Hi Peter, The answer to your question lies in the intended application of the device. If it has an intended application, then it is a machine. If it is a component that could be incorporated into many kinds of machines, think “gearbox” for example, then it is not in the scope of the MD, even it it is an assembly of linked parts at least one of which moves. Also, does it include the power and control systems necessary for it’s function, or are these provided by the application device? If they are contained, then the device is closer to a machine, pending the intended application. If they are external then it is a machine part and outside the MD.
Doug Nix [email protected] +1 (519) 729-5704 > On 24-Sep-20, at 16:35, Peter Tarver <[email protected]> wrote: > > Hello. > > For the following, I have (nearly) concluded that the > Machinery Directive applies, but I have some lingering > uncertainty. I'm looking for reasonable arguments to > say that it does or doesn't apply before I dive > headlong into the tasks related to supporting a > declaration against the Machinery Directive. > > Consider a product that is completely sealed but > contains a rotating mass. The mass rotates as a primary > part of the product's function. In the strictest sense, > it is (or contains) a machine. However, any number of > products contain rotating masses (e.g., fans) that are > not generally subject to the Machinery Directive and > which have other standards under the Low Voltage > Directive that address the relevant safety concerns. > > Among the many use cases for the product are autonomous > or robotic mail delivery and security systems, which > will move along the ground or along floor surfaces. > These pieces of motive host equipment would require > application of the Machinery Directive. For these and > other use cases,the product could serve as a safety > component, though perhaps not in any traditional sense, > but within the context of Annex V of the Machinery > Directive. > > There are no specific standards in the OJ list of > harmonized standards that apply directly to the > product's primary applications function, so I assume EN > 60204-1 will apply, with perhaps some peripheral > standards that are in the OJ list. > > FWIW, I've performed a review of the mechanical hazards > using IEC 62368-1 and found that the product falls > squarely into MS1. > > What ever arguments you can make either in favor of > applying the Machinery directive or against it are > welcomed and encouraged. I look forward to hearing from > you. > > Peter > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to > <[email protected]> > > 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 <[email protected]> > Mike Cantwell <[email protected]> > > For policy questions, send mail to: > Jim Bacher: <[email protected]> > David Heald: <[email protected]> - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
