Vacuum and compressor automation

[Blaspark]

.

 

[Blaspark]

An MK grid switch assembly is covered by MK, if it is done in accordance with their instructions.
Devices such as a GET light switch and a BG patress back box, are designed and the standards are written in such a way that they can be assembled in an ad-hoc manner, as long as they fit together correctly.
Metal clad sockets and switches often have "custom" back boxes and one make of socket won't fit another makes back box correctly, then the product law would kick in, and you would be in breach of it, because they were not designed to be as one assembly.

From what your saying it sounds like if we're following manufacturers instructions and not building a machine it's fine.

 

[netblindpaul]

From what your saying it sounds like if we're following manufacturers instructions and not building a machine it's fine.

Unless you are doing the work in the course of a business, and it is to be used outside your business premises.
So in the course of your business, if you buy a Schneider panel and put a load of Schnieder control gear in it and a Schneider PLC to control the lighting in a customers premises, it must be CE marked to the LVD by you.
If it's real DIY at home then it doesn't matter until you sell it, in which case it probably will even if it is to another DIY'er and it's already 2nd hand.

 

[netblindpaul]

"I'm just trying to get an idea of how far this goes"

Me too seems we could come close in commercial installations fairly regularly

Yes you could, if you put a box of bits together without thought, for example a lighting panel, or a control panel for some extract fans, then you must follow the procedure and CE mark it, lighting would be to the LVD, and fans to the MD, Air con panels, MD, LEV panels MD, Heating panels, could be either depending on the heating system.

 

[Blaspark]

Yes you could, if you put a box of bits together without thought, for example a lighting panel, or a control panel for some extract fans, then you must follow the procedure and CE mark it, lighting would be to the LVD, and fans to the MD, Air con panels, MD, LEV panels MD, Heating panels, could be either depending on the heating system.

To be honest I think my insurance doesn't cover any of that and I don't want to expose myself to the liability. Ce marking has fines attached if you c**k it up.

I think my focus, and same for most people here, should be avoiding the whole ce business.

 

[netblindpaul]

Avoidance is up to you, but remember, lots of products are already CE marked, and modifications to them eliminate that and put the "person" modifying them in the firing line as the manufacturer.
This includes machinery repairs.
Because I have always done this sort of work, when I went self-employed, well 1 person ltd co with my own customer base rather than doing labour only subbying, I went looking for insurance, and found that my core business of machinery repairs and upgrades etc. was excluded from most insurance policies offered to electrical contractors, it was a surprise how many policies when you read the small print excluded 3ph work too.
We probably pay as much a month for insurance to do the consulting, machinery repairs & modifications, design & provision of electrical panels etc. and general electrical contracting and maintenance (7671 stuff) as many of you do in a year.
There is still stuff on the consulting side that I can't do for people because I know I'm not insured, validation of safety software under IEC 62061 for example, I've also not got enough experience in all the possible PLC makes to put myself forward as an expert to do the safety training on the makes, to be competent to do the validation.
This is one area where HSE have even issued guidance on competency, and it is quite an eye opener.
I will eventually drop off the contracting stuff, but it makes so little difference in the cost of the policy it's handy to keep it there because if I do a job for friends or family then I'm still covered.

Remember, we've not even touched on COMAH site stuff, IEC 61508, chemical process plants and the like. That's just as critical, and changes there could cause major issues, normally in these environments they have change control mechanisms in place.
Though smaller operators may not be so careful, and could land a contractor in trouble.

 

[Blaspark]

Avoidance is up to you, but remember, lots of products are already CE marked, and modifications to them eliminate that and put the "person" modifying them in the firing line as the manufacturer.
This includes machinery repairs.
Because I have always done this sort of work, when I went self-employed, well 1 person ltd co with my own customer base rather than doing labour only subbying, I went looking for insurance, and found that my core business of machinery repairs and upgrades etc. was excluded from most insurance policies offered to electrical contractors, it was a surprise how many policies when you read the small print excluded 3ph work too.
We probably pay as much a month for insurance to do the consulting, machinery repairs & modifications, design & provision of electrical panels etc. and general electrical contracting and maintenance (7671 stuff) as many of you do in a year.
There is still stuff on the consulting side that I can't do for people because I know I'm not insured, validation of safety software under IEC 62061 for example, I've also not got enough experience in all the possible PLC makes to put myself forward as an expert to do the safety training on the makes, to be competent to do the validation.
This is one area where HSE have even issued guidance on competency, and it is quite an eye opener.
I will eventually drop off the contracting stuff, but it makes so little difference in the cost of the policy it's handy to keep it there because if I do a job for friends or family then I'm still covered.

