Issue 1

Choosing a New Approach Directive

 
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Laidler Associates Consulting Service
The Essential Requirements of a New Approach Directive deal in particular with the health and safety of users (both workers and consumers) and can also cover other fundamental requirements such as protection of property or the environment.

Because of the nature of the Essential Requirements, it is often the case that in order to fully cover all the relevant public interests, several directives may need to be applied simultaneously.

Joint application requires the product concerned to be designed and manufactured according to all applicable Directives as well as to go through the assessment procedure for all applicable Directives, unless stated otherwise.

Joint Application of Directives
In the Machinery Directive, the Essential Requirements cover all aspects of any particular machine including controls, indicators, maintenance, characteristics of guards and protection against hazards.

Paragraph 1.5 “Protection against other hazards”, is the key section when applying multiple Directives. Paragraph 1.5.1 states that “where machinery has an electrical supply it must be designed, constructed and equipped so that all hazards of an electrical nature are or can be prevented”.

The recognised route to compliance is by the application of BS EN 60204:1 Safety of machinery: Electrical equipment of machines: General requirements. This is a Type B standard for the Machinery Directive and is applicable to all machinery types. It is also a general standard for the Low Voltage Directive (LVD), and it’s correct application fulfils the requirements of LVD for machinery.

Paragraph 1.5.10 Radiation states that “any emission is limited to the extent necessary for it’s operation”, and paragraph 1.5.11 External Radiation states “external radiation does not interfere with its operation”. Electromagnetic interference produced by electrical and electronic products falls under the scope of emitted radiation; hence compliance with EHSR 1.5.10 and 1.5.11 requires the application of the EMC Directive. Testing to discover the levels of emitted radiation is likely to be required, even if CE Marked parts have been used. It is the overall level of emitted radiation that is important, therefore even though the individual parts may comply in isolation, together they may fall outside of allowed limits and only testing will indicate this.

Hazards covered by the Essential requirements of New Approach Directives may concern different aspects that are complimentary to each other. As a result, several directives may need to be applied at the same time in order to cover all of the relevant public interests.

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