Peter As you note, the term "independently placed on the market" is in the Machinery Directive, so appears unchanged in concept in the MR At the moment I think Machinery Guide ยง42 Safety components is still the most useful guidance, along
At the beginning of July, The EU Commission has issued Draft standardisation request to CENELEC and CEN support of Regulation (EU) 2023/1230 - 5 new standards - updates to a number of other standards - To be completed within 18 months !! https://ec.europa.eu/docsroom/documents/60695?locale=en Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Peter Tarver <[email protected]> Sent: Saturday, August 10, 2024 12:06 AM To: [email protected] Subject: [PSES] Machinery Regulation - safety components In reviewing the Machinery Regulation, Article 3 defines a safety component as "...means a physical or digital component, including software, of a product within the scope of this Regulation, which is designed or intended to fulfil (sic) a safety function and which is independently placed on the market, the failure or malfunction of which endanger the safety of persons, but which is not necessary in order for that product to function or for which normal components may be substituted in order for that product to function; (emphasis added.) The component falls under Annex I, Part, B but is only sold to OEMs 1) whose equipment would clearly fall under the Regulation, and 2) who integrate the component into other equipment before that other equipment is placed on the market, but 3) is not "independently placed on the market," for general sale, is there any reason to conclude that the Regulation does not apply to the component? The product is sold into the EU for applications other than those that would be subject to the Regulation, so it seems that applicability could depend on the interpretation of "independently" in the context of the regulation. Or is the use of "independently" intended to mean "not manufactured by the OEM for their own use?" I note that similar language existed in the Machinery Directive. My approach is to apply an abundance of caution and presume the Regulation applies, but I'd appreciate the input of the group. A final couple of questions: should it be assumed that the same standards published in the EU OJ for the Machinery Directive will satisfy the Regulation until a separate list of standards is published and linked to the Regulation? Also, is there a view on when such a list will be published? Regards, Peter Tarver ________________________________ 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]<mailto:[email protected]> All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/[email protected]/<https://www.mail-archive.com/[email protected]/%20> Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe)<https://ewh.ieee.org/soc/pses/list.html> List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: [email protected]<mailto:[email protected]> Rick Linford at: [email protected]<mailto:[email protected]> For policy questions, send mail to: Jim Bacher at: [email protected]<mailto:[email protected]> ________________________________ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1 - ---------------------------------------------------------------- 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: https://www.mail-archive.com/[email protected]/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: [email protected] Rick Linford at: [email protected] For policy questions, send mail to: Jim Bacher: <[email protected]> _________________________________________________ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1