Remember, we've not even touched on COMAH site stuff, IEC 61508, chemical process plants and the like. That's just as critical, and changes there could cause major issues, normally in these environments they have change control mechanisms in place.
Though smaller operators may not be so careful, and could land a contractor in trouble.

"Though smaller operators may not be so careful, and could land a contractor in trouble"
I'm pretty sure ignoring most of what you say is normal practice. How can one avoid the bs?

Also you gave the example of me making a lighting system using all schneider gear saying that I'd have to mark it. There seems to be slightly different rules for fixed installations something we haven't covered in this chat. I'm new to this but watching a video from Queen University. The lecture says for fixed installations "you don't ce mark it, you don't provide a declaration of conformity but it has to comply with the protection requirements".

Those are his words not mine. I'm not sure why he says it.
8 minutes into this video he says it.

 

[netblindpaul]

That video is entitled EMC Directive, we’ve not even got as far as discussing this yet.
What you state is correct wrt a fixed installation under BS7671, as an assembly of CE marked components.
However the components that are used to put the installation together are not exempt from anything.

 

[David Prosser]

How are you going to complying with the CE directive and EN60204-1 to start with?

I thin

If this is a stand alone control panel, then yes, and BS 7671 would not be the relevant standard. If it is for lighting it would be the EN 61439 series, and you must CE mark in accordance with the Low Voltage Directive.
If it is to control machinery then the design and build standard would be EN 60204-1 (for general machinery, there are a couple of specific machine types that are outside this).
Using all CE marked components does not make the assembly CE marked.
I can take you through every reason if you like, but we'll be here a very long time, and I'm off to China Saturday for a few weeks, to advise a Chinese machinery builder on CE marking of their machinery and electrical panels.
I do much more of this now than I do electrical works, as my background is in machinery, and I used to do this before redundancy and self-employment.
What Rob has said is correct.

If you are designing and building electrical panels, there is a lot more involved, as the panel becomes a product in its own right, and that must be CE marked.

If it is controlling machinery, then the assembly of panel and machine must comply with the Machinery Directive.

This is the same concept as when you mix and match MCB's in a distribution board, like it or not, when you do that, you become the manufacturer of the assembly in the eyes of the law.

Oh, and as of the end of March no matter what happens, the only thing that changes will be CE being becoming UKCA marking for the UK market.

It's not a stand alone control panel though. It a key switch instead of a normal light switch that switches all the lighting on through a relay in the distribution board.

 

[Blaspark]

I thin



It's not a stand alone control panel though. It a key switch instead of a normal light switch that switches all the lighting on through a relay in the distribution board.

I checked with stone-emc.co.uk, who I'd recommend for all your emc/ce work needing done, and they say no ce mark needed nor pre-compliance emc testing. He says the same as the guy in the video. What's required is good engineering practice and to follow manufacturer's instructions.
That goes for the simplest example and controlling the lights with a plc.
It's different if your equipment isn't fixed or you're selling it as an end user product.
Also the siemens forums are empty of comments on this because no one is doing it. They are, however, full of questions on how to correctly follow the manufacturer instructions.

 

[netblindpaul]

We never got as far as EMCD, I was only going through LVD & MD, how did this get to EMCD?

 

[Blaspark]

We never got as far as EMCD, I was only going through LVD & MD, how did this get to EMCD?

When does emcd apply? Have I lost the plot? You were talking about ce certification? Does ce certification not always include emc?
Also maintaining compliance with emc directive is actually required in all examples given? It's just done by good engineering practice and following manufacturers instructions. Testing is not normally required though it may be, it would seem.

 

[netblindpaul]

I thin



It's not a stand alone control panel though. It a key switch instead of a normal light switch that switches all the lighting on through a relay in the distribution board.

That depends on what it is, if you put it together and fit it, it's a product, which means it must meet the LVD.

I am struggling to understand why this thread has moved from LVD compliance on to EMC compliance.
The requirements of the two directives are totally different.

 

[Blaspark]

That depends on what it is, if you put it together and fit it, it's a product, which means it must meet the LVD.

I am struggling to understand why this thread has moved from LVD compliance on to EMC compliance.
The requirements of the two directives are totally different.

You're right it must be in compliance with lvd. This topic has included other factors as any conversation in this area should

Can I ask the name of your company?

 

[spark 68]

Interesting and fascinating discussion about CE marking and EN standards as ever chaps however the OPs location is given as South Africa, I don't think any of these directives apply to him , no doubt similar national/international equivalent standards do though.