New requirements on Machinery in Europe

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.

Austest Sydney and Melbourne have expanded their environmental test capabilities with new Salt Spray and Temperature/Humidity chambers.  This testing is suitable for tropical country climate tests, AS/NZS 4601 and standards such as those relating to Taxi Cab Alarm Systems / passenger transport regulation 2007.

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

Australias’ Communications Alliance Ltd invites public comment on the following two draft Standards:

 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).

Australian and New Zealand importers should be careful when considering purchase and importation of travel adaptors for sale or distribution  Austest and Harvest Labs have received numerous submissions from clients for testing and certification of travel adaptors, resulting in most failing to meet AU/NZ requirements and in particular, the dimensional requirements within AS/NZS 3112 as referenced by AS/NZS3122.

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).