD standards do not, in general, mention E-stops. It seems to me that if you have a product where you cannot apply the Machinery Directive article 1(5) exclusion, one of the consequences is that an E-stop will probably be required. This would mean that the difference would be somewhat more material than just in the technical file. What do you think? Rgds Nick. At 8:51 +0100 20/6/02, i...@uk.tuv.com wrote: Hi Robert This type of product would be covered by EN 60335-2-14, Particular requirements for kitchen machines. The scope includes citrus fruit squeezers and centrifugal juicers. Technically, the machinery Directive does apply since it meets the definition of a machine, assuming that it is not excluded by article 1(5), that is a risk assessment shows that the risks are not mainly of electrical origin. However in the UK, I do remember a DTI document which was issued soon after the MD was released that said that products which have traditionally fallen within the scope of the LVD in the past may continue to do so. I don't know if this advice has been superceded or forgotten or whether it still applies since domestic electrical appliances within the scope of EN 60335 have traditionally been in the scope of the LVD. In practical terms, the main difference in the application of the LVD and MD is the requirements for the technical file. EN 60335-1 states (Introduction) that the essential requirements of the LVD, MD and CPD are covered by the standard (Noise and vibration???) This and more information can be found in the European Commission DGIII Guidelines on the application of council Directive 73/23/EEC. I hope this helps. Best regards Glenn Moffat TUV International UK Tel: +44 121 634 8000 Fax: +44 121 634 8080 --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
CE (LVD) for Fruit Juicers
Glen Moffat wrote: Technically, the machinery Directive does apply since it meets the definition of a machine, assuming that it is not excluded by article 1(5), that is a risk assessment shows that the risks are not mainly of electrical origin. However in the UK, I do remember a DTI document which was issued soon after the MD was released that said that products which have traditionally fallen within the scope of the LVD in the past may continue to do so. I don't know if this advice has been superceded or forgotten or whether it still applies since domestic electrical appliances within the scope of EN 60335 have traditionally been in the scope of the LVD. This is the way I understand the majority of appliance manufacturers are interpreting the requirement. Household appliances falling under the scope of EN 60335 are considered LVD, even though many of them use moving parts that would seem to put them within the scope of the machinery directive. If you're concerned about the unlikely case where this decision might be challenged, you can always prepare a risk assessment using the 335 report as its basis, and follow the more stringent marking/documentation requirements of the Machinery Directive. Greg Galluccio www.productapprovals.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: CE (LVD) for Fruit Juicers
In general I agree wholeheartedly with Glenn's excellent response, but I would add that my copy of EN60335-2-14-1997 includes the following statement (dated November 1998) on CENELEC headed paper: ' An investigation by CENLEC TC61 has shown that all risks from products within the scope of this standard are fully covered by the Low Voltage Directive 73/23/EEC. If the product has mechanical moving marts, a risk assessment in accordance with the Machinery Directive 89/392/EEC has shown that the risks are mainly of an electrical origin and consequently this directive is not applicable. However, the relevant essential safety requirements of the Machinery Directive are covered by this standard together with the principal objectives of the Low Voltage Directive.' Ultimately, it's the manufacturer's responsibility to make the relevant assessment and decide which Directives apply, and CENELEC can only provide guidance, but for straightforward domestic applications, I'd say the above statement was pretty much the last word on the subject. We've done work on a number of appliances within the scope of this standard, but not very recently and I don't think my copy of the standard includes all the latest amendments. There was a proposed amendment regarding the provision of interlocks which would have affected blenders and juicers in particular, so it would be worth making sure you have an up-to-date standard if this is the product type you are dealing with. Please ask if I can be of more help. Regards Nick. At 8:51 +0100 20/6/02, i...