Safety Compliance

[renshen1957]

If a company called Keyser Söze Amplification pops up selling amps without providing any contact info, it's not me....

Hi,

That's interesting to know, but shouldn't this be in technical discussion as a new thread and in Garage Talk? Just saying.

Best regards,

Steve

[V2]

If a company called Keyser Söze Amplification pops up selling amps without providing any contact info, it's not me....

Hi,

That's interesting to know, but shouldn't this be in technical discussion as a new thread and in Garage Talk? Just saying.

Best regards,

Steve

It was just a joke, Steve. No need for a new thread.

[pdf64]

Might there be a distinction in the regulatory compliance requirements required for 'placing a product on the market' and a private contract in which a customer commissions a competent person to design / build equipment?
One being a product, the other a service, even though for a small time builder, whichever route was taken, the client would likely end up with custom built equipment.

[guitarmike2107]

Might there be a distinction in the regulatory compliance requirements required for 'placing a product on the market' and a private contract in which a customer commissions a competent person to design / build equipment?

no, no loop holes like that, I having worked a number of years building custom electro-mechanical equipment for customers you still have to comply with the EU directives regardless of the sales/marketing approach.

The 60065 standards are not law here (EU) but should you get sued you need to be able to evidence that your design was safe, and using the tests and procedures in the standard would help you do this.

You should also have some written procedures that control the production and testing and acceptance of production amps, according to a youtube amp I saw recently Fender do production HIPOT test on all there USA amps.

Many of the products we made we had to take photo's of, as it was common for the field techs to tinker with things when they shouldn't. so having photo evidence of the product before they leave is a good idea too.

It should be pointed out that if you build an amp for yourself, and it burns down your block of flats you would still likely be liable. so really we should all be encouraging best practice on the forums at all times.

[pdf64]

When going through the EMC regs a few years ago, it seemed that equipment designed and used solely within the organisation did not fall in scope, eg require a compliant design file, CE marking. Just needed to ensure that it wouldn't cause problems to the outside world, eg neighbours tv, overhead aircraft.
My thinking was that if the organisation had to bring in external help to produce such in-house equipment, then it should still be out of scope, and that could extend to the whole project being undertaken via contract to an external party.
And if an organisation could do that, so could a private individual, without obligations on the external party changing, ie the equipment would not fall in scope of the regs controlling the placement of products on to the market, eg require CE mark, compliant design file.

So a builder could design / build a custom amp to a customer's order, without necessity to demonstrate compliance to the regs applicable to such commercially available products.
Liability issues would still be there and require suitable mitigation, but only if something went wrong / a problem arose.
The point being that (according to my understanding as outlined above) the builder isn't at risk of action / prosecution from various regulatory authorities purely for selling a custom designed / build, non-CE marked amp.
As what they have sold is a service
And that would probably change if they advertised a standardised product for sale, probably even if that product was built to order and some features of the product could be modified in accordance with the customer's wishes. As they may be deemed to have placed a product on to the market.

[guitarmike2107]

All of the machinery I have designed is "custom" and where they are complete machines/appliances they have all been CE marked.

There are some loop hole in some standards, Pressure equipment has a similar one for pressure assemblies, where the installer takes responsibility for the final installation/usage. However even in those cases the parts of equipment we designed and manufactured had to have a declaration of incorporation, meaning that if it was installed in the safe and correct manner that it would be CE compliant.

I would think that by comparison with the PED and EMC directives, building and using an electrical appliance for your own use on your own premises would be a similar case, as long as it does not harm others.

Your case is hung around the definition of what placing on the market means, so pg 18 of this document may help.
http://www.mg.gov.pl/NR/rdonlyres/BBABE ... _Guide.pdf

I think our customers would be of the opinion that you are supplying them with electrical equipment that you have designed and manufactured and sold/given to them, though they may ask for features, they (generally) do not specify design or safety features.

[guitarmike2107]

The other scenario that comes to mind is if someone purchased a kit and asked you to build it, so it is essentially just a service you are providing.

I still think you would be legally required to CE mark the amp and keep a manufacturing and testing record for the product. Best to ask a specialist like Conformance ltd about that sort of thing....

[pdf64]

Ha, they've got you tied up every which way.
Thanks for your perspective on this.

[guitarmike2107]

That's just about the case, you can self certify to most directives though, so if you know how, it is achievable, we never tested electrical products to destruction, that is not a directive requirement and would not work for any company that builds custom, 1 off electronic equipment.

I have done design work for both transport and Oil and Gas sectors, you should see the paperwork files you have to put together for a diesel engine - triplex pump unit going into a potentially explosive atmosphere! certifying amps becomes easy in comparison....

I will maybe put together something on my site in the future to help.. if I ever get time

[pdf64]

'If you want something doing, ask a busy man'.
I think that any useful/ relevent CE compliance documentation, eg generic templates that can be amended to suit, may be beneficial to small time builders.
Maybe restrict access to recent customers, with a cut off below x£/PA, then at least you may get some benefit in terms of increased business.
To make it less daunting, how about making it a series of papers, each covering an aspect of one topic?
It may reach the stage where it may be feasible to make it a subscription service, perhaps along the lines of the TIPS safety and environmental compliance newsletters I used to get.

[guitarmike2107]

This is the sort of thing I started working on a few years ago.

http://www.mediafire.com/view/emyty2unz ... e_Test.pdf

I don't mind sharing information as I have learned allot from the forums in the first place. I have more of this sort of thing but it need revised.

[pdf64]

Yes, that's great!
Some guidance notes alongside might make it even better, eg what methods work to protect necessary markings from the petrol test?
And yes, keeping it maintained to current regs is an ongoing routine.

I don't see that deriving some compensation from providing such a suite of info should run counter to the ethos of the freely given info and guidance available in forums?
As there's a basic cost incurred in getting the current regs / standards, before you've even put any time into interpreting them and devising methods of compliance.

[renshen1957]

If a company called Keyser Söze Amplification pops up selling amps without providing any contact info, it's not me....

Hi,

That's interesting to know, but shouldn't this be in technical discussion as a new thread and in Garage Talk? Just saying.

Best regards,

Steve

It was just a joke, Steve. No need for a new thread.

Why I am the last one to get it?

[renshen1957]

duplicate after receiving notice that I had posted too soon after my previous post (on another topic).