On December 29^th 2009 a new Machinery Directive, 2006/42/EC, came into force in the EEA (EU + Iceland, Liechtenstein and Norway) and Switzerland. Exporters of machinery to the states in this area should analyse the provisions as there are important changes in the new directive. Some of these are explained in this article.

Person authorised to compile the technical file

One of the changes is directed towards manufacturers outside the EEA. A person, that is authorised to compile a technical file, has to be appointed. The name and address must be presented in the Declaration of Conformity or in the Declaration for Incorporation. The agreement between this person and the manufacturer must be in a written form.

Relation to LVD (low voltage directive), 2006/95/EC

The old Machinery Directive gave the manufacturer of machinery the authority to choose to comply with the machinery directive or with the low voltage directive, if the risk assessment indicated that the electrical risks were the predominant. The new directive does not provide  this entitlement. Instead, the new directive contains a list of machinery that are excluded as they are covered by LVD.

The essential health and safety requirements of the LVD are included in the new machinery directive.

Manuals

Each state in Europe requires the manuals to be written in its official language(s). The requirements of the old directive were often understood that it was only the safety instructions that had to be written in the member state’s official language(s).  The new directive is clear; Product manuals have to be written in the member state’s official language(s), otherwise the product must not be sold or taken into service.

Harmonised standards

Machinery that is manufactured in conformity with a harmonised standard is presumed to comply with the essential health and safety requirements covered by such a harmonised standard. It must be observed that all standards that were harmonised with the old directive are not automatically harmonised with the new directive.

Partly completed machinery

The scope of the new directive has been expanded. It comprises not only completed machinery but also partly completed, defined as “an assembly which is almost machinery but which cannot in itself perform a specific application”. The only requirement in the old Machinery Directive on partly completed machinery was that the manufacturer had to draw up a Manufacturer’s Declaration (annex IIb). In the new directive, article 13 explains what has to be done before partly completed machinery is placed on the market in the EEA:

1. 1.       The manufacturer of partly completed machinery or his authorised representative shall, before placing it on the market, ensure that:

(a)  the relevant technical documentation described in Annex VII, part B is prepared;

(b)  assembly instructions described in Annex VI are prepared;

(c)   a declaration of incorporation described in Annex II, part 1, section B has been drawn up.

1. 2.       The assembly instructions and the declaration of incorporation shall accompany the partly completed machinery until it is incorporated into the final machinery and shall then form part of the technical file for that machinery.

Summary

The new Machinery is explaining the responsibilities of the manufacturers and of the representatives in more plain terms. Furthermore, it requires additional liability and accountability for partially completed machinery so that even though it might form part of the complete machinery the manufacturer is still held accountable for their product ensuring liability in case if non-compliance with the essential occupational health and safety requirements.

As the new directive requires a representative having the authority to compile a technical file, a manufacturer in Australia should consider expanding this mandate. The authorities in the EEA will never address a manufacturer outside the EEA with questions if they doubt that a product doesn’t comply with the provisions of the machinery directive. Instead the importer will be considered manufacturer and eventually held responsible for non-compliance. This could potentially result in importers in the EEA all requiring copies of the technical file. Instead of sending copies to several importers, an authorised representative established in the can receive a written authorisation from the manufacturer to perform on behalf all or part of the obligations and formalities relating to the machinery directive.

Contact Approval Specialists for assistance in placing your product on the European Market.

Sydney

• Combined Temperature -70°^C to +150°^C  and Humidity 30% – 98% rh Chamber for equipment 1m(w) x 1m(d) x 2m(h) 
•  Tropical Climate test chamber 2.4m(w) x 2.2m(d) x 2.8m(h) ,constant humidity 93%
• Temperature test chamber 4.8m(w) x 2.3m(d) x 2.8m(h)  10°C to 50°C
• Salt Spray Chamber 1m(d) x 2m(w) x .9m(h) continuous or periodic cycling salt mist with temp range 35-55^oC
• Vibration (call for specs)
• Water and Dust ingress capabilities to IP 67

Melbourne

• Combined Temperature and Humidity Chamber for equipment  0.9m(w) x 0.7m(d) 1.5m(h),   -30^oC to +70^oC,  Humidity up to 98%
• Miscellaneous ovens up to +200^oC

Salt Spray Chamber

 Analogue interworking and non-interference requirements for Customer Equipment for connection to the Public Switched Telephone Network (DR AS/CA S002:2010)

Requirements for customer cabling products (DR AS/CA S008:2010)

DR AS/CA S002:2010 is a revision of the 2005 edition of the Standard. It proposes new and revised requirements for power and voltage transmission limits (to cater for VDSL2 services), longitudinal balance and insertion loss, new recommendations for decadic signalling and keypad locks and the removal of the 50 Hz meter signal detection and Loop-in PSTN line requirements.