@uk.tuv.com wrote: Hi Robert This type of product would be covered by EN 60335-2-14, Particular requirements for kitchen machines. The scope includes citrus fruit squeezers and centrifugal juicers. Technically, the machinery Directive does apply since it meets the definition of a machine, assuming that it is not excluded by article 1(5), that is a risk assessment shows that the risks are not mainly of electrical origin. However in the UK, I do remember a DTI document which was issued soon after the MD was released that said that products which have traditionally fallen within the scope of the LVD in the past may continue to do so. I don't know if this advice has been superceded or forgotten or whether it still applies since domestic electrical appliances within the scope of EN 60335 have traditionally been in the scope of the LVD. In practical terms, the main difference in the application of the LVD and MD is the requirements for the technical file. EN 60335-1 states (Introduction) that the essential requirements of the LVD, MD and CPD are covered by the standard (Noise and vibration???) This and more information can be found in the European Commission DGIII Guidelines on the application of council Directive 73/23/EEC. I hope this helps. Best regards Glenn Moffat TUV International UK Tel: +44 121 634 8000 Fax: +44 121 634 8080 Hi Group, Looking through the OJEC LVD Standards list, I could not find under EN 60335 and its many parts a particular part that covered a juicer. Does anyone know which particular part of this standard this product falls under? Also, not having seen this device, if it has blades like a blender, will the Machinery Directive also be applicable? Thanks for sharing your knowledge. Sincerely, Robert R. Loop Engineering Supervisor - Product Safety ph: (256) 837-4411 x313 fax:(256) 721-0144 email: rl...@hnt.wylelabs.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: CE (LVD) for Fruit Juicers
Hi Robert This type of product would be covered by EN 60335-2-14, Particular requirements for kitchen machines. The scope includes citrus fruit squeezers and centrifugal juicers. Technically, the machinery Directive does apply since it meets the definition of a machine, assuming that it is not excluded by article 1(5), that is a risk assessment shows that the risks are not mainly of electrical origin. However in the UK, I do remember a DTI document which was issued soon after the MD was released that said that products which have traditionally fallen within the scope of the LVD in the past may continue to do so. I don't know if this advice has been superceded or forgotten or whether it still applies since domestic electrical appliances within the scope of EN 60335 have traditionally been in the scope of the LVD. In practical terms, the main difference in the application of the LVD and MD is the requirements for the technical file. EN 60335-1 states (Introduction) that the essential requirements of the LVD, MD and CPD are covered by the standard (Noise and vibration???) This and more information can be found in the European Commission DGIII Guidelines on the application of council Directive 73/23/EEC. I hope this helps. Best regards Glenn Moffat TUV International UK Tel: +44 121 634 8000 Fax: +44 121 634 8080 Hi Group, Looking through the OJEC LVD Standards list, I could not find under EN 60335 and its many parts a particular part that covered a juicer. Does anyone know which particular part of this standard this product falls under? Also, not having seen this device, if it has blades like a blender, will the Machinery Directive also be applicable? Thanks for sharing your knowledge. Sincerely, Robert R. Loop Engineering Supervisor - Product Safety ph: (256) 837-4411 x313 fax:(256) 721-0144 email: rl...@hnt.wylelabs.com This email transmission is confidential and intended for the addressee only. It may contain privileged and confidential information. If you are not the person or organization to whom it is addressed, you must not copy, distribute, or take any action in reliance upon it. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
CE (LVD) for Fruit Juicers
Hi Group, Looking through the OJEC LVD Standards list, I could not find under EN 60335 and its many parts a particular part that covered a juicer. Does anyone know which particular part of this standard this product falls under? Also, not having seen this device, if it has blades like a blender, will the Machinery Directive also be applicable? Thanks for sharing your knowledge. Sincerely, Robert R. Loop Engineering Supervisor - Product Safety ph: (256) 837-4411 x313 fax:(256) 721-0144 email: rl...@hnt.wylelabs.com This email transmission is confidential and intended for the addressee only. It may contain privileged and confidential information. If you are not the person or organization to whom it is addressed, you must not copy, distribute, or take any action in reliance upon it. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
