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Presentation. 6. Joakim Franzon SP Electronics Electrical safety LVD issues compared to other directives. Normally an appliance is covered by more than one directive! Which directive is valid, is all directives valid? How to determine which directive that is applicable?

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Joakim Franzon

SP Electronics

Electrical safety

Lvd issues compared to other directives
LVD issues compared to other directives

  • Normally an appliance is covered by more than one directive!

  • Which directive is valid, is all directives valid?

  • How to determine which directive that is applicable?

  • Can the manufacturer or the person responsible for the product choose directive?

  • LVD – Machinery Directive

Risk assessment
Risk assessment

  • To determine if the specific product can be excluded from the scoop of for example the Machinery directive and only be considered to be in the scoop of LVD, the manufacturer has to perform a risk assessment of that product. Standard EN 1050 (Safety of Machinery – Principles for risk assessment) gives the principles for risk assessment.



Risk assessment

Machinery Directive

Risk assessment1
Risk assessment

MDThe manufacturer shall perform a risk analysis in order to eliminate any risk or hazard throughout the foreseeable lifetime of the machinery.

LVDNo specific requirement regarding risk analysis stated in the LVD directive. The risk analysis has been made when developing the harmonised standard.

Electrical risks/ hazards:-Electric chock-Fire due to electrical installation/ dimensioning/ design-Electrical current-Energy related hazards-Heating

The term machinery means
The term machinery means

  • an assembly of linked parts orcomponents, at least one of whichmoves, with the appropriate actuators,control and power circuits, etc., joinedtogether for a specific application, inparticular for the processing, treatment,moving or packaging of a material

  • an assembly of machines which, in order to achieve the same end, are arranged and controlled so that they function as an integral whole

  • interchangeable equipment modifying the function of a machine, which is placed on the market for the purpose of being assembled with a machine or a series of different machines or with a tractor by the operator himself in so far as this equipment is not a spare part or a tool

Lvd machinery directive
LVD – Machinery Directive

Example 1:

Commercial electrical boiling pan:

As investigated (risk assessment according to 98/37/EEC) by the technical committee CENELEC TC 61, it is shown that risks with products as commercial electrical boiling pans having mechanical moving parts is mainly of electrical origin and therefore the Machinery directive is not valid. When testing according to a harmonised standard to The Low Voltage Directive, relevant essential safety requirements of Machinery Directive is covered.

Lvd machinery directive1
LVD – Machinery Directive

Example 1:

Commercial electrical boiling pan:

Although when comparing the machinery directive with the standard EN 60 335-2-47, which is an harmonised standard according to LVD, this standard does NOT deal with risks as malfunction in logical circuits and risk for crushing hands and other parts of the body. Those risks are covered by the Machinery Directive.

Lvd machinery directive2
LVD – Machinery Directive

  • Extract from guidelines on the application of

  • Directive 73/23/EEC (Low Voltage Directive):

“Where, for machinery, the risks are mainly of electrical origin, such machinery shall be covered exclusively by Council Directive 73/23/EEC of 19 February 1973 on the harmonisation of the laws of the Member States relating to electrical equipment designed for use within certain voltage limits.”

Lvd machinery directive3
LVD – Machinery Directive

  • Conclusion:

  • The hazards has to be determined. If the hazards is mainly of electrical origin the LVD shall be used. If the hazards is mainly of mechanical origin the Machinery Directive shall be used.

  • The manufacturer performs the risk assessment.

  • The manufacturer does not chooses which directive to use, it depends on the result of the risk assessment.

Lvd machinery directive4
LVD – Machinery Directive

  • Example 2:Hand-held and transportable electrically driven tools:

  • The LVD Working Party has agreed that standards covering this type of equipment shall be published only under the “Machinery” Directive in the Official Journal of the European Communities, and hence it has been agreed to apply the conformity assessment procedures of the “Machinery” Directive rather than those of the LVD.

Differencies in directive texts
Differencies in directive texts

  • LVD The electrical equipment may be placed on the marketonly if, having been constructed in accordance with goodengineering practice in safety matters in force in the Community,it does not endanger the safety of persons, domestic animals or property when properly installed and maintained and used in applications for which it was made.

  • MDThe manufacturer shall follow the principles of safety integration. Machinery must be so constructed that it is fitted for its function, and can be adjusted and maintained without putting persons at risk.

Voltage limits lvd compared with other directives
Voltage limits, LVD compared with other directives

  • LVD 50 V a.c. – 1000 V a.c. 75 V d.c. – 1500 V d.c.

  • MD No specific voltage limit All hazards of an electrical nature shall be prevented

  • R&TTENo specific voltage limit. The LVD shall be used when testing the safety aspects

  • Equipment outside the voltage limits?– No CE-marking required but national laws applicable. The equipment shall comply with good engineering practice.

Lvd r tte directive
LVD – R&TTE Directive

  • If the equipment, or relevant components, falls under the R&TTE Directive it must meet the requirements of all applicable directives that the equipment falls under. The R&TTE Directive does not have its own detailed requirements, and refers therefore to the safety objectives of the LVD, but with no voltage limit applying.