Imported: SDOCs and industrial machinery

[DougP]

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.

[RikN]

I'm new to solar installs, and have been off the tools for a while. I am looking to install an AC coupled Fronius PV inverter and a Selectronic battery inverter. However when I asked the supplier for the sDOCs I received other papers. The DHRA is for domestic items as I see it. And inverters are not listed. So are JAS-ANZ and TUV certificates suitable alternatives.

[AlecK]

While a certifier can rely on an SDoC for a DMRA [ESR 83]; if one doesn't exist there's no alternative that we can rely on.

That said, any inverter installed as grid-connected must be installed i.a.w "4777.1"; which in turn requires the inverter to comply with 4777.2 & 4777.3. So you need to be looking for a written claim that it complies; so look at what those JAS / TUV certs actually say.
If they don't claim compliance with AS 4777 (or the later AS/NZS 4777) series; you're on thin ice
if it dfoes claom compliance with 4777; you still can't rely on such a document - but it would count as supporting evidence.

[RikN]

Thanks for the detail Alec
The system I am looking at is off grid.
Though the supplied certs claim 4777.2 compliance. (only the battery inverter claims 4777.3)

What doesn't make sense to me is for prescribed electrical work certified parts are required, but a supplier does not have to sell electrical devices with an SDOC.

[AlecK]

Welcome to the big wide world where installers have to accept responsibility for what we install as well as for how we install it.

How we install is relatively easy; just comply with the ESRs & cited Standards.

For what we install we can mitigate our risk by being careful about selection of fittings.
We have some (very) limited bum-cover when it comes to DMRAs & DHRAs; but generally we have to make our own decision as to whether something is "electrically safe".

For high-risk PEW, we also have the benefit of independent checking by an inspector.
And in some cases, we have a "certified design" - in which case we only have to follow the design.
But even under a CD, we only get limited bum-cover as we can only rely on it 'in good faith";
meaning if there's obviously something unsafe about the design we need to challenge it.

We can't completely avoid responsibility; because ultimately it's our choice whether to install something.
That said, as long as we are not reckless; we're unlikely to get into trouble.