DR AS/CA S008:2010 is a revision of the 2006 edition of the Standard. It proposes revised requirements for cable materials, conductor composition, special applications cables and aligning the requirements for earthing of enclosures and access to terminations with AS/ACIF S009 Installation requirements for customer cabling. The requirements for surge protective devices are proposed to be removed as they are addressed in other Standards.

PUBLIC COMMENT PERIOD CLOSES AT 5.00 P.M. ON 6 SEPTEMBER 2010

Communications Alliance welcomes your input. Copies of these documents can be obtained from our website www.commsalliance.com.au/Documents/public-comment  

All submissions received will be made publically available on the Communications Alliance website. (Austest Laboratories is a member of the Communications Alliance).

The following banned travel adaptor is a good example.

“These adaptors are unsafe as they do not offer adequate protection from contact with live parts, to the point where live 230 volt parts can be accessed and touched easily.

“Energy Safety is concerned about this style and type of adaptor, particularly as they may be used at skirting board level and could be easily accessible to small children and infants,” says Richard Lamb, Energy Safety Compliance Officer.

The adaptors have been sold through tourist gift shops and pharmacies and on online auction sites such as Trade Me.  A supplier, Melric International Limited, has already initiated a voluntary recall.  It is believed the adaptors first appeared in late 2007.

Plug adaptors are intended for use by overseas travellers with small low power personal appliances that they carry with them, such as a cell phone charger, laptop computers, or battery charger for camera equipment.

“Energy Safety’s advice is do not use these universal adaptors, return them to where you purchased them and seek a refund,” says Richard Lamb.” (extract, NZ Ministry of Economic Development, Energy Safety).

AS/NZS 60335

• Part 2.2 Vacuum Cleaners and Water-Suction Cleaning Appliances
• Part 2.21 Storage Water Heaters
• Part 2.31 Range Hoods
• Part 2.43 Clothes Dryers and Towel Rails
• Part 2.54 Surface Cleaning Appliances including Steam Cleaners
• Part 2.75 Commercial Dispensing Appliances and Vending Machines
• Part 2.82 Amusement Machines
• Part 2.89 Commercial Refrigerating Appliances

Lighting

• AS/NZS61347.1 Lamp Controlgear – General and Safety
• IEC/EN61347-1 Lamp Controlgear – General and Safety  
• IEC/EN 61347-2-13 Particular Requirements for d.c or a.c supplied electronic controlgear for LED modules

 IP Testing to AS/NZS & IEC & EN 60529

 MEPS

• AS/NZS 62301 Measurement of Standby Power
• AS/NZS62087.1 Power Consumption of Audio and Video Equipment General
• AS/NZS 62087.2.1 Power Consumption Digital Television Set-Top Boxes
• AS/NZS 62087.2.2 Power Consumption of Television Sets

Austest Laboratories is accredited for the above testing by A2LA, the American Association for Laboratory Accreditation.  Austest has chosen A2LA as our accreditation provider, giving our customers the widest possible global acceptance of accredited reports. A2LA has accredited more than 2000 organisations and is a signatory to several multilateral mutual recognition arrangements including the International Laboratory Accreditation Cooperation (ILAC), the Asia Pacific Laboratory Accreditation Cooperation (APLAC), and the InterAmerican Accreditation Cooperation (IAAC). A2LA and NATA (National Association of Testing Authorities) are both signatories to the ILAC and APLAC MRA’s for mutual acceptance of test data and reports.

A copy of our complete scope of accredited testing including EMC and Telecommunications is downloadable from here

This has now been clarified with JATE producing an english version here.. Interpretation_Art9. 

Please direct certification questions regarding JATE to Ms Chun Kim

Enquiries to austest@austest.com.au

The EMR Standard differentiates between devices used by an aware user (generally understood to be a device used in a controlled environment by professional or trained users), and a non-aware user (generally understood to be a device that is used in an uncontrolled environment by the general public or untrained users).  Controlled environments could be restricted areas where EMR hazard prone areas are clearly demarcated and/or have warning labels displayed.

Such devices have to comply with their respective Compliance Levels depending on the device Category (either A or B) they fall into (defined in the EMR Standard), as detailed below:

Compliance Level 1 Devices

 This applies to Category A devices only, i.e. a device that is an aware or non-aware user device, and not required to be evaluated under Sections 5.2 and 5.3 of Schedule 5 of the ARPANSA standard (relevant ARPANSA RPS3 extracts are provided below).

 S5.2.2 Equipment with mean power output not exceeding 100 mW (regarding aware user devices).

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where the nominal mean power output delivered to the antenna does not exceed 100mW.

S5.2.3 Equipment with mean power output exceeding 100 mW (regarding aware user devices).

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where:

(a) it operates on a push-to-talk basis;

(b) it is used by an aware user;

(c) it is operated with a transmit duty factor of 50% or less averaged over a six minute period;

(d) it does not exceed the power levels of Table S2 (in ARPANSA RPS3); and

(e) normal operation entails the antenna or other radiating structure being separated from the user’s body by not less than 2.5cm.

 S5.3.2 Equipment with mean output power not exceeding 20 mW (regarding non-aware user devices).

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where the nominal mean power output delivered to the antenna does not exceed 20 mW.

S5.3.3 Equipment with mean output power exceeding 20 mW (regarding non-aware user devices).

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where:

(a) it operates on a push-to-talk basis;

(b) it is operated with a transmit duty factor of 50% or less averaged over a six minute period;

(c) it does not exceed one fifth (20%) of the power levels of Table S2 (in ARPANSA RPS3); and

(d) normal operation entails the antenna or other radiating structure being separated from the user’s body by not less than 2.5cm.

The evaluation of mobile or portable transmitting equipment for compliance with this Standard is not required where the output power delivered to the antenna does not exceed the levels of Table S2 and normal operation entails the antenna or other radiating structure being from the user’s body by not less than 20 cm.

In essence, devices with a mean output power less than 100mW (for aware user devices) / 20mW (for non-aware user devices) are deemed to comply without the need for further testing.  Where devices exceed these power levels, they can still be deemed to comply if they meet the respective criterion of S5.2.3 or S5.3.3 depending on the intended usage environment of the device.  Examples of Compliance Level 1 devices are analogue cordless phones, handheld CB radios used for recreational or domestic purposes, remote garage door openers and the like.

 To comply with compliance level 1, the supplier of a device must:

(a) prepare a description of the device; and

(b) make a declaration of conformity for the device.

 Compliance Level 2 Devices

 This applies to a Category B device (i.e. not a Category A device) for which the normal position of use is more than 20cm from the human body.

 Such device are assessed in accordance with AS 2772.2 standard, which uses a calculated approach, taking into account the transmitter power to the antenna, the antenna gain, and the intended distance of the antenna from the human body.

Typically, examples of such devices or system comprising the transmitter connected to a transmitting antenna would be radio broadcast transmitters, cellular (GSM/UMTS) transmitters, transmission relay stations and the like.

 To comply with compliance level 2, the supplier of a device must:

(a) comply with compliance level 1; and

(b) show conformity with the applicable standard by a report of the results of assessment.

 Compliance Level 3 Devices

 This applies to a Category B device (i.e. not a Category A device) for which the normal position of use is within 20cm from the human body.

 For devices that are used in close proximity to the human ear (e.g. mobile phones), measured SAR levels need to be in accordance with EN 62209-1 method.  Any other SAR measurement method is not acceptable to demonstrate compliance with the Australian Radiocommunications (Electromagnetic Radiation – Human Exposure) Standard 2003.

 For devices not used in close proximity to the human ear, but within 20cm of the human body (e.g. body worn devices that are not Category A devices), the measurement method to be applied is as detailed in Schedule 2 of the Australian Radiocommunications (Electromagnetic Radiation – Human Exposure) Standard 2003.

Examples of such devices are our mobile phones, digital cordless phones and the like.

 To comply with compliance level 3, the supplier of a device must:

(a) comply with compliance level 1; and

(b) show conformity with the applicable standard by a report of the results of assessments by an accredited testing body.

Approval Specialists and Austest Laboratories provide low cost report evaluations to determine if existing test data meets local requirements.

Given their broad spectrum of transmission and the future possibility of numerous UWB devices in home applications, there is the potential for interference with existing radiocommunications services or other home devices, once multiple UWB devices are operating in the 1 location.  This is due to multiple devices increasing the ambient “noise floor” within a specific environment.  While 1 UWB device may have transmissions that sneak under the EMC CISPR emission noise floor for a Class B device, there’s no doubt that multiple devices will have an additive effect.

It can be argued that electronic devices in European homes and businesses are well equipped to handle noise via the EMC immunity test requirements of the CE Marking EMC Directive. 

This is not the case in Australia or New Zealand, where the ACMA and NZ MED do not require immunity testing of products.  Previous (dubious) arguments for not invoking EU style EMC Immunity requirements in Australia and New Zealand have included the less densely populated nature of Australian and New Zealand communities compared with those in Europe.   This argument becomes invalid when there are so many products in a home competing for the same limited transmission spectrum (typically from 900MHz to 4GHz).

The use in each home of multiple UWB devices, 802.11a/b/g/n, Zigbee, Bluetooth, 2G, 3G, Femtocells and soon 4G, creates a huge potential for interference issues that remain unaddressed by the ACMA’s current and banal C-Tick regime for general products and LIPDs.      

Contact our Australian lab for EMC emission testing of a wide range of products or LIPD testing to AS/NZS4268 for 802.11x/Bluetooth/RKE/RF devices.

The ACMA have produced a discussion paper on UWB with the closing date for submission on 7 June.  Further information can be found here.

The certification process will be further strenghtened at the end of the year when only test results from approved, accredited labs will be accepted as evidence of compliance. 

For A2LA (The American Association for Laboratory Accreditation) accredited MEPS testing, contact our Australian lab www.austest.com.au