Imported: SDOCs and industrial machinery
Posted: Tue Apr 14, 2020 8:08 am
mowgli
Oct 15 2018 07:47
Just looking at SDOCs here. Fully aware of appliance safety requirements.
Trying to work out whether an SDOC is required for a small CNC machine. Basically it\'s a flexible cord set, appliance inlet and small power supply with ELV output to drive the machine. All LV components are rated 230V 50Hz.
The only obviously relevant entry in the risk register is the flexible supply cord which is easily replaced with a locally sourced cord.
Less obvious is the power transformer incorporated into the machine. It\'s not for general use which rules out a few options. I reckon it could fit \"Constant voltage transformers and power supply units\" which would make it high risk requiring SDOC.
Does this sound right? The entire assembly doesn\'t fit any risk category which would mean no SDOC required. Is it correct to consider the machine components individually? In which case SDOC is required.
Sarmajor
Oct 15 2018 07:52
NO. You are overthinking this. You don’t have to pull the thing to pieces to get bits that might need an SDOC.
It is a CNC machine and they are not on the list of declared medium risk articles.
Look at the list with a critical eye and the majority of items are Domestically oriented.
mowgli
Oct 15 2018 07:57
Thanks Sarmajor
mowgli
Oct 15 2018 08:25
Sarmajor do you know of a reference for the appliance is not an assembly of fittings?
pluto
Oct 15 2018 12:28
AS/NZS 60335-1 is a base for all applicances made to a specified standard in the AS/NZS 60335 series.
A more basic standard to use would AS/NZS 3820 which gives the high level requirements and the labelling required.
Sarmajor
Oct 15 2018 13:06
I don’t understand your question.
mowgli
Oct 15 2018 13:35
Sarmajor, you assert and I agree, that you shouldn\'t have to disassemble an appliance to assess it against the DMRA register.
ESR says SDOC applies to fittings. It doesn\'t explicitly exclude fittings which are incorporated into appliance.
I\'m just wondering if there is a reference to support our assertion. Perhaps it\'s a grey area where commonsense should prevail.
AlecK
Oct 15 2018 17:37
I wish the writers of ESRs were half as careful with their words as you are reading them.
I agree that a CNC machine is not a DMRA, and that component parts of an item of equipment (avoiding the defined term \"appliance\") don\'t need to be considered.
But you\'re right that an \"appliance\", just like an \"installation\", is a collection of \"fittings\".
However as an installer, why worry? You don\'t need to see let alone posses a copy of an SDoC even for a DMRA.
Only sellers / suppliers need to care about SDoCs.
mowgli
Oct 15 2018 21:12
An importer friend asked me to help him fill out the SDOC paperwork. I wasn\'t sure he needed to and it appears he doesn\'t.
Regardless he\'ll still have to establish compliance with local standards.
Oct 15 2018 07:47
Just looking at SDOCs here. Fully aware of appliance safety requirements.
Trying to work out whether an SDOC is required for a small CNC machine. Basically it\'s a flexible cord set, appliance inlet and small power supply with ELV output to drive the machine. All LV components are rated 230V 50Hz.
The only obviously relevant entry in the risk register is the flexible supply cord which is easily replaced with a locally sourced cord.
Less obvious is the power transformer incorporated into the machine. It\'s not for general use which rules out a few options. I reckon it could fit \"Constant voltage transformers and power supply units\" which would make it high risk requiring SDOC.
Does this sound right? The entire assembly doesn\'t fit any risk category which would mean no SDOC required. Is it correct to consider the machine components individually? In which case SDOC is required.
Sarmajor
Oct 15 2018 07:52
NO. You are overthinking this. You don’t have to pull the thing to pieces to get bits that might need an SDOC.
It is a CNC machine and they are not on the list of declared medium risk articles.
Look at the list with a critical eye and the majority of items are Domestically oriented.
mowgli
Oct 15 2018 07:57
Thanks Sarmajor
mowgli
Oct 15 2018 08:25
Sarmajor do you know of a reference for the appliance is not an assembly of fittings?
pluto
Oct 15 2018 12:28
AS/NZS 60335-1 is a base for all applicances made to a specified standard in the AS/NZS 60335 series.
A more basic standard to use would AS/NZS 3820 which gives the high level requirements and the labelling required.
Sarmajor
Oct 15 2018 13:06
I don’t understand your question.
mowgli
Oct 15 2018 13:35
Sarmajor, you assert and I agree, that you shouldn\'t have to disassemble an appliance to assess it against the DMRA register.
ESR says SDOC applies to fittings. It doesn\'t explicitly exclude fittings which are incorporated into appliance.
I\'m just wondering if there is a reference to support our assertion. Perhaps it\'s a grey area where commonsense should prevail.
AlecK
Oct 15 2018 17:37
I wish the writers of ESRs were half as careful with their words as you are reading them.
I agree that a CNC machine is not a DMRA, and that component parts of an item of equipment (avoiding the defined term \"appliance\") don\'t need to be considered.
But you\'re right that an \"appliance\", just like an \"installation\", is a collection of \"fittings\".
However as an installer, why worry? You don\'t need to see let alone posses a copy of an SDoC even for a DMRA.
Only sellers / suppliers need to care about SDoCs.
mowgli
Oct 15 2018 21:12
An importer friend asked me to help him fill out the SDOC paperwork. I wasn\'t sure he needed to and it appears he doesn\'t.
Regardless he\'ll still have to establish compliance with local standards